Los Angeles Moves to Cap Embodied Carbon in Construction
On April 9 2024 the LA City Council instructed building-safety officials to write embodied-carbon limits into the Los Angeles Green Building Code. The move rides the wave of California’s statewide CALGreen update that already makes lower-carbon concrete mandatory on large projects. For manufacturers this means specifications will soon ask not just for compressive strength or fire ratings but for a product-specific EPD that proves your tons of CO₂ per cubic yard sit below a new ceiling.
Why LA Is Zeroing In on Embodied Carbon
Worldwide the materials used to make buildings—steel, cement, glass, insulation—account for roughly 13 percent of annual CO₂ emissions (IPCC, 2023). Los Angeles signed C40’s Clean Construction Declaration in 2022 and now wants hard numbers in its own code to back that pledge. The City Council motion directs the Department of Building and Safety to propose embodied-carbon caps for all new construction and major additions over 50 000 ft² (City of Los Angeles, 2024).
CALGreen Sets the Floor, LA Wants a Ceiling
California’s CALGreen code began requiring embodied-carbon compliance on July 1 2024 for commercial projects larger than 100 000 ft² and K-12 schools over 50 000 ft² (CALGreen, 2024). Los Angeles will likely mirror CALGreen’s three compliance paths but sharpen the thresholds and lower size triggers to capture more mid-rise housing.
Three Ways to Show You Meet the New Limits
- Whole-building LCA: Document a 10 percent global-warming-potential reduction versus a reference design.
- Product-specific GWP targets: Each concrete mix, steel assembly, or insulation board falls below a published GWP number tied to regional averages.
- Weighted-average approach: Show the combined materials package beats the limit when tallied across the project.
Project teams may also reuse at least 45 percent of the primary structure to skip deeper calculations, a nod to circular-economy thinking (3C-REN, 2024).
Concrete, Steel, and Glass Manufacturers: Your New Scorecard
Specifiers will scrutinize EPDs issued no earlier than 2019 and look for declared product averages, not generic industry PDFs. A ready-mix plant that swaps in 40 percent SCMs or a rebar mill that runs on renewable power can win bids if the numbers are transparent. Miss the paperwork and you are relegated to “default GWP” values that sit 25-30 percent higher than current market leaders—pricing you out before you even quote.
EPDs Become Table Stakes
Policy makers picked EPDs because they are audit-ready and already embedded in LEED v4 and Buy Clean California. An architect can plug a digital EPD into EC3 in seconds; a missing declaration takes hours of substitutions. That time penalty alone nudges even cost-sensitive GCs toward better-documented products.
Choosing a Partner Without Losing a Year
Most of the timeline pain hides in data wrangling: utility bills, plant yields, fleet fuel, upstream ingredients. Look for an LCA team that collects that data for you, keeps everyone on one platform, and knows which PCR your competitors use so you don’t recieve outlier results that hinder bids. Speed here is revenue, not convenience.
The Clock Is Ticking
LA’s code writers must report back before October 2025. Once the ordinance lands, owners will only approve materials with clear, current EPDs. Get yours in the queue now while labs and verifiers still have capacity.
Frequently Asked Questions
When will Los Angeles finalize embodied-carbon caps in its Green Building Code?
City Council instructed the Department of Building and Safety to return recommendations within 180 days of April 9 2024; a draft ordinance is expected to surface in late 2025.
Do small projects under 50 000 ft² need product-specific EPDs?
The current council motion targets larger projects. Smaller jobs may avoid direct caps but will still benefit from lower-carbon specs favored by architects chasing CALGreen or LEED points.
Will generic industry-wide EPDs satisfy the new LA requirements?
Probably not. Draft language points to product-specific or plant-specific EPDs to prove actual, not average, performance.
How low do concrete GWP numbers need to go?
CALGreen sets its prescriptive limit at 175 percent of regional averages. LA is likely to tighten that later, but exact figures are not yet published.
What happens if a supplier cannot meet the cap?
Owners can still purchase higher-GWP products but must balance them with deeper reductions elsewhere or risk plan-check rejection.
Will my generic industry EPD satisfy the upcoming Los Angeles limits?
Probably not. The draft framework points toward product- and facility-specific EPDs or whole-building LCAs, mirroring CALGreen language that treats generic data as a last resort.
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.
