March 5, 2024

The Environmental Protection Agency (EPA) is seeking comments on, and will host a public webinar in connection with, a draft document entitled “EPA Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials” (PCR Criteria document). The Inflation Reduction Act authorized $100 million for the EPA to develop a program to identify and label construction materials and products that have substantially lower embodied carbon, in coordination with the General Service Administration, and the Department of Transportation’s Federal Highway Administration. On February 14, 2024, the EPA sought comments on its draft approach to implement the label program, for which comments are due by March 18, 2024.

The EPA notes that it is committed to developing a label program that creates an easy and reliable way for purchasers to identify and procure lower embodied carbon construction materials and products. In its February 14 notice, the EPA stated that its draft approach for implementation of this program includes a plan to label specific construction materials and products based on the Global Warming Potential (GWP) provided through environmental product declarations (EPDs). EPDs are disclosure documents that include key environmental impacts of products as established in product category rules (PCRs), which are a set of guidelines that determine what data should be gathered and how it will be evaluated when conducting the life cycle analysis used to create the EPD. Per the EPA, PCRs act as the guardrails for EPDs by providing specific rules, requirements, and guidelines for calculating and reporting environmental data for a product.

Per this notice, current data quality requirements and PCR process development approaches lack the consistency, transparency and oversight measures required by the federal government, and as a result, the EPA’s PCR Criteria document builds on existing standardization efforts in order to ensure high quality, consistent and transparent data and processes are used to develop the documents which will ultimately be used to set thresholds and certify products under the label program. To inform the development of the final PCR Criteria document, the EPA is seeking feedback on whether the draft PCR Criteria document adequately addresses existing gaps in data quality and standardization related to the PCRs to ensure that robust, consistent, and representative EPDs are available to support the label program.

Comments are due by April 4, 2024 and should be submitted through the federal eRulemaking portal using Docket ID EPA-HQ-OPPT-2024-0075. Additionally, the EPA will host a webinar in connection with the draft PCR Criteria document on March 21, 2024 from 1pm to 2pm ET. Those interested in participating in the webinar must register here by 12pm ET on March 21, 2024.

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