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GSA pilots Buy Clean Inflation Reduction Act Requirements for low embodied carbon construction materials

Major milestone for industrial decarbonization advances eleven projects through materials with substantially lower levels of embodied carbon emissions

WASHINGTON — Marking a major milestone for the Biden-Harris Administration’s industrial decarbonization goals, the U.S. General Services Administration today announced a pilot of new requirements [PDF - 125 KB] for the procurement of substantially lower embodied carbon construction materials in GSA projects funded by the Inflation Reduction Act. The requirements [PDF - 145 KB] were developed with market insights gathered from domestic manufacturers, local suppliers, small businesses, and environmental and labor groups. They advance President Biden’s federal sustainability goals and efforts to strengthen American leadership in clean manufacturing and jobs.

The Inflation Reduction Act provides $3.375 billion for GSA to invest in federal buildings to help reduce carbon emissions and catalyze innovation. This Act includes $2.15 billion to procure low embodied carbon materials for construction and renovation projects. In support of the Biden-Harris Administration Federal Buy Clean Initiative, these investments are helping GSA leverage its purchasing power to spur markets for products that have substantially lower levels of embodied greenhouse gas emissions associated with their raw materials, transportation, and manufacturing — all of which occurs before GSA purchases the products. This pilot will help achieve President Biden’s federal sustainability goals, including a net zero emissions federal building portfolio by 2045, and net zero emissions procurement by 2050, while supporting good American manufacturing jobs.

“Today’s announcement marks a major step forward in our efforts to use the federal government’s buying power to catalyze innovation and strengthen American leadership in clean manufacturing and jobs,” said GSA Administrator Robin Carnahan. “We look forward to acting on what we learn from this pilot to accelerate progress toward the government’s urgent climate goals, and achieve the sustainability triple-win of good jobs, value for taxpayers and a healthier planet for future generations.”

The six-month pilot will go into effect immediately, applying the GSA interim IRA Low Embodied Carbon Material Requirements [PDF - 145 KB] into procurement for eleven GSA construction and modernization projects [PDF - 125 KB]. The pilot will generate insights into regional market availability of qualifying products and materials, and inform adjustments that may be needed for GSA’s final set of material requirements for its IRA-funded projects.

“In the face of the climate crisis, our progress will be measured by the pace with which we put steel in the ground and literally build the clean energy economy,” said National Climate Advisor Ali Zaidi. “Today, we are kicking off construction projects around the country that will put people to work on that vision, and create the demand for more climate solutions, like low-carbon steel, concrete and other materials, manufactured here and stamped Made in America.”

The GSA interim requirements are based on the U.S. Environmental Protection Agency’s Interim Determination [PDF]. They set global warming potential limits for the most carbon-intensive materials prioritized by the federal interagency Buy Clean Task Force: asphalt, concrete, glass, and steel. These limits reflect feedback from three requests for information on low embodied carbon construction materials, two industry days organized by GSA in February, and close interagency collaboration through the Buy Clean Task Force. GSA also developed FAQs [PDF - 290 KB] to address questions and comments.

The pilot signals to manufacturers that GSA requires Environmental Product Declarations for materials procured using IRA funding. EPDs are a key tool for gaining visibility into a product’s environmental impacts through its entire lifetime in a standard, third party-verified format, and they are commonly used in Buy Clean programs. Some product categories, such as hollow structural sections and structural steel plate produced in integrated steel mills, have not yet published EPDs, so the GSA pilot provides additional time for manufacturers to gather and publish data. Once adequate data is available in the market, GSA plans to establish GWP limits for individual manufacturing processes (i.e. integrated mills and electric arc furnaces) to promote innovation throughout the industry and lower emissions from all processes. The pilot also implements EPA’s Interim Determination, which establishes the definition of “substantially lower” greenhouse gas emissions based on EPDs.

“This new Buy Clean pilot will inform our whole-of-government approach to accelerating the innovation and adoption of more environmentally-preferable construction materials needed to rebuild our nation’s infrastructure,” said EPA Administrator Michael S. Regan. “By addressing pollution from energy-intensive manufacturing and learning from GSA’s construction projects, we can bolster Federal Buy Clean efforts and make significant gains towards our climate goals and a stronger economy.”

The GSA pilot requirements are a part of the Biden-Harris Administration’s comprehensive approach to industrial decarbonization. While GSA and the U.S. Department of Transportation engage the market for these products to encourage increased EPD harmonization and availability, EPA is working to establish new grant, technical assistance and carbon labeling programs for construction materials. These actions are also aligned with the U.S. Department of Energy’s $6 billion Industrial Demonstrations Program, which will provide funding to accelerate emissions reductions in energy-intensive industries and help scale production of promising new technologies.

“GSA has been an industry leader in high-performance green buildings for more than 20 years. We will continue to work with industry as we pilot lower embodied carbon materials, which represent almost a third of the built environment’s total emissions,” said GSA Public Buildings Service Commissioner Nina Albert. “GSA also continues to strive for net zero carbon from operations across its portfolio of approximately 1,650 federally-owned buildings located across the United States.”

GSA will share these new requirements with other federal agencies to inform governmentwide construction procurement as well as signatories of the Federal-State Buy Clean Partnership. GSA continues to solicit questions and comments on these requirements at


About GSA: GSA provides centralized procurement and shared services for the federal government, managing a nationwide real estate portfolio of nearly 370 million rentable square feet, overseeing approximately $75 billion in annual contracts, and delivering technology services that serve millions of people across dozens of federal agencies. Our mission is to deliver the best customer experience and value in real estate, acquisition, and technology services to the government and the American people. Follow us at @USGSA.