Introduction: EPD Mandates Are No Longer Just a European Story
countries and jurisdictions worldwide have adopted or proposed Buy Clean policies that require or incentivise Environmental Product Declarations for construction materials in public procurement.
For years, the Environmental Product Declaration was primarily a European instrument. Rooted in ISO 14025 and operationalised through EN 15804, EPDs were the language of environmental transparency in the EU construction market — driven by green building certification systems, voluntary procurement guidelines, and progressive national building codes.
That geography is changing rapidly. Since 2021, a global wave of Buy Clean policies has spread EPD mandates far beyond Europe. The United States, Canada, Australia, Japan, and several emerging economies have adopted or proposed legislation that requires construction materials used in publicly funded projects to carry verified environmental declarations — and in some cases, to meet maximum embodied carbon thresholds.
This article maps the global spread of Buy Clean policies, examines how different jurisdictions approach EPD mandates, and explains what the trend means for construction-product manufacturers — especially European producers who already have EN 15804+A2-compliant EPD programmes.
What Is Buy Clean?
The Core Concept
Buy Clean is a procurement policy approach that uses the purchasing power of public infrastructure investment to drive environmental performance in the construction materials supply chain. The logic is straightforward: governments spend enormous sums on roads, bridges, buildings, and infrastructure. By requiring that the materials used in these projects carry verified environmental data — and in some cases, meet maximum carbon intensity thresholds — governments can steer the market toward lower-carbon products without imposing direct regulatory mandates on manufacturers.
The Typical Buy Clean Architecture
| Component | Description | Example |
|---|---|---|
| Scope | Which projects are covered (public buildings, infrastructure, or all public procurement) | US Federal: all federal construction >$35M |
| Material categories | Which products must carry EPDs (typically high-carbon materials first) | Steel, concrete, asphalt, flat glass, timber |
| EPD requirement | Whether a verified EPD is required as a condition of procurement | Mandatory for covered materials |
| GWP thresholds | Whether maximum GWP limits apply (some jurisdictions start with disclosure only) | California: product-specific GWP limits |
| Preference mechanisms | Whether lower-GWP products receive scoring advantages in competitive tenders | GSA scoring credit for below-average GWP |
The United States: Federal and State-Level Action
Federal Buy Clean Policy
The US federal government launched its Buy Clean initiative in 2022, initially as an executive action under the Biden administration and subsequently reinforced through the Inflation Reduction Act (IRA) and the Federal Acquisition Regulation (FAR). The policy requires that federally funded construction projects above a threshold value use materials that carry verified EPDs for covered product categories.
The General Services Administration (GSA) and the Federal Highway Administration (FHWA) are the lead implementing agencies. GSA has published interim requirements for federal buildings, while FHWA has issued guidance for federally funded highway and bridge projects.
Covered materials (federal): The initial scope covers structural steel, concrete, asphalt, and flat glass. The Administration has signalled plans to expand coverage to additional materials including timber, insulation, and gypsum products. Product-specific GWP thresholds are being developed based on industry EPD data analysis.
California: The Pioneer
California’s Buy Clean California Act (AB 262), enacted in 2017, was the first Buy Clean legislation in the US. It requires state-funded projects to use structural steel, concrete reinforcing steel, flat glass, and mineral wool insulation that carry EPDs and meet maximum GWP limits set by the California Department of General Services. The GWP limits are updated periodically based on industry data.
California’s approach is notable for setting binding GWP thresholds, not just disclosure requirements. Products exceeding the maximum GWP cannot be used in covered state projects — creating a hard market signal that differentiates low-carbon and high-carbon products.
Other US States
Following California’s lead, multiple US states have adopted or proposed Buy Clean legislation:
- Colorado (HB 22-1329) — requires EPDs for state-funded construction projects
- New York — enacted Buy Clean legislation requiring EPDs and GWP limits for state projects
- Oregon, Washington, Minnesota — various Buy Clean bills at different stages of legislative process
Canada: Provincial and Federal Momentum
Federal Green Procurement Policy
Canada’s federal government has incorporated embodied carbon requirements into its Greening Government Strategy. The policy requires that major federal construction projects calculate and report the embodied carbon of key structural materials. While the federal policy is currently disclosure-focused rather than threshold-based, it creates a clear market signal that EPDs are expected for products supplied to federal projects.
British Columbia: Zero Carbon Step Code
British Columbia has gone further through its Zero Carbon Step Code, which includes provisions for embodied carbon alongside operational carbon targets. The Step Code creates a voluntary pathway for municipalities to adopt progressively stricter carbon requirements — and EPDs are the primary tool for quantifying the embodied carbon component.
Standard alignment: Canadian Buy Clean policies generally accept EPDs compliant with ISO 14025 and ISO 21930 (the North American equivalent of EN 15804 for construction products). European manufacturers with EN 15804+A2 EPDs may need to verify alignment with North American PCR requirements, but the core LCA methodology is compatible.
Australia and Asia-Pacific
Australia: National Carbon Offset Standard for Buildings
Australia has incorporated embodied carbon considerations into its National Australian Built Environment Rating System (NABERS) and the Green Star rating system administered by the Green Building Council of Australia. Several state governments — notably New South Wales and Victoria — have introduced or proposed embodied carbon requirements for state-funded infrastructure, using EPDs as the data source.
Japan: Green Procurement
Japan’s Act on Promoting Green Procurement and the Ministry of Land, Infrastructure, Transport and Tourism (MLIT) guidelines increasingly reference Type III environmental declarations for construction materials. While not yet as prescriptive as US or EU approaches, Japan’s green procurement framework creates demand for EPDs from construction-product manufacturers supplying the Japanese market.
South Korea and Singapore
South Korea operates a national Environmental Product Declaration programme under the Korea Environmental Industry & Technology Institute (KEITI). Singapore’s Green Mark certification system awards credits for products with verified EPDs, and the Building and Construction Authority (BCA) has signalled plans to strengthen embodied carbon requirements in future Green Mark iterations.
Europe: GPP and the EPBD Amplifying EPD Demand
EU Green Public Procurement (GPP)
Within Europe, Green Public Procurement (GPP) criteria published by the European Commission increasingly reference EPDs as the preferred tool for verifying the environmental performance of construction products. While EU GPP criteria are voluntary, multiple member states — including the Netherlands, France, and Sweden — have incorporated them into binding national procurement rules.
EPBD Recast and CPR Reinforcing Demand
The EPBD recast (whole-life carbon calculation for new buildings) and CPR 2024/3110 (GWP declaration as a regulated product characteristic) will create additional pull for EPDs across the EU. Together, these instruments ensure that EPD data is needed both at the building level (for WL-GWP compliance) and at the product level (for CPR declarations).
What This Means for Manufacturers
The Convergence Opportunity
The global spread of Buy Clean policies creates a convergence opportunity for manufacturers who invest in comprehensive EPD programmes. A manufacturer with a robust set of EN 15804+A2-compliant EPDs is positioned to serve multiple markets:
| Market | EPD requirement | EN 15804+A2 compatibility |
|---|---|---|
| EU (CPR + EPBD + GPP) | Mandatory (phased) | Native standard |
| US (Federal + states) | Mandatory for covered projects | Compatible via ISO 21930 alignment |
| Canada | Mandatory / voluntary (varies by province) | Compatible |
| Australia | Green Star / state procurement | Compatible |
| Japan, Korea | Green procurement / certification credits | Compatible (may require local registration) |
The Competitive Pressure
Buy Clean policies create two-sided competitive pressure. On one side, products without EPDs are excluded from a growing share of public procurement — the largest single market for construction materials in most countries. On the other side, products with above-average GWP face threshold-based exclusion in jurisdictions like California, or scoring disadvantages in competitive tenders.
Practical Recommendations
- Map your export markets against Buy Clean requirements — identify which jurisdictions require EPDs and whether GWP thresholds apply.
- Invest in producer-specific EPDs rather than relying on industry-average data. Producer-specific EPDs demonstrate your actual environmental performance and provide competitive advantage in GWP-scored tenders.
- Ensure EN 15804+A2 compliance — this is the most widely accepted EPD standard globally, with compatibility paths to North American, Australian, and Asian requirements.
- Register with internationally recognised programmes — EPDs from programme operators participating in ECO Platform mutual recognition (such as EPD Polska) are accepted across the widest range of international markets.
- Track GWP thresholds — in jurisdictions with binding GWP limits, monitor threshold updates to ensure your products remain compliant. If your GWP is close to the limit, prioritise manufacturing improvements.
The Bottom Line
Buy Clean has gone global. What started as a single California law in 2017 has become a worldwide procurement movement that makes EPDs the entry ticket for public construction markets. For construction-product manufacturers, the message is clear: an EPD is no longer a nice-to-have sustainability credential — it is a market access requirement in a growing share of the world’s largest construction markets.
European manufacturers with established EN 15804+A2 EPD programmes are well-positioned for this global shift. The investment in LCA data and third-party verification that serves the EU market also serves Buy Clean requirements in the US, Canada, Australia, and beyond. The question is not whether to invest in EPDs, but how quickly to scale coverage across your product portfolio.
Information current as of publication date. Buy Clean policies and GWP thresholds are subject to legislative updates in each jurisdiction.