Do self-declared (Type II) environmental claims satisfy NYC’s low-carbon material requirement?

No. The Guidelines call for third-party-verified Type III EPDs that follow ISO 14025. Self-declared numbers will be marked as non-compliant.

Will an EPD published under a now-expired PCR be rejected?

Not automatically. However, NYC reviewers may ask for confirmation that the EPD remains valid and request an update if a newer PCR exists before procurement begins.

Does mass timber automatically qualify as a low-carbon material?

No. Timber elements must still provide an EPD showing cradle-to-grave impacts. Biogenic carbon accounting rules apply, and transport distances can erode the advantage.

How often should manufacturers update EPDs for the NYC market?

At least every five years, or sooner if a major process change (like switching to renewable electricity) significantly lowers impacts and could help reach the 25 % low-carbon threshold.

NYC Clean & Circular Rules: What Suppliers Must Know

From aspirational to mandatory

NYCEDC’s Clean and Circular Guidelines launched in March 2025 and will now ride along with every city-backed RFP larger than $5 million (NYCEDC, 2025). Private developers are already copying the template to de-risk permitting delays. The headline target is a 50 % cut in embodied carbon for new projects by 2033, echoing PlaNYC 2023 goals (PlaNYC, 2023).

Three numbers that decide the shortlist

75 % diversion of construction and demolition waste.
95 % reuse or recycling of concrete and soil.
25 % of installed materials must qualify as low-carbon (NYCEDC, 2025).

If your product cannot document its GWP in kg CO₂e, it simply cannot count toward the 25 %. An EPD is the only widely accepted receipt.

EPDs: passport to the “low-carbon” column

Spec writers need apples-to-apples comparisons. A Type III EPD under EN 15804 or ISO 21930 provides that, plus transparency on acidification, eutrophication, and other impact categories. Without it, estimators will mark your SKU as non-compliant and move on.

Data hurdles hidden in the forms

The new RFP template asks for:

A1-A3 cradle-to-gate impacts from a third-party-verified EPD.
Proof that the underlying PCR will still be valid at project groundbreaking (often two to three years out).
A commitment letter for end-of-life take-back or recycling.

Suppliers with historic energy bills scattered across plants know the pain. An LCA partner that wrangles multisite data quickly (and flags missing utility meters) saves weeks.

Circularity now covers C stages too

The Guidelines reward products that design for deconstruction. Including C1–C4 impacts (demolition through disposal) can bump your material into the preferred tier, especially if you can show closed-loop recycling rates above 80 %. Keep in mind that generic databases may over-penalize end-of-life impacts. Primary plant data beats default factors every time.

ROI: first movers book more of the 26 000-ton prize

SPARC Kips Bay—the Guidelines’ pilot campus—will avoid 26 400 t CO₂e by swapping in mass timber and low-carbon concrete (NYCEDC, 2025). Winning suppliers there expect multi-phase orders through 2031 worth far more than the cost of their EPD portfolios. Slow adopters lost those line items before they even priced them, ouch.

Quick moves before your next NYC bid

Audit your catalog for EPD gaps.
Map PCR expiry dates against your bid calendar.
Line up plant utility data for the most in-demand SKUs.
Draft a take-back policy that facilities can actually execute.

A bit of prep now beats scrambling later, because reviewing teams in New York wont wait.