Minnesota SF 3136: EPDs Set to Steer State Purchasing
Minnesota already shells out more than $2 billion a year on goods and services for public projects (Minnesota Department of Administration, 2024). If SF 3136 passes, that spend will lean heavily toward products backed by trustworthy Environmental Product Declarations and low-carbon benchmarks. Here’s what manufacturers need to know before the procurement tide turns.
What SF 3136 Actually Does
Filed on April 1, 2025, SF 3136 would shift day-to-day control of the Environmental Standards Procurement Task Force from general administration to the Minnesota Department of Transportation (MnDOT) (LegiScan, 2025). The bill doesn’t rewrite the rules—it moves the referee. Expect faster integration with MnDOT bid specs and tighter feedback loops between material data and project delivery.
The Task Force in a Nutshell
Created by statute 16B.312 in 2023, the Task Force is charged with two big asks:
- Require vendors to submit third-party EPDs during bidding.
- Set greenhouse-gas limits for key construction materials (Minnesota Statutes 16B.312, 2024). The group’s membership spans concrete, asphalt, steel, labor, and environmental NGOs, meaning the final playbook will balance technical feasibility with policy ambition.
Which Materials Are on Deck First?
- Ready-mix concrete and cementitious binders
- Hot-mix asphalt
- Rebar and structural steel
- Glass, aluminum, and insulation are under review for phase-two (Task Force website, 2025). If your catalog touches any of these, assume an EPD will soon be the price of admission.
Likely Performance Benchmarks
Early Task Force minutes hint at using Global Warming Potential (GWP) percentile caps—think: “no higher than the 60th-percentile product on EC3 for a given mix design.” Hard numbers are still in flux, but the direction is crystal clear: average won’t cut it.
Procurement Timeline You Can’t Ignore
The current draft aims for pilot GWP limits by the 2027 construction season, then full enforcement on all state-funded vertical and horizontal projects in 2028. MnDOT’s ten-year capital highway plan peaks at about $833 million in 2026 alone (MnDOT Metro District Plan, 2024), so missing the first cutoff could sideline lucrative bids.
Data Hurdles Hiding in Plain Sight
Gathering twelve months of energy, waste, and mix data from multiple plants takes longer than anyone admits. A timline crunch is a real risk when finance and plant ops are already swamped. Give yourself at least six months of runway before the Task Force finalizes its spec.
Smart Moves for Manufacturers
- Map your current PCR landscape. If competitors rely on the same rulebook, follow suit; switching later means a full recalculation.
- Run a dry-run LCA now to spot carbon hotspots. Tweaking mix designs or fuel sources today beats emergency retrofits later.
- Pick an LCA partner who will herd internal data, not just hand you a spreadsheet template.
Payoff Beyond Compliance
Public projects dominate Minnesota’s heavy-civil pipeline, and spec writers rarely list alternates once a low-carbon baseline is baked in. An EPD that undercuts the Task Force’s future GWP cap by even 10 percent can lock in preferred-supplier status before rivals get their paperwork in order.
Frequently Asked Questions
Will SF 3136 add new material types to the EPD requirement?
Not directly. The bill is administrative; however, the Task Force it empowers is already studying insulation, lumber, and glass for the next wave (Task Force website, 2025).
Do I need to publish through a specific program operator for Minnesota projects?
No. The statute is operator-agnostic. Any ISO 14025-compliant EPD will count, whether it’s published with UL, IBU, or Smart EPD.
How often will I need to refresh my EPD?
Expect a five-year validity window under EN 15804-A2 rules. If the governing PCR updates sooner, you’ll need to align at the next renewal.
Can small batch changes trigger non-compliance?
Yes. If a revised mix pushes your GWP above the Task Force’s cap, you’ll have to re-submit an updated EPD or risk bid rejection.
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.
