Does SB 2484 force every supplier to file an EPD?

Not explicitly, but procurement staff cannot verify global-warming-potential claims without one, so EPDs become de-facto required for bid competitiveness.

When could Illinois start enforcing material GWP limits?

If the bill moves in the 2026 spring session, IDOT could publish draft limits by late 2026 and enforce them in 2027 contracts.

Which PCR should I use for asphalt supplied to Illinois DOT?

The current EN 15804-aligned asphalt mixtures PCR published by NAPA (2023) remains the safest choice until Illinois issues different guidance.

Can a facility-wide EPD cover multiple concrete mix designs?

Only if each mix falls within the declared range in strength and composition defined by the PCR; otherwise separate EPDs are needed.

What happens if my product exceeds the eventual GWP cap?

You can redesign the formulation, switch inputs, or supply EPD-backed evidence of performance benefits that justify a variance, but expect tougher scrutiny.

Illinois SB 2484: A Buy Clean Blueprint

What the bill actually says

Filed on February 7 2025, SB 2484 directs the Illinois Department of Transportation, in tandem with Central Management Services and the Capital Development Board, to draft “one or more standards” for State purchases of appliances, concrete, asphalt, steel, and other building materials (IL SB 2484, 2025). Those standards must consider:

A maximum acceptable global-warming potential (GWP) per material.
Practical ways to promote life-cycle assessments (LCAs) and environmental product declarations (EPDs) when evaluating bids. The bill is still parked in the Senate Assignments Committee as of April 11 2025, yet the language mirrors earlier House drafts and other Buy Clean bills, a sign that policymakers are closing ranks.

Why manufacturers should not wait for passage

Drafting standards takes time, but agency staff often lean on existing market data to set first-generation GWP limits. If your mix or melt already sits above better-performing peers, a last-minute retrofit will cost more than an early-stage carbon tune-up. California saw average ready-mix GWP drop 10 % in two years after its own limits went live (CARB, 2024).

GWP caps are tightening everywhere

EPA’s June 2025 interim determination pegs “substantially lower” materials as the top 20 % performers in national EPD databases (EPA, 2025). Colorado, New York, and Minnesota draft rules within a similar envelope. Illinois staff are unlikely to reinvent that wheel, so treating the 80th-percentile line as a working ceiling is a prudent yardstick.

EPDs become your bid passport

SB 2484 does not shout “mandatory EPD,” but procurement officers cannot verify GWP without one. Expect bid packages to request:

Plant-specific, third-party-verified EPD less than five years old.
Proof that the declared unit matches the supplied product.
A digital copy ready for EC3 or a State portal. A generic industry-average label will likely earn partial credit at best.

Data pain points, solved early

Collecting twelve months of energy, raw-material, and transport data across multiple plants can devour hundreds of staff hours. The trick is to automate pulls from ERP and utility portals, then stage the numbers in a LCA-ready template before your consultant knocks. Producers that did this for the California GWP rule cut internal prep time by roughly 60 % (CalCIMA member survey, 2024). Dont leave that step to the intern.

Align existing PCRs with IDOT expectations

Most Illinois projects rely on EN 15804-compliant PCRs for concrete and steel. Check expiry dates now. If your PCR sunsets in 2026, budget a rapid EPD renewal so you are not forced to switch rulebooks mid-bid. Early comments in committee hint that IDOT may reference national PCRs to keep multi-state suppliers eligible (committee witness slips, March 2025).

Get ready before spec-writers call

Map your product lines against likely material categories in the bill.
Benchmark each plant’s GWP versus top-quartile EPDs in EC3.
Prioritize plants that feed State-funded corridors—I-55, I-90, and rebuildil bridges top the capital plan.
Lock in an LCA partner with a white-glove data-collection model to avoid last-minute fire drills. Speed matters when bids open in 30 days not six months.

Watch the committee clock

Illinois lawmakers break for summer on May 31 2026. If SB 2484 clears assignments this winter, draft standards could hit public comment by Q3 2026 and show up in contracts by the 2027 construction season. That is one product-development cycle, not long at all. Missing that train means watching competitors with carbon-smart EPDs snag the next round of State work—ouch, that hurts thier pipeline.