Buy Clean Massachusetts: Embodied-carbon rulebook
Beacon Hill is weighing HD.3507, a bill that would turn embodied-carbon data into a ticket of entry for public contracts. If you sell concrete, steel, rebar, or engineered wood in Massachusetts, the countdown to verifiable Environmental Product Declarations (EPDs) could start the moment the bill clears committee.
Why Beacon Hill cares about your mix design
Buildings account for roughly 23 % of statewide greenhouse-gas output when you include the emissions baked into materials (State GHG Inventory, 2024). HD.3507 aims to chip away at that bucket by making global-warming potential (GWP) a line item in every state-funded project larger than 50 000 ft².
Four product families under the spotlight
The draft text lists structural concrete, reinforcing steel, structural steel, and a long roster of engineered-wood systems. Anything outside those lanes can be added later by the Division of Capital Asset Management and Maintenance (DCAMM), so sleepers like insulation or aluminum should not sleep on this bill.
Deadlines in plain English
- July 1 2027 – All covered projects over 100 000 ft² must submit facility-specific EPDs before substantial completion.
- July 1 2029 – Requirement drops to every covered project, no size carve-out.
- July 1 2029 – DCAMM launches a public database for reported GWPs (Massachusetts Legislature, 2025).
Facility-specific, not generic
The bill uses the phrase “supply-chain specific,” calling for data that traces at least 70 % of cradle-to-gate GWP back to real plants. Generic industry averages will not pass muster. Manufacturers relying on dated or industry-wide EPDs will need a refresh.
Small-business cushion, sort of
DCAMM can offer grants to offset EPD costs for small manufacturers. The pot depends on future appropriations, so planning on free money would be a gamble.
Miss the train, miss the bid
MassDOT’s five-year capital plan totals $18.5 billion between FY 2026-30 (MassDOT, 2025). Any slice of that pie will soon require carbon numbers alongside unit prices. No EPD, no purchase order.
Start dates vs. lead times
Even a ruthlessly efficient EPD workflow can run six to nine months from first data pull to publication. Add internal approvals, a quality review, and the holiday slow-down and 2027 feels alarmingly close. Teh prudent teams are mapping data gaps now.
Choosing the right LCA partner
Look for:
- A data-collection process that does not hog plant engineers for weeks.
- Experience publishing facility-specific EPDs under ISO 21930.
- Clear plan for PCR alignment so your declaration stays valid when rules update.
Beyond public work: private spillover
Once state agencies demand low-carbon specs, private developers tend to copy-paste them into RFP templates. Expect ripple demand from higher-ed campuses and corporate labs hungry for ESG headlines.
The takeaway
HD.3507 is still in committee, yet the smart money treats it as a done deal. Lock in your EPD roadmap now, beat the rush, and turn compliance into a competitive edge.
Frequently Asked Questions
Does HD.3507 require third-party-verified EPDs or will self-declared data work?
The bill explicitly references ISO 14025 Type III EPDs, which must be independently verified, so self-declarations will not qualify.
Will legacy industry-average EPDs satisfy the Massachusetts thresholds?
No. The draft text calls for "supply-chain specific" data that ties at least 70 % of cradle-to-gate impact to one producer. Generic averages will likely be rejected.
How soon should manufacturers start if they need an EPD by July 2027?
Assuming six to nine months for a smooth EPD project, kickoff in Q1 2026 leaves minimal buffer for PCR hiccups or approval cycles.
Are contractors responsible for verifying the accuracy of EPDs they collect?
Contractors only need to collect and forward the EPDs; the bill says they are not required to verify supplier data.
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
