EPA weighs comments on low carbon materials, product labeling

The Environmental Protection Agency is set to review feedback from a February-March public comment period involving a draft approach for implementing an Inflation Reduction Act-funded Label Program for Low Embodied Carbon Construction Materials. The $100 million undertaking will support the White House Buy Clean Initiative, applicable to Departments of Defense and Transportation and General Services Administration procurement, by helping define what constitutes “clean” construction materials. “The program will expand market access for lower embodied carbon construction materials and help federal purchasers prioritize these materials,” says EPA Office of Chemical Safety and Pollution Prevention Assistant Administrator Michal Freedhoff.

The draft approach proposes a) to standardize and improve the data that manufacturers and suppliers use in developing environmental product declarations, which chart key environmental impacts measured up to site delivery; b) a process by which EPA would use data from EPDs and other sources to set thresholds for the amount of embodied carbon a material or product can have to qualify for the low embodied carbon label; and, c) a material or product certification method along with a companion registry.

“As part of the Buy Clean Initiative, the federal government has begun procurement of over $4 billion in American-made low embodied carbon steel, concrete, asphalt, and glass for use in federal projects,” notes White House Council on Environmental Quality Chief Sustainability Officer Andrew Mayock.

“EPA’s work on creating a Carbon Label Program will support the Department of Transportation and our stakeholder efforts to promote the use of low carbon construction materials by increasing transparency and consistency for tracking environmental considerations,” adds DOT Deputy Assistant Secretary for Policy Ann Shikany.

On the heels of the public comment period for the Label Program draft approach, EPA invited feedback on “Criteria for Product Category Rules (PCRs) to Support the Label Program for Low Embodied Carbon Construction Materials.” The 30-page document offers guidelines to improve PCRs by establishing consistent EPD data quality and transparency requirements. The proposed criteria suit PCR Program Operators, committee members (trade associations and their producer or manufacturer members) and review panels, plus Life Cycle Assessment interests.

Climate and other environmental impacts detailed on EPDs abiding the PCR Criteria will determine construction material or product eligibility in the EPA’s broader Label Program for Low Embodied Carbon Construction. EPA plans to award $100 million in Inflation Reduction Act grants as the Label Program takes shape and construction materials or products interests develop and verify EPDs. Declarations generated through the grant program will make it easier for interested purchasers to ensure the construction projects they fund are using lower embodied carbon construction materials. The PCR Criteria will support both grantees and the broader marketplace in developing robust product EPDs.


“Criteria for Product Category Rules” provides sample chart templates for EPA Label Program-compliant Environmental Product Declarations.