New York’s Requirements for Concrete EPDs

Concrete producers serving the state of New York will soon be required to provide environmental product declarations (EPDs) for concrete mixes sent to agency projects valued over $1 million and using 50 or more yards of concrete or Department of Transportation (DOT) projects valued over $3 million and using 200 or more yards of concrete. 

As per the recently established Buy Clean Concrete guidelines — effective from January 2025 — concrete producers will also be obligated to confirm that their mix materials stay under specified environmental impact limits.

What is an EPD?An Environmental Product Declaration, or EPD, is a report that quantifies the environmental impact — or carbon footprint — of a building product like concrete. EPDs have been described as the equivalent of a nutritional label on a food product but for environmental reporting on materials. 
EPDs were first created as a management tool used in LEED to ensure meaningful and transparent data on emissions was being used. EPDs are now widespread in construction — not just on LEED projects — as specifiers react to consumer demand and government requirements for sustainable building.
EPDs for concrete are created when an EPD service provider conducts a life cycle assessment of a concrete plant and materials to communicate verifiable and accurate environmental information. Architects, engineers, contractors and property owners can then use EPDs to make informed decisions about the materials they select. 
More: What Specifiers Should Know About EPDs

About Buy Clean Concrete

The Buy Clean Concrete guidelines were highly anticipated after a  2021 law required the New York Office of General Services in partnership with the New York State Energy Research and Development Authority to accelerate the use and innovation of low-carbon concrete in state projects in consultation with a group of industry stakeholders — including New York’s DOT, Department of Environmental Conservation, the Metropolitan Transportation Authority and the Port Authority of New York and New Jersey, plus licensed professional engineers, registered architects and construction interests. 

The effort resulted in the publication of the guidelines, which set out achievable initial carbon limits with phased reductions over time and will have some significant impacts on the wider concrete production industry in New York.

What the New Requirements Will Mean for New York Construction

Beginning in 2025, New York State agency projects valued over $1 million and using 50 or more yards of concrete, or DOT projects valued over $3 million and using 200 or more yards of concrete will require EPDs for any concrete used during construction and adhere to GWP limits equivalent to 150% of average emissions for concrete mixes in the northeast US. These limits will be revised in 2027. To put this into perspective, state projects like the Kew Garden Interchange in Queens, which concluded in 2022, will be the scale of undertakings that the Buy Clean Concrete guidelines target. 

The guidelines grant exclusions for urgent assignments and those requiring high-strength or fast-setting concrete mixes, and do not apply to state authorities. There is also a waiver process for projects where it is not feasible to source concrete that meets the guideline requirements.

Kew Garden Interchange, New York State Department of Transportation

What This Means for Concrete Producers 

Buy Clean Concrete guidelines demand innovation, adaptation and a commitment to sustainable practices from every concrete producer serving the New York market. Producers will not only need to be transparent about their mix materials' environmental impact — they will also be challenged to ensure that their materials don’t exceed an environmental impact above set Global Warming Potential (GWP) thresholds. 

To continue serving government projects in the state of New York, producers will have to create EPDs to prove the GWP impact of their mixes and adopt new mix designs and technologies to lower the carbon footprint of their concrete.

Creation of Product Specific EPDs 

From January 2025, concrete producers will have to certify that their mixes achieve an environmental impact below New York State's set limits. 

Doing this will require the creation of product-specific — or Type III — EPDs. They involve a complex life cycle assessment (LCA) of each unique concrete mix and look at many factors — including plant-related factors — that impact a product’s carbon footprint. They must also be verified by a third party like Athena, Climate Earth or the NRMCA.

Production of Low Carbon Concrete

Concrete producers serving New York will also need to adopt new technologies and mix designs to remain competitive when bidding on projects covered by Buy Clean Concrete. After all, GWP is now effectively a bid criteria.

Concrete is made up of so many ingredients, so there are lots of ways to reduce the carbon impact of the individual components and processes. Most of the carbon reduction and carbon removal innovation effort is focused on three key areas: low-carbon fuels, low-carbon blended cement and carbon capture, utilization and storage technologies like CarbonCure.

Read our Complete Guide to Low Carbon Concrete 

What Specifiers Can Do to Support Buy Clean Concrete

Specifiers play a pivotal role in bridging the gap between policy and practice. With the new mandates in place, it's crucial for specifiers to:

1. Require Type III EPDs as Standard

Requiring Type III EPDs on all concrete mixes and products will help specifiers to more accurately measure the embodied carbon content of construction materials on all projects — not just those covered by Buy Clean Concrete guidelines.

2. Permit/Prefer the Use of CO2 Mineralization

To lower the GWP of concrete, architects and engineers can specify the use of COmineralization technologies like CarbonCure Ready Mix or CarbonCure Precast. Consider incorporating the following language into your master concrete specifications: 

CO2 mineralized concrete is permitted (or preferred) where available, pending concrete performance criteria is met. 

What is CO2 Mineralization Technology?Embed this video: 

3. Create embodied carbon goals

Specifiers can adopt the Buy Clean Concrete philosophy and place a GWP cap in their specifications by mandating that no bids above a certain GWP will be accepted. To determine a reasonable GWP cap for a specific project, use industry average EPDs and deduct 10% or 20% off the GWP to encourage the use of low carbon materials, technologies and manufacturing processes. 

NOTE: GWP caps on concrete should be based on accurate information pertaining to the specific application and location. For example, it would be unfair to cap GWP based on a 3000 psi mix if the application will actually use a 6000 psi mix. Also, GWP data would vary widely from one region to another. Check the EC3 tool for comparables in your area.

Buy Clean Concrete Will Expand Past New York

New York may be the first to launch specific Buy Clean guidelines for concrete, but many other states are hot on its heels due to the rise of broader Buy Clean requirements set by the federal government and adapted by many state governments. 

Producers across the country should be considering Type III EPDs and low carbon innovations to give themselves a competitive edge.

To learn more about CarbonCure’s technologies for low carbon concrete, get in touch

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