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Embedded carbon emissions the new, critically important factor in construction

Embedded carbon emissions the new, critically important factor in construction

In a first-of-its-kind move for a U.S. state, the State of New York has mandated that all concrete used in state-funded building or transportation projects must meet certain low embedded-carbon emissions standards. This comes as part of the state’s goal to achieve a net zero economy by 2050.


Starting in 2025, concrete producers will be required to provide emissions data for state agency contracts exceeding $1 million and involving more than 50 cubic yards of concrete, or state Department of Transportation contracts exceeding $3 million and involving more than 200 cubic yards of concrete. Important to note is that this data must encompass emissions across the entire life cycle of the product’s manufacturing process – not just the final production step. The State of New York is currently working with producers on the methodologies for properly demonstrating compliance with these mandates.

The U.S. federal government is on a similar trajectory through its Federal Buy Clean Initiative, leveraging its role as the largest purchaser in the world with $630 billion annual budget, to incentivize low emission construction products.


In December 2021, President Biden issued Executive Order 14057, enacting the Buy Clean Task Force and charging the federal agencies with prioritizing low-carbon building materials in federal procurement and federally funded projects. Agencies across the federal government have already implemented programs under this objective, with the General Services Administration (GSA) initiating a pilot program of new requirements for lower embodied carbon construction materials in GSA Inflation Reduction Act (IRA)-funded projects earlier this year.

It's expected for states beyond New York to follow similar measures. As part of the federal initiative, the Biden Administration also introduced the launch of a new Federal-State Buy Clean Partnership in March 2023, which was signed by California, Colorado, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New York, Oregon, and Washington. This partnership serves as a commitment from participating states to prioritize lower-carbon infrastructure materials, and to engage in further collaboration with each other and the federal government in setting a clear demand signal to the marketplace.

Looking globally, low embedded carbon in construction projects is quickly becoming the standard in the concrete industry and across other construction materials, including aluminum, iron, and steel. Policies like the Europe’s Carbon Border Adjustment Mechanism (CBAM) imposes tariffs on the embedded carbon and origin of these carbon-intensive products to prevent the risk of carbon leakage - where EU companies move carbon-intensive production to countries with less stringent climate policies.


As of 1st October 2023, the transitional phases of the CBAM came into force, requiring companies to calculate, monitor and report on the embedded emissions of imported products. Then from January 2026, companies will be required to purchase carbon certificates, based on embedded emissions and origin, tied to the Emissions Trading System (ETS) market price.

The issue of embedded emissions tracking is also gaining attention in the U.S. Congress. A selection of members have publicly supported a form of CBAM legislation, similar to that of the EU, including a bill by Senator Cassidy (R-LA) that could be introduced as early as year’s end. Another bipartisan group of Senators introduced the PROVE It Act earlier this year, which requires the U.S. government to track emissions across the manufacturing process of certain goods like aluminum, glass, iron, steel, natural gas, plastics, and lithium-ion batteries. Many are calling this bill a “step in the direction” of CBAM legislation like Cassidy’s supposed draft bill.


As more markets require proof of the sustainability of their construction materials and projects, companies need a system to prove the emissions intensity of their upstream supply chains.

Using Circulor’s Emissions Tracking and Material Traceability capabilities available through its PROVE platform, customers gain end-to-end visibility of their upstream emissions, attributing CO2-e data to individual products by dynamically aggregating emissions data at each step of the supply chain based on the actual flow of materials. Customers can then use this continuous, granular supply chain data on product quantities, inherited emissions, and origin to complete regular reports that the EU, U.S. and its various states increasingly require.


Taking a comprehensive approach to trace the entire lifecycle of materials enables accurate embedded emissions calculations using primary data based on the flow of materials. An emissions tracking solution that gathers granular data on an ongoing basis will save both time and money to meet this growing global standard.


To discover more about Circulor’s PROVE platform, its Emissions Tracking and Material Traceability solutions, and how this satisfies growing global requirements for sustainable products, visit us here and read more on our blog here.

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