Inflation Reduction Act low-embodied carbon material requirements

Inflation Reduction Act of 2022, Pub. L. No. 117-169

April 10, 2025

• Concrete
• Cement
• Concrete masonry units
• Asphalt
• Steel
• Glass

Concrete

IRA LEC concrete requirements

• Where provision of concrete that qualifies under our IRA concrete limits is impractical, our IRA limits for cement may be applied to the cement being used in the concrete mix.

Assemblies

• Construction product assemblies (such as rebar-reinforced concrete, or concrete made with qualifying cement) qualify for IRA funding if at least 80% of the assembly’s total cost or total weight comprises materials that meet these requirements.

Compliance documentation

• A product-specific Type III (third-party verified) Environmental Product Declaration, or EPD, that: (i) is based on the PCR used to develop these limits: NSF International’s Product Category Rule for Concrete [PDF] (8/2021, version 2.1 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, such as concrete’s upstream cement plant, rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Cement

IRA LEC cement requirements

• As an alternative to concrete, our IRA limits for cement may be applied to the cement being used in the concrete mix.
  • A concrete EPD accounts for the whole mix design, including quantitative impacts of specific cements, aggregates, and admixtures.
  • If a concrete EPD is provided to demonstrate compliance, a cement EPD doesn’t need to be submitted to us. Cement is an input to concrete mixes, and its GWP is accounted for in the concrete EPD.

Assemblies

• Construction product assemblies can also qualify for IRA funding where at least 80% of the assembly’s total cost or total weight comprises IRA-qualifying material such as low embodied carbon cement.

Compliance documentation

• A product-specific Type III (third-party verified) Environmental Product Declaration, or EPD, that: (i) is based on the PCR used to develop these limits: NSF International’s Product Category Rule for Portland, Blended, Masonry, Mortar, and Plastic (Stucco) Cements [PDF] (5/2020, version 3.0 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Concrete masonry units

IRA LEC concrete masonry unit, or CMU, requirements

Compliance documentation

• A product-specific Type III (third-party verified) Environmental Product Declaration, or EPD, that: (i) is based on a PCR for the applicable product category that was active when the EPD was issued, and which was used to develop these limits: UL’s Part B: Concrete Masonry and Segmental Concrete Paving Product EPD Requirements (11/2020, version 1.0 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, such as concrete’s upstream cement plant, rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Asphalt

IRA LEC asphalt requirements

Compliance documentation

• A product-specific Type III (third-party verified) EPD that: (i) is based on the PCR used to develop these limits: the National Asphalt Paving Association’s Product Category Rule for Asphalt Mixtures [PDF], (4/2022, version 2.0 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, such as asphalt binder production, rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Steel

IRA LEC steel requirements

Assemblies

• Construction product assemblies (such as fabricated steel products including handrails, conduit, ductwork, pipes, metal raceways, and so on) qualify for IRA funding if at least 80% of the assembly’s total cost or total weight comprises materials that meet these requirements.

Compliance documentation

• A product-specific Type III (third-party verified) EPD that: (i) is based on the PCRs used to develop these limits: UL’s PCR Guidance for Building-Related Products and Services, Part B: Designated Steel Construction Product EPD Requirements [PDF] (8/2020, version 2.0 or later) or SCS Global Services’ PCR for Designated Steel Construction Products [PDF] (5/2015, version 1.0 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, such as fabricated steel’s upstream steel mill(s), rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Glass

IRA LEC glass requirements

Assemblies

• Construction product assemblies (such as processed glass fabricated from flat glass, or insulating glass units containing flat glass) qualify for IRA funding if at least 80% of the assembly’s total cost or total weight is comprised of materials that meet these requirements.
  • For purposes of the calculation, the glazing assembly on curtain wall, storefront, or punch window conditions includes only the assembly components of the glazing unit (such as an IGU or laminated glazing unit). Glazing assembly components include flat glass lites, any laminate interlayers (such as PVB), any fritting or internal IGU shading components, spacer and created airspace, desiccant, and perimeter edge seals.
    • Assembly components exclude adjacent materials from the glazing unit assembly calculation, such as window sashes and framing, gaskets, sealants, seals, air vapor barrier, and structural connections. Those adjacent materials may be covered as expenses necessary to acquire and install approved products, materials, and assemblies.

Compliance documentation

• A product-specific Type III (third-party verified) EPD that: (i) is based on the PCR used to develop these limits: the NSF International / National Glass Association Flat Glass PCR [PDF] (9/2020, version 2.0; or 3/2013, version 1.0 or later); and (ii) conforms with ISO 14025 and ISO 21930.
  • Where feasible, EPDs must also be based on supply chain-specific data for associated unit processes, such as facility-specific data for processed glass’s upstream glass plants, rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas-intensive processes is unavailable, an EPD without such data that meets compliance documentation criteria (i) and (ii) is sufficient.

Footnotes

¹“High early strength” is concrete that, through the use of additional cement, high-early-strength cement, or admixtures, has accelerated early-age strength development. High early strength concrete produced using additional cement should be avoided where possible, due to its higher embodied carbon. An affected project delivery team must obtain written approval from our IRA PMO on whether high early strength concrete is necessary for technical reasons. This 30% allowance reflects input from structural engineers, general contractors, and ready-mix or cement producers.

²Based on input from the glass industry about inconsistent data from the limited set of processed glass and insulating glazing unit EPDs, we are only issuing GWP limits for un-fabricated flat glass at this time.