SB 755: California’s New Climate Check for State Contractors
Most manufacturers breathed a sigh of relief when Buy Clean only covered four materials. SB 755 erases that comfort zone: every company selling **anything** to a contractor with a California state contract above $5 million will soon need to feed their customer reliable greenhouse-gas numbers. Blow the deadline and your product may vanish from bid lists.
What the bill says in plain English
SB 755, the California Contractor Climate Transparency Act, piggybacks on last year’s corporate disclosure laws and pulls state vendors into the spotlight (LegiScan, 2025). Contractors must forward their own emissions data to the Air Resources Board every year:
- $25 M+ in annual state contracts: report Scopes 1-3 plus a climate-risk analysis.
- $5-25 M: report Scopes 1-2 only.
The first filings kick in one year after CARB finalises its regulations, expected late 2026, so the reporting year likely starts in 2027.
Why manufacturers will feel the heat
Contractors cannot finish a Scope 3 inventory without supplier inputs. The G&A Institute found just 18 % of California’s top suppliers currently disclose Scope 3 numbers (G&A Institute, 2025). Expect urgent data requests once the rule is final; no numbers means no compliant bid.
EPDs: the shortcut to material Scope 3 data
A third-party verified Environmental Product Declaration already contains cradle-to-gate carbon results aligned with ISO 14025. When a contractor plugs that value into their supply-chain calculator, audit questions evaporate. Caltrans saw this firsthand when it began demanding EPDs for concrete and asphalt earlier this year (Caltrans Standard Specifications, 2025).
Timelines, fines, and reputational risk
CARB can levy administrative penalties up to $500,000 per reporting year for bad or missing data (SB 755 draft text, 2025). More painful: procurement officers may sideline non-responsive vendors to avoid shared liability. Losing a multi-year maintenance contract over an unverified carbon figure would sting more than any fine.
Data collection tips that keep bids flowing
- Map which SKUs move through California state projects; start with top-revenue lines.
- Gather 2024 utility, material, and waste records for the plants that make those SKUs.
- Choose an LCA partner that handles the grunt work of supplier surveys and utility audits so your process engineers stay on the line, not in spreadsheets.
- Plan for annual refresh cycles; build a standing folder structure so next year’s update takes days, not months.
How SB 755 meshes with Buy Clean
Buy Clean sets maximum embodied-carbon limits for four materials. SB 755 asks for company-wide emissions. Together they create a two-prong test: product-level EPDs secure the material spec, while enterprise data keeps the purchase order alive. Caltrans already treats them as two sides of one sustainability coin (Deloitte-CLF, 2025).
Get audit-ready before the RFP drops
The window between a request for proposal and bid submission is shrinking. Having verified EPDs and a living GHG inventory on the shelf means you can answer Scope 3 questionnaires in an afternoon, not a quarter. Wait and you might discover the ship sailed with your competitor on deck. Dont be late.
Frequently Asked Questions
Does SB 755 mandate that every product sold to the state has its own EPD?
No; the bill focuses on contractor-level emissions. However, contractors will lean on EPDs because they supply third-party verified cradle-to-gate carbon data that counts toward Scope 3, making compliance far easier.
What size manufacturers fall under SB 755?
Technically the rule targets contractors, not product makers. Yet if your customer holds more than $5 million in annual California contracts, expect a data request regardless of your own revenue.
Will Buy Clean compliance automatically satisfy SB 755?
Only partially. Buy Clean covers embodied carbon for specific materials, while SB 755 requires broader Scope 1-3 numbers and climate-risk disclosure at the contractor level. You still need a corporate-level emissions inventory.
When will reporting actually start?
CARB must publish regulations first, projected late 2026. Reporting would then begin the following calendar year, so 2027 data would likely be the first submission.
Can generic databases replace product-specific EPDs?
Generic factors may fill small gaps, but contractors risk penalties if estimates diverge materially from reality. Verified, product-specific EPDs remain the gold standard for defensible Scope 3 figures.
About the Author
Eric works at the intersection of sustainability, regulation, and business strategy, helping manufacturers navigate the evolving landscape of EPDs and LCAs. Having spoken with hundreds of teams across North America, brings a deep understanding of what drives ROI, what regulators are asking for, and how companies can stay ahead with smart, scalable approaches to environmental reporting.
