U.S. Criteria for Product Category Rules (PCRs) to Support the Label Program for Low Embodied Carbon Construction Materials

Background

An increasing number of U.S. federal, state, and local government and institutional procurement policies are aimed at driving down greenhouse gas (GHG) emissions by selecting construction materials with lower embodied carbon impacts. Embodied carbon refers to the GHG emissions released during the life cycle of construction materials and products. As such, these policies require manufacturers to disclose the embodied carbon of the materials and products. The Inflation Reduction Act (IRA), which passed in 2022, authorized $100 million to EPA to develop a program to identify and label construction materials and products that have substantially lower embodied carbon.

EPA is working to address existing gaps in data quality and standardization to ensure robust, consistent, and representative EPDs are available to support the Label Program for Low Embodied Carbon Construction Materials. In March, EPA published a notice to seek public input on its draft Criteria for Product Category Rules (PCRs) to support the Label Program for Low Embodied Carbon Construction Materials. The criteria outline the metrics for which PCRs may be eligible to be used under EPA’s Label Program. ACA and the coatings industry has a vested interest in the criteria, as coatings are used on many construction materials and the label program may eventually include coatings products. ACA has developed three PCRs for the industry: a PCR for Architectural Coatings, a PCR for Resinous Floor Coatings, and a PCR for Powder Coatings. ACA is finalizing a fourth, a PCR for Coil Coatings. ACA reviewed the draft criteria and provided comments requested EPA consider having a clearly defined list of construction material categories with a phased timeframe approach for implementation.

ACA Action

ACA submitted a comment letter to EPA in early April 2024 regarding the Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials and will continue to monitor any further developments.

ACA Staff

Katherine Berry
Director of Sustainability & Environment

Suzanne Chang
Counsel