Does the bill require EPDs for every material on a project?

Not quite. EPDs are mandatory only if the project team uses the prescriptive pathway, yet that path will likely dominate because it demands less modeling effort than a full whole-building LCA.

What reduction target must my product hit?

Your product’s global-warming potential must be at least 30 percent below the relevant industry average reference stated in the bill or subsequent rules.

When will contracting officers start asking for EPDs?

One year after the bill becomes law. The Division of Capital Asset Management must publish implementing rules within that window, and every bid issued after must comply.

Are industry-wide EPDs acceptable?

Yes, but only as a baseline for comparison. To win points, you need product-specific EPDs that outperform the industry-wide figure by the required margin.

Will renovation projects be exempt?

No. Renovations larger than 20 000 ft² and representing over 50 percent of a building’s assessed value must follow the same embodied-carbon rules.

Massachusetts Targets Embodied Carbon in State Projects

Why Beacon Hill Is Eyeing Materials, Not Just Megawatts

The Bay State already regulates tail-pipe and smokestack emissions. Building materials now sit in the crosshairs because they contribute an estimated 11 percent of statewide greenhouse gases before a single light turns on (MA GGR Report, 2024). Legislators want faster wins, and construction procurement is low-hanging fruit.

Which Products Land on the Hot Seat

The bill calls out four families: structural concrete, reinforcing and structural steel, and engineered wood such as cross-laminated timber (MA Bill H.3337, 2025). If you sell ready-mix or glulam into public jobs over 50 000 ft²—or major renovations exceeding 20 000 ft²—you are officially in scope.

Three Compliance Pathways, One Common Thread

Performance pathway: show a 30 percent lower global-warming potential (GWP) via cradle-to-grave whole-building LCA.
Re-use pathway: preserve at least 45 percent of the existing structure.
Prescriptive pathway: supply Type III EPDs proving the average GWP across 90 percent of covered products beats the industry mean by 30 percent (MA Bill H.3337 PDF, 2025).

Whatever door you pick, transparent product data is the ticket. EPDs are the only currency accepted in two of the three options.

Timelines and Thresholds

• Rules must be written within one year of enactment. • Projects bid after rulemaking must comply immediately. • The Division of Capital Asset Management will ratchet targets every two years to stay on the net-zero glide path (MA Bill S.2127, 2025).

There is still details to hash out, but the clock will start the moment the governor signs.

The Revenue Case for Manufacturers

Public owners procured roughly US $4 billion in vertical construction inside Massachusetts last year (MA DCAMM, 2024). Winning even a small slice often hinges on spec compliance. Vendors armed with product-specific EPDs can close bids faster and command premium placement, offsetting document costs many times over.

Choosing an LCA Partner Who Moves at Legislative Speed

Regulators grant just twelve months to build databases, craft specs, and train procurement teams. Your LCA firm must gather site data quickly, navigate the right PCRs, and publish through a program operator recognized by architects in New England. Slow paperwork will bench your product before tip-off.

Watch-List Items

Design software alignment, database selection, and verification audits remain undefined. Keep an eye on draft rules late 2025 and the first biennial review in 2028, when the GWP cut could deepen beyond 30 percent.

Ready or Reactive—Your Call

S.2127 / H.3337 rewrites the playbook for selling into state projects. Manufacturers who invest in credible, project-specific EPDs now will greet the new rules with a shrug while competitors scramble to catch up.