Buy Clean California Act: EPD Keys to Winning Bids
California is tightening the screws on embodied-carbon. From 1 January 2025, structural steel, rebar, flat glass, and insulation supplied to any state-funded project must carry a facility-specific, third-party verified EPD that beats brand-new global-warming-potential (GWP) limits. Miss the mark and your product is simply invisible at bid time.
Why Sacramento Cares About Your Mill’s Footprint
The Buy Clean California Act (BCCA) links state procurement dollars to the CO₂ profile of basic construction materials. Lawmakers peg the policy to a stark number: building products account for roughly 11 % of California’s territorial greenhouse-gas inventory (CARB, 2024). Shrinking that slice is cheaper than retrofitting finished buildings, so the state took a hard look at its own $180 billion, ten-year infrastructure pipeline (build.ca.gov, 2024).
The 2025 GWP Limits at a Glance
Starting bids advertised after 1 January 2025 must prove cradle-to-gate GWP below these ceilings (DGS, 2025):
- Hot-rolled structural steel: 1 010 kg CO₂e per tonne
- Rebar: 755 kg CO₂e per tonne
- Flat glass: 1 430 kg CO₂e per tonne
- Light-density mineral wool board: 2.68 kg CO₂e per m² at R-value 1
Revised limits for other insulation sub-categories will land later in 2025 under SB 1207. These numbers might looks small, yet many average EPDs hover 5–15 % above them.
Facility-Specific EPDs or Bust
Industry-wide averages no longer cut it. The BCCA FAQ spells it out: an EPD must cover a single plant or, at minimum, report each plant separately (DGS, 2025). Anything less leaves specifiers no way to confirm compliance. Third-party verification under ISO 14025 remains mandatory, and the document cannot be past its five-year shelf life when material arrives onsite.
Cost of Inaction: Locked-Out of a $10 B-Per-Year Market
California public works spent about $10 billion on capital outlay in 2023 and 2024 combined (LAO, 2025). Skip the EPD and your steel beam or insulation panel is barred from that spend even if you underbid on price. Competitors armed with compliant declarations rise a full tier on bid scorecards—easy math for purchasing officers juggling low-carbon mandates.
Timeline Check: Bid, Award, Install
- Bid Stage: bidder submits the EPD with cradle-to-gate GWP and facility ID.
- Award Stage: agency cross-checks limit tables; no EPD equals non-responsive bid.
- Install Stage: agency may spot-audit invoices against the EPD’s facility name to catch substitutions. Missing or expired EPDs can trigger contract penalties. Leave no surprises for the site superintendent.
Data Hurdles Most Teams Trip On
Bill-of-material clarity is the biggest sinkhole. Many mills track scrap rates in accounting systems but not in a form clean enough for life-cycle software. Upstream energy data is another pain point—utilities supply totals in BTU or therms, yet PCRs want mega-joules. The sooner environmental and finance teams swap numbers, the sooner a verifier can bless the LCA.
Action Checklist for 2025 Compliance
- Map every eligible SKU to a single production line.
- Pull 12 months of energy, raw material, and transport data.
- Select the latest PCR listed by DGS—old versions risk rejection.
- Lock a verifier early; BCCA reviews have been running eight weeks on average (BCCA Obstacles Report, 2023).
- Publish before the next bid window opens. Dont bet on extensions.
From Box-Ticking to Bid-Winning
A compliant EPD is more than paperwork. It turns climate policy into a moat around your spec. When buyers must meet rigid carbon caps, the lowest-number product writes itself into the job. Get the math right now, and California’s infrastructure binge becomes a growth lever rather than a bureaucratic headache.
Frequently Asked Questions
Do industrywide EPDs satisfy Buy Clean California Act rules?
No. The Act explicitly requires facility-specific, third-party verified EPDs that disclose impacts for one plant or list impacts plant-by-plant. Industry averages are rejected (DGS, 2025).
How often will California tighten the GWP limits?
DGS must review limits every three years. The first adjustment took effect 1 January 2025; expect the next by 2028 unless the Legislature accelerates the cycle (DGS GWP Adjustment Study, 2024).
Is concrete covered by the Buy Clean California Act?
Only concrete reinforcing steel today. A separate bill (SB 778) proposes adding ready-mix concrete, but it has not passed as of August 2025.
What if our EPD expires mid-project?
An expired EPD is non-compliant. Plan to renew at least six months before the original five-year validity ends so bids and inspections stay clean.
About the Author
Eric works at the intersection of sustainability, regulation, and business strategy, helping manufacturers navigate the evolving landscape of EPDs and LCAs. Having spoken with hundreds of teams across North America, brings a deep understanding of what drives ROI, what regulators are asking for, and how companies can stay ahead with smart, scalable approaches to environmental reporting.
