Label Program for Low Embodied Carbon Construction Materials

November 1, 2024

The EPA is implementing a new label program to help federal purchasers and other buyers find and buy cleaner, more climate-friendly construction materials and products. The label program is made possible by a $100 million investment from the Biden-Harris Administration’s Inflation Reduction Act and aims to cut climate pollution linked to the production of construction products and materials, which accounts for more than 15% of annual global greenhouse gas (GHG) emissions. The Inflation Reduction Act invests billions of dollars to reduce industrial emissions while supporting good jobs, greater equity, and a strong manufacturing base, including $350 million to support EPA’s efforts to reduce GHG emissions from construction materials.

Label Program Approach

On August 7, 2024, the EPA issued its Label Program Approach for Identifying Low Embodied Carbon Construction Materials. The label program will define what constitutes “clean” construction materials in support of the Biden-Harris Administration’s landmark Buy Clean Initiative, which leverages the Federal Government’s power as the world’s largest purchaser to catalyze demand for clean construction materials used in federal buildings, highways, and infrastructure projects. Materials and products that earn the label will be listed in a central, publicly accessible registry, making it easier to identify—and therefore purchase—these materials.
The label program will prioritize steel, glass, asphalt, and concrete, as there are significant opportunities to reduce carbon emissions from these materials and they represent the vast majority of construction materials and products purchased with federal funds.
The EPA will implement the program using a phased approach that all material categories will be able to follow, at a cadence that aligns with the material’s market maturity and data availability. The phases are:
  • Phase I: Data Quality Improvement. Standardizing and improving the quality of data underlying and provided by Environmental Product Declarations (EPDs).
  • Phase II: Threshold Setting. Using robust EPDs, data, and other credible and representative industry benchmarks to determine thresholds for specific material categories and types.
  • Phase III: Labeling Materials and Products. Labeling materials and products that meet EPA’s criteria.

What Is Embodied Carbon?

Embodied carbon, also known as embodied greenhouse gas (GHG) emissions, refers to the amount of GHG emissions associated with upstream—extraction, production, transport, and manufacturing—stages of a product’s life. Many initiatives to track, disclose, and reduce embodied carbon emissions also consider emissions associated with the use of a product and its disposal.

WHAT TO KNOW:

CO2 emissions are not going to become greener, but insulation materials are low embodied carbon products AND also prevent CO2 from being release into the environment at all.

Why Does it Matter?

The U.S. industrial sector is linked to nearly a third of annual U.S. GHG emissions, and the manufacturing of construction materials and products accounts for 15% of annual global GHG emissions. EPA is joined by 12 other federal agencies on the Buy Clean Task Force, who together account for 90% of all federally financed and purchased construction materials. Agencies are working to identify actions to reduce GHG emissions and climate change impacts comprehensively, including optimizing salvage, reuse, and low embodied carbon materials. Increasingly, states, local governments, and large public- and private-sector institutions have also adopted Buy Clean initiatives and policies to reduce embodied carbon emissions from the construction materials in their supply chains. Buy Clean policies and programs related to construction materials generally require disclosures of the environmental—and especially the embodied carbon—impacts of these products. These impacts are typically disclosed through Environmental Product Declarations (EPDs). Insulation materials have low embodied carbon. Many NIA members offer EPDs for their insulation materials.


The label program will offer a tiered rating system for construction materials and products. Thresholds will be informed by a public input process before being finalized; and they will be periodically reviewed and updated to encourage continuous improvement and help users meet sustainability objectives. The top-threshold tier will be designed to help recognize and reward innovative efforts to achieve deep reductions in embodied carbon associated with these construction materials and products.
To earn the label, manufacturers will submit an EPD for their materials to demonstrate that they meet the eligibility criteria. The label program will determine which recognition level a construction material is eligible for, based on information provided in the EPD. The EPA’s label program will use a conformity assessment and verification approach for EPDs aligned with the existing EPD verification system and consistent with standards and best practices within the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) 17000 series, as well as those required by EPA’s Framework for Assessing Environmental Performance for Specifications, Standards, and Ecolabels for Federal Purchasing.
The EPA published the Draft Label Program Approach in the Federal Register and accepted stakeholder input on this proposed approach through a 30-day public comment period. The draft program approach was also informed by public input received in response to a 2023 Request for Information (RFI) and input from other federal agencies, including the Federal Highway Administration in the Department of Transportation and the General Services Administration.

Potential Inclusion of Additional Materials

The EPA will consider the inclusion of other materials in the label program as time and resources allow, and if materials sectors take the actions necessary to move through the phases of the label program, including:
  • Developing and/or updating the relevant product category rule to meet EPA Product Category Rule Criteria, and
  • Generating a sufficient number of EPDs to ensure there is representative data upon which to create thresholds.
More information about how additional materials may be included in the program is provided on the EPA website (see “Implementation Approach for the U.S. EPA Label Program for Low Embodied Carbon Construction Materials” in the Resources section).

Tips for Companies Seeking to Participate in EPA’s Label Program

1. Develop EPDs for the materials and products your company manufactures. 
EPDs will be used to evaluate materials and products for inclusion in the label program.
In the near future, EPA and its grantees will provide no-cost technical assistance to help manufacturers develop EPDs. If you would like to receive additional information on how to receive this free assistance, please sign up to be added to the mailing list on the EPA’s website.

2. Reduce the embodied carbon in the materials and products your company manufactures. Through producing an EPD, manufacturers will be able to identify opportunities to reduce embodied carbon. Manufacturers who do not yet have an EPD developed can identify embodied carbon reduction options by reviewing the life-cycle assessment used in the product category rule for their material or product.

Some common ways to reduce the embodied carbon of construction materials and products, while maintaining performance standards, include the following.
  •  Manage energy and invest in energy-efficient upgrades: EPA’s ENERGY STAR Industrial Program offers manufacturers technical support to help them reduce the embodied carbon of their materials and products.Join ENERGY STAR’s Industrial Assistance Network to receive training, tools, and individual coaching. Email EnergyNetwork@energystar.gov to learn more.

    Reduce your energy intensity and participate in the ENERGY STAR Challenge for Industry to receive EPA recognition.

    Use the ENERGY STAR Energy Performance Indicators (for available sectors) to understand the energy efficiency of your plants. Plants that earn 75 (out of 100) or higher are eligible for ENERGY STAR plant certification.

    Use ENERGY STAR resources to find ways to reduce energy and carbon by conducting an Energy Treasure Hunt.

  • Power your facilities, when possible, with electricity from renewable sources. Consult EPA’s Green Power Partnership to learn how to reduce emissions associated with conventional electricity use while supporting the domestic development of clean energy resources.
  • Improve the efficiency of your freight transportation: Participate in EPA’s SmartWay program to better benchmark, report, and reduce Scope 1 and Scope 3 freight emissions.
  • Shift to lower impact input materials or material mixes, including shifting toward circular manufacturing processes such as incorporating what would have been waste materials into new products.
  • Invest in lower carbon fuels.
Visit EPA’s Technical Assistance, Tools, Resources, and Funding Opportunities webpage for more help on certification under EPA’s label program.
Resources
• Buy Clean Initiative: www.sustainability.gov/buyclean
• EPA’s Framework for Assessing Environmental Performance for Specifications, Standards, and Ecolabels for Federal Purchasing: www.epa.gov/system/files/documents/2022-02/updated-framework_020222.pdf
• ENERGY STAR Resources
• Learn about the ENERGY STAR Industrial Program: www.energystar.gov/industry
• Join ENERGY STAR’s Industrial Assistance Network (www.energystar.gov/industrial_plants/industrial_assistance_network) by emailing EnergyNetwork@energystar.gov
• Participate in the ENERGY STAR Challenge for Industry to receive EPA recognition:
• Use the ENERGY STAR Energy Performance Indicators to understand the energy efficiency
of your plants: www.energystar.gov/epis
• Earn ENERGY STAR plant certification: https://www.energystar.gov/industrial_plants/
earn-recognition/plant-certification
• Use ENERGY STAR resources to find ways to reduce energy and carbon by conducting an Energy Treasure Hunt: https://www.energystar.gov/industrial_plants/treasure_hunt
• Implementation Approach for the U.S. EPA Label Program for Low Embodied Carbon Construction Materials: www.epa.gov/system/files/documents/2024-08/lpa_final_8-6-24.pdf
• RFI and Webinar Announcement for Sustainable Marketplace/Environmentally Preferable Purchasing Program: https://www.regulations.gov/docket/EPA-HQ-OPPT-2022-0924/document
• Green Power Partnership: www.epa.gov/greenpower/green-power-partnership-resources
• To be added to the EPA’s Environmentally Preferable Purchasing (EPP) mailing list: https://www.epa.gov/greenerproducts/forms/contact-us-about-greener-products-and-services
• Learn more about technical assistance tools and resources for developing EPDs: https://www.epa.gov/greenerproducts/tools-resources-and-funding-opportunities
• EPA’s SmartWay Partnership: www.epa.gov/smartway/learn-about-smartway
• For more help on certification under EPA’s label program: www.epa.gov/greenerproducts/tools-resources-and-funding-opportunities