Does S6931A force every bidder to have an EPD?

The bill says agencies must **request** EPDs “when available.” In practice, teams that supply eligible materials without an EPD will be disadvantaged because evaluators cannot compare embodied-carbon numbers. Bring an EPD to stay competitive.

Which construction materials are covered by New York’s embodied-carbon guidance?

Concrete, asphalt, several steel categories, and four glass products are flagged in the GreenNY EO 22 guidance. Any of those supplied over the listed volume thresholds need EPD disclosure.

We sell into New York but do not build there. Does the rule still apply?

Yes if your product ends up in a state-funded project. Agencies will ask general contractors for EPD PDFs. If you cannot provide one, the contractor may switch to a supplier that can.

Can we use a European PCR for a U.S. EPD submission?

Often yes, provided the PCR is EN 15804 compliant and the program operator is recognized. Double-check with your LCA consultant; some U.S. operators accept EN-based PCRs, others insist on a local equivalent.

New York S6931A Turns EPDs Into Bid Passports

A new sheriff in Albany

S6931A directs every New York agency to run a sustainability and decarbonization program backed by a newly empowered GreenNY Council (NY S6931A, 2025). Within that mandate sits a clear order: for major capital work after January 1, 2026, project teams must calculate total embodied carbon and collect EPDs from bidders “when available.”

EPDs leap from optional to operational

Requiring EPDs in bids locks your impact data into the procurement process, much like a passport check before boarding. No EPD, no comparison, no ride. It is the same playbook already seen in Executive Order 22 guidance that trains buyers to ask for EPDs up-front to benchmark future carbon caps (GreenNY Guidance, 2025). Expect specifications to mention EPDs next to compressive strength or rebar grade.

What counts as “major” work?

Projects that trigger the rule include:

New state‐owned buildings over 5 000 sq ft
Adaptive reuse or gut rehabs costing ≥ 50 % of a new build
Transportation jobs meeting material thresholds in EO 22 (glass ≥ 2 000 sq ft; concrete ≥ 50 cubic yds; etc.) These thresholds mirror existing GreenNY reporting cutoffs so contractors see one set of yardsticks instead of two (GreenNY Guidance, 2025).

Why suppliers should care yesterday

State procurement in New York tops US$18 billion a year (OGS Annual Report, 2024). Even if public work is a sliver of your sales, architects will reuse state-ready specs on private jobs because it simplifies life. Showing up with an EPD keeps you in that spec stack rather than being swapped for a competitor who planned ahead.

Data wrangling just got real

Agencies must report progress by September 2026 using the NY Energy Manager portal, so their contractors must feed them clean, audit-ready impact data. That means EPD PDFs stamped to EN 15804 and published with a recognized program operator. Spreadsheet snapshots or enviromental brochures will not pass.

Picking an LCA partner without stalling production

Speed matters. The bill gives less than eighteen months until bid desks start scanning for EPD attachments. Look for partners who:

shoulder facility-level data collection rather than handing you templates to fill in
already publish through US and EU operators
commit to a delivery schedule measured in weeks, not quarters
Cheap advisors who leave you chasing utility bills risk missing the 2026 cut-off and watching bids evaporate.

The upside

Once your EPD lives in EC3 or a procurement portal, sales teams can cite concrete GWP scores that win tie-breakers and LEED points. That extra margin dwarfs credential costs—especially when the state is one of the customers footing the bill.

Act now, avoid the scramble

S6931A flips the script: carbon data first, purchase order second. Manufacturers who start their LCA this quarter will glide through 2026 tenders while late movers wrestle with rush fees and lost specs. Finish the paperwork before the paperwork finishes you.