Impact of Federal Buy Clean Requirements on the Concrete Industry 

The new Buy Clean Executive Order means that from January 1, 2023, the United States federal purchasing agencies are required to obtain EPDs for concrete building materials used on federal projects. 

In a recent webinar, policy expert and Senior Director of Global Customer Success Eric Dunford discussed the implications of Buy Clean on the concrete industry and the new requirements for EPDs for producers.


  • What is Buy Clean?
  • Impact of Buy Clean on Concrete Production
  • How Buy Clean Will Be Implemented
  • How Carbon in Concrete is Measured
  • How Concrete EPDs are Created
  • Summary of How Buy Clean Will Affect Concrete Producers

What is Buy Clean?

‘Buy Clean’ is a term that describes any legislation that proposes incorporating climate considerations (i.e., the carbon impact of any products purchased by the government) as part of public procurement decision-making.

Like many environmental initiatives, Buy Clean originated in California in 2017 as Bill 262 and was replicated in Colorado, Washington, and Minnesota. The federal government introduced Buy Clean in an Executive Order on December 8, 2021. The title of the Executive Order is Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability. Section 303 of the order established the first Federal Buy Clean Task Force to take specific action on concrete and steel.

It should be noted that Buy Clean is not unique to the US; similar Buy Clean legislation is underway in other countries around the world. The Government of Canada, for example, has committed to a target CO2 reduction of 30% for structural materials by 2025 and is investigating alignment with the US Federal Buy Clean requirements.

Impact of Buy Clean on Concrete Production

The federal government is one of the world's largest procurement bodies. They purchase trillions of dollars worth of materials and equipment every year. 

From a concrete perspective, government spending on infrastructure is one of the top two end destinations for all concrete manufactured in the United States. As such, government procurement is very powerful and influential. Any policies that affect concrete procurement in the federal government are likely to be replicated at state and local government levels and in the private sector.

Since the federal government announced Buy Clean, some of the federal government's public agencies have started publishing maximum carbon limits. For example, the General Services Administration (GSA) issued guidelines on maximum global warming potential limits. Any products that exceed those limits will not be permitted for use on federal projects.

Interestingly, the GSA’s guidance for concrete mixes in the 5500-6499 psi range has a maximum limit of 404 kg of CO2 per cubic meter, whereas the NRMCA’s maximum industry average for mixes in the same range is much higher at 493.67 kg of CO2 per cubic meter. Under the GSA’s new guidelines, many common concrete mixes are already disqualified from federal projects.

How Buy Clean Will Be Implemented

For any Buy Clean legislation to work, the government needs a way to compare materials using an independent and transparent quantification of their life cycle impact. It also needs a way to compare mixes to the maximum carbon limits and industry averages that are published and managed by the National Ready Mix Concrete Association (NRMCA), the Cement Association of Canada, and other industry bodies.

Environmental Product Declarations, or EPDs, have been developed to help procurement officers in government and beyond effectively measure the carbon impact of materials.

EPDs are similar to nutrition labels on a food product but focus on materials' environmental and sustainable attributes. They were adopted by other industry sectors many years ago. For example, designers use them to compare finishes or interior materials on attributes other than price. Increasingly EPDs are being adopted by architects, engineers, and contractors to compare structural materials like concrete.

An anonymized example of a real EPD that can be accessed through the National Ready Mix Concrete Association (NRMCA)

While there are many different types of EPDs, the one that applies to concrete is the EPD Type III. Type III EPDs mandate that the information is vetted and verified by a third party—a requirement of Buy Clean.

What is an EPD?

An EPD is a report that quantifies the environmental impact of a building product.

A concrete EPD service provider conducts a life cycle assessment of the concrete plant and materials to communicate verifiable and accurate environmental information. Architects, engineers, contractors, and property owners use EPDs to make informed decisions about the materials they select.

Simply put, an EPD is an easy way to prove the carbon footprint of your concrete mixes and products.

How to Measure Carbon in Concrete

Concrete EPDs measure the life cycle impact from cradle to gate, rather than cradle to grave. They measure all carbon inputs from the time of raw material extraction (e.g., processing and shipping the materials to the concrete plant) to the time the concrete mix leaves the gates of the concrete plant (e.g., energy and other equipment used to manufacture concrete). 

It doesn’t cover the transportation to the construction site, application of the concrete, or end of life. While what happens to the concrete after it leaves the plant still has a carbon impact, that impact would be impossible to measure accurately for use by procurement professionals.

Adapted from K. Simonen, Life Cycle Assessment

How to Create Concrete EPDs

The creation of EPDs involves a life cycle assessment (LCA) of each unique concrete mix and looks at many factors—including plant-related factors—that impact a product’s carbon footprint. Concrete EPDs must comply with the internationally accepted principles, framework, methodology, and practices for LCAs established by ISO 14040 and ISO 14044 as well as data collection, methods, and assumptions outlined in the ISO standard 14025. 

Step 1: Find the PCR for Concrete

The first step in creating an EPD is to find the product category rule (PCR) that’s applicable to concrete. PCRs provide the calculation and reporting requirements for creating LCAs and EPDs. 

Step 2: Conduct and Verify Your Concrete’s LCA

Conduct a life cycle assessment that compiles and examines the inputs and outputs of materials and energy—and the associated environmental impacts—directly attributable to concrete up to the point that it leaves the concrete plant. This includes the inputs and outputs of raw materials suppliers also.

Step 3: Compile the EPD

The EPD report presents the results of the LCA along with additional information about the concrete’s performance and other sustainability attributes as outlined in the PCR instructions. The content in the EPD report never includes ratings, judgments, or direct comparisons with other products.

Step 4: EPD Verification

The EPD verification process is conducted by an approved independent, third-party verifier or an accredited certification body with knowledge and experience of the types of concrete, the industry, and relevant standards covered by the EPD and its geographical scope. Athena, Climate Earth, and the NRMCA are some of the approved third-party EPD verifiers operating in the industry.

Step 5: Register and Publish the EPD

Once the EPD is verified, it can be registered and published to a recognized repository like ASTM International. The EPDs generally get picked up by other tools like the EC3 Tool by the Carbon Leadership Forum, which stores all product-specific EPDs for low carbon concrete for consideration by specifiers. EPDs are typically valid for five years. 

Learn how to create an EPD for concrete products.

How Buy Clean Will Affect Concrete Producers

When Buy Clean is implemented in 2023, the carbon footprint of concrete will be normalized as another bid selection criteria for federal projects. But it’s not just federal projects that will be affected. State and local governments and public sector organizations will follow suit.

If producers can’t find ways to create Type III EPDs for all concrete mixes and make concerted efforts to reduce the carbon footprint of their mix designs, they will be blocked from bidding on projects.

To prepare your business for the changes that are coming, address the following three areas:

1. Understand Your Impact

  • How are you performing in comparison to industry averages?
  • Do you need to invest time or energy to change your mixes or source different materials? 
  • Who are the key vendors and providers of environmental product declarations that you need to engage? 

2. Be Ready to Communicate 

  • What are you doing to create lower carbon concrete?
  • Are your staff equipped to speak about embodied carbon, EPDs, etc.?
  • Do you have sales and marketing materials to showcase what you’re doing to reduce your carbon footprint?

3. Invest in Carbon Reduction

  • What are you doing to reduce the carbon content in your concrete?
  • Can you make different material selections or adopt new technology to reduce the carbon footprint of your mixes without compromising quality?
  • Can you change your energy supply from coal to LNG or clean energy?

Watch the on-demand webinar to learn more about Buy Clean, EPDs, and what it means for the concrete industry.

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