CALGreen 2022 Update: EPDs That Win California Specs
California’s July 2024 CALGreen supplement quietly flipped the script on embodied carbon. Large nonresidential projects and schools now need proof, not promises. If your products show up without credible, product‑specific EPDs, you risk being sidelined while competitors get written in. Here is what changed and why it matters to your product.
What changed on July 1, 2024
Mandatory embodied‑carbon rules took effect through the 2022 Title 24, Part 11 supplement. The update was published January 1, 2024 and became enforceable July 1, 2024 (CBSC, 2024) (CBSC, 2024). That moved CALGreen from mostly voluntary to measurable requirements on big projects.
Who is in scope, and when it widens
Today the mandate applies to nonresidential buildings that are 100,000 square feet or more, and to schools that are 50,000 square feet or more. On January 1, 2026, the threshold for nonresidential projects under BSC authority drops to 50,000 square feet (CBSC CALCode Quarterly, 2025) (CBSC CALCode Quarterly, 2025). If your products feed these projects, specifiers will ask for compliant documentation.
Where EPDs fit in CALGreen
CALGreen offers three compliance paths for embodied carbon. Two are performance based and one is prescriptive. The prescriptive path centers on documented global warming potential for a short list of materials using product or plant‑specific Type III EPDs. Covered categories include structural and reinforcing steel, flat glass, mineral wool board insulation, and concrete. Code sections 5.105, 5.409.2, and 5.409.3 spell out the details (AIA California, 2024) (AIA California, 2024).
The three paths, plain English
- Building reuse. Keep at least 45 percent of existing structure and enclosure when you renovate. That saves carbon immediately because the greenest beam is the one you do not replace (AIA California, 2024).
- Whole‑building LCA. Show at least a 10 percent reduction from a compliant baseline design using accepted LCA rules. Think of it as a scorecard for cradle‑to‑grave impacts (AIA California, 2024).
- Prescriptive EPD route. Provide qualifying EPDs that demonstrate product GWP within CALGreen limits for each listed material. It is a checklist that inspectors can verify quickly (AIA California, 2024).
Why manufacturers need product‑specific EPDs now
Project teams want fewer headaches during plan check. A current, third‑party verified EPD lets them document compliance in minutes rather than redesign around your product later. Without one, your product can trigger conservative default assumptions that make you less competitive on carbon, which quietly pushes you out of the spec conversation.
Fastest practical moves this quarter
- Lock your reference year and collect primary data from production, utilities, transport and waste. Aim for plant‑level specificity so the EPD reflects your actual process, not a generic average.
- Align early on the correct PCR and program operator so verification and publication run smoothly. Ask for a clear timetable and the exact documents reviewers will expect at permit.
- Prepare a submittal pack. Include EPD PDFs, mix IDs or SKUs, and a one‑page summary that maps each EPD to CALGreen’s categories. That removes friction for plans examiners.
Concrete nuance most teams miss
Concrete may be treated as a weighted average across mixes for compliance. That means an optimized high‑volume mix can offset a specialty mix with higher GWP when documented correctly. The arithmetic matters as much as the recipe, and the worksheet format from CALGreenInfo helps teams show their math cleanly (CBSC, 2024).
Common pitfalls that slow approvals
Picking an uncommon PCR can force extra explanation if competitors use a different rulebook. Substituting an industry‑average EPD where the code expects product or plant‑specific data will be flagged. Letting an underlying PCR expire does not automatically invalidate your EPD, yet it can complicate renewals, so plan the update cadence.
Sales upside, not just compliance
When embodied‑carbon caps appear in a bid set, an EPD turns into a gate pass. Teams can specify faster, avoid risk adders, and keep your product in play even when value engineering heats up. One medium project can repay the paperwork many times over because it keeps you in the rooms where choices get made.
Choosing an LCA and EPD partner
Look for three things. First, a white‑glove data collection approach that saves your engineers’ time. Second, clear PCR guidance that aligns with what peers use. Third, predictable project management so verification and publication hit the schedule you promised your sales team. Speed, ease, quality and completeness matter here more than a bargain quote.
Tools that make compliance easier
California’s public team released worksheets that mirror permit checklists for building reuse, whole‑building LCA, and the product GWP path. These are designed to be filled, signed, and uploaded with plans. They are available at CALGreenInfo, which aggregates videos, factsheets, and forms for the July 2024 supplement. It is definately worth bookmarking.
Make CALGreen your spec advantage
Treat the EPD as a performance credential. Nail the data once, keep it current, and position your product as the easy choice on projects that grow each year as the 2026 threshold approaches. That is how CALGreen stops being a hurdle and starts being a head start.
Frequently Asked Questions
Which CALGreen embodied‑carbon rules are in force today and what are the size thresholds?
As of July 1, 2024, the 2022 CALGreen supplement made embodied‑carbon limits mandatory for nonresidential projects 100,000 ft² and bigger, and for schools 50,000 ft² and bigger. On January 1, 2026, the BSC threshold drops to 50,000 ft² for nonresidential projects. These dates and thresholds are published by California’s Building Standards Commission (CBSC CALCode Quarterly, 2025) (CBSC CALCode Quarterly, 2025).
Which materials need EPDs under the prescriptive path?
Structural steel, reinforcing steel, flat glass, mineral wool board insulation, and concrete. CALGreen requires product or plant‑specific Type III EPDs for these categories to show product GWP within limits (AIA California, 2024) (AIA California, 2024).
Does CALGreen specify exact GWP numbers for every product?
Yes, the code provides GWP thresholds and calculation methods, including a weighted average approach for concrete. Jurisdictions accept the official CALGreen worksheets to demonstrate compliance at plan check (CBSC, 2024) (CBSC, 2024).
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.
