Executive Order 594: EPDs Move From Nice to Need
Massachusetts’ Executive Order 594 quietly rewired state construction. It sets hard emissions targets for government operations and tells project teams to cut embodied carbon in materials. Translation for manufacturers selling into state projects: Environmental Product Declarations move from marketing PDF to spec-critical proof. The opportunity is large, the timelines are real, and the fastest path is having plant‑specific data ready before bids land.
What EO 594 actually does
Executive Order 594 applies to all Massachusetts executive agencies and public higher‑ed. It targets cuts in emissions from onsite fossil fuel use against a 2004 baseline by 20% in 2025, 35% in 2030, and 60% in 2040, and directs teams to evaluate strategies to reduce embodied carbon in building materials (Mass.gov Executive Order No. 594, 2021). In short, the state wants cleaner operations and lower‑carbon materials documented with credible data.
Why EPDs show up in state specs
Design guidance from DCAMM now tells project teams to require Environmental Product Declarations for materials and to set allowable GWP limits in specifications (DCAMM Designer Procedures and Guidelines, 2025). That is the bridge from policy to purchase order. If an EPD is missing at submittal, the material may need replacement or extra justification. No one wants schedule risk over paperwork.
The procurement signal is not small
Massachusetts’ Environmentally Preferable Products program reported $409 million in climate and environmental preferable purchases in FY24, representing 17% of all statewide‑contract sales (OSD EPP Annual Report FY24, 2025). That buying muscle shapes what vendors prioritize. When specs start asking for EPDs and GWP thresholds, those who can supply numbers win time and trust.
The capital pie at stake
MassDOT’s FY2026–2030 Capital Investment Plan funds approximately $18.5 billion in transportation projects. Any supplier who can pair competitive pricing with verified low‑carbon data has an edge when carbon becomes a scored criterion (MassDOT Press Release, 2025). EPDs do not guarantee selection, but they do remove a common barrier that keeps products out of consideration.
What could tighten next
The Embodied Carbon Intergovernmental Coordinating Council is preparing a statewide plan by January 1, 2026, including options to require EPDs for certain materials and to set GWP guidance for state procurement (OCIR ECICC, 2025). The Legislature is also reviewing a Buy Clean bill that defines supply‑chain specific EPDs, raising the bar above generic industry averages (Massachusetts Legislature H.3325, 2025). Exact thresholds are still in motion. Where numbers are missing, agencies have said they will study and consult rather than guess.
Practical playbook for manufacturers
- Map Massachusetts exposure. List SKUs used in state projects or in public higher‑ed work. Rank by revenue and likelihood of spec scrutiny.
- Confirm the right PCRs. Match competitors’ references so your EPDs land apples‑to‑apples in bid reviews. If two PCRs fit, favor the one most common in local specs.
- Collect plant data once, cleanly. Utilities, fuels, production volumes, scrap, inbound transport, and packaging for a defined reference year. Future renewals get exponentially easier if the first pass is tidy.
- Pick a program operator aligned to your market. Smart EPD and IBU are common touchpoints, but what matters is third‑party verification, speed, and predictable publishing.
- Pre‑build submittal packs. Include the third‑party verified EPD, mill certs where relevant, mix designs, and a one‑page GWP summary that points reviewers to the right modules.
Partner checklist for low‑stress EPD delivery
Look for a team that removes data‑collection drag, coordinates across plants, and manages verification calmly. Speed matters when bids move fast, but quality and completeness are what keep RFIs from boomeranging back. Being operator‑agnostic helps when owners prefer a specific registry. Bonus if they can translate results into clean spec language without drama. It definately saves your engineering time.
Bottom line for Massachusetts
EO 594 made embodied carbon part of the state’s construction vocabulary, then DCAMM put it into design guidance. The money in motion is significant and public. EPD coverage is now a ticket to play, not a nice‑to‑have. Get credible data, get it verified, and be ready to hand a reviewer exactly what they need the moment they ask.
Frequently Asked Questions
Does Massachusetts require EPDs for all state projects today?
DCAMM guidance instructs teams to require EPDs for materials and to set GWP limits in specs, which means many state projects will ask for them now (DCAMM Designer Procedures and Guidelines, 2025). A statewide Buy Clean mandate is under discussion and planning, with details due by January 1, 2026 (OCIR ECICC, 2025).
Which numbers in EO 594 should manufacturers care about?
The order sets emissions‑reduction targets for onsite fossil fuel use against a 2004 baseline by 20% in 2025, 35% in 2030, and 60% in 2040, and directs teams to evaluate strategies to reduce embodied carbon (Mass.gov Executive Order No. 594, 2021).
How big is the opportunity in transportation projects?
MassDOT’s FY2026–2030 Capital Investment Plan totals about $18.5 billion (MassDOT Press Release, 2025). EPD‑ready materials are increasingly positioned to meet spec requirements as carbon becomes a scored criterion.
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
