Boston Article 37: Zero Net Carbon, Explained
Article 37 just made Boston the toughest proving ground for new buildings. If your products feed structure or enclosure, design teams will ask for embodied carbon numbers, fast. Here is what Zero Net Carbon zoning changes, how EPDs slot into submittals, and the moves that keep your products on the spec instead of the sidelines.
What Article 37 actually requires
Starting July 1, 2025, most new Article 80 projects must open at net zero operational emissions and show their math during review. The triggers are 15 or more dwelling units, 20,000 square feet or more of new construction, or additions of at least 50,000 square feet. Projects prove compliance in the Article 80 process and must report embodied carbon. Buildings drive about 71 percent of Boston’s emissions, which is why the city is doing this now (Boston.gov, 2025) (Boston.gov, 2025).
Who gets extra time
Boston phases in net zero operations for complex facilities. New labs must meet net zero by 2035. New hospitals and general manufacturing must meet net zero by 2045. Projects that file before July 1, 2025 are exempt from the new ZNC provisions, but the window has closed for new filings (Boston.gov, 2025).
Embodied carbon reporting enters the chat
Large Projects over 50,000 square feet must submit a building LCA that covers structure and enclosure, with stages at minimum A1 to A3, B4, and C2 to C4, plus manual calculations for A4 and A5 if the tool does not cover them. Today this is a reporting requirement, not a reduction requirement, and it is filed before building permits are issued (BPDA, 2025) (Embodied Carbon LCA Reporting Instructions, 2025).
Where EPDs plug in
Project teams need trusted, product specific GWP values fast. Third party verified EPDs shorten the back and forth on submittals, reduce the need for conservative default assumptions, and help your materials compete on evidence rather than price alone. Without an EPD, many teams will apply cautious estimates and a penalty, which can push a product out of consideration when carbon budgets are tight. That is not the hill you want to die on.
What the city will ask for, and when
Article 37 aligns with Article 80. Expect three touchpoints. Initial Filing with your plan to meet the ZNC standard, Design Filing with final documentation before building permits, and a Construction Completion Filing before the certificate of occupancy. The Planning Department records Article 37 compliance with Inspectional Services for permits, so paperwork timing matters a lot here (BPDA, 2025) (BPDA Article 37, 2025).
A quick playbook for manufacturers
- Map your Boston exposure. Which SKUs are common in structures and enclosures on Article 80 projects, and which cross the 50,000 square foot Large Project line.
- Prioritize product specific EPDs for those SKUs. If a product is new to market, some operators allow a prospective EPD using limited months of data, then a refresh once a full year is available.
- Choose the PCR competitors already use, unless there is a stronger, current alternative. The PCR is the rulebook of Monopoly, ignore it and the game falls apart.
- Align the EPD scope with the building LCA scope. Make sure declared unit, system boundary, and data vintage are crystal clear to drop straight into the city’s Excel template.
- Pick a partner who takes on data wrangling inside your plants, not one who hands you a checklist and wishes you luck. Speed comes from hands on collection and clean modeling, not magic.
The market signal behind the policy
In 2024 the Article 37 team reviewed 65 project filings totaling 9.84 million square feet, and 91 percent targeted LEED Gold. Momentum is baked in before enforcement even starts (BPDA, 2024) (BPDA Article 37, 2025). City modeling says if the ZNC rules had applied to large buildings that began operation in 2023, total citywide emissions would have fallen by 0.58 percent, roughly equal to all waste related emissions that year (Boston.gov, 2025).
What this means for your sales pipeline
Boston owners and GCs now expect clean carbon documentation at schematic design, not during submittals. Teams that can drop verified EPDs and clear LCA inputs into the city’s templates will move faster and look lower risk. Reliable cost averages are hard to pin down because each scope differs, but an EPD often pays for itself with a single mid sized win. Do not let admin friction be the reason your product misses the cut.
Make the next 30 days count
Pull last year’s utilities, material inputs, and transport data for high volume SKUs, then lock the PCR and operator for each. Build an EPD schedule that matches your bid calendar and Boston’s Article 80 phases. We prefer guidence that turns paperwork into momentum, because the spec is won long before concrete trucks arrive.
Frequently Asked Questions
Does Article 37 require embodied carbon reductions or only reporting for Large Projects?
Only reporting at this time. The city requires a building LCA for structure and enclosure, with specified life cycle stages, submitted before building permits. No reduction target is set in Article 37’s current guidance (Embodied Carbon LCA Reporting Instructions, 2025).
What projects trigger Boston’s Zero Net Carbon operational standard?
New filings after July 1, 2025 with 15 or more residential units, 20,000 square feet or more of new construction, or additions of at least 50,000 square feet. Most uses must open at net zero. Labs have a 2035 deadline, hospitals and general manufacturing 2045 (Boston.gov, 2025).
What documentation cadence should manufacturers expect from design teams?
Expect requests during Article 80 Initial Filing, Design Filing, and Construction Completion Filing. EPDs and LCA-ready data that align with Boston’s Excel template keep submittals on track and reduce rework (BPDA Article 37, 2025).
About the Author
John brings a clear, research-driven perspective on the EPD, LCA and HPD space and keeps a close pulse on environmental trends and standards in North America, helping clients understand where the industry is heading and how to get there.
