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EPA Seeks Comments to Help Inform Program for Labeling Low Embodied Carbon Construction Materials

The Environmental Protection Agency (EPA) is seeking comments on its Draft Approach for Implementation of the EPA Label Program for Low Embodied Carbon Construction Materials (Draft Label Program Approach). The Inflation Reduction Act authorized $100 million to 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.

In the Draft Label Program Approach, the EPA has outlined the following: (1) a phased approach that all material categories will be able to follow at a cadence that aligns with that material’s market maturity and data availability; (2) a plan to label specific construction materials and products based on the Global Warming Potential (GWP) provided via robust environmental product declarations; (3) a publicly accessible online registry of certified materials and products; (4) a tiered rating system of certification for materials and products; and (5) a conformity assessment and verification system aligned with the existing Environmental Product Declaration verification system, and consistent with standards and best practices within the ISO IEC 17000 series and EPA’s Framework for Assessing Environmental Performance for Specifications, Standards, and Ecolabels for Federal Purchasing.

Per this notice, EPA is seeking public input on specific aspects of the Draft Label Program Approach and explains that the following topics may help inform stakeholder input on the Draft Label Program Approach: (1) suggestions on ways to improve background data, enhance publicly available datasets in the Life Cycle Analysis (e.g., analysis of environmental impact over the course of the entire life cycle of a product material, process, or other measurable activity) Data Commons, and facilitate improvements to Product Category Rules; (2) input on what methods would be effective, feasible, and time- and cost-effective for specifying regional differences specific to the sourcing of construction materials and products in the GWP threshold setting process; (3) input on how to effectively define “representative” data for a specific material type when setting GWP thresholds; (4) input on whether the conformity criteria and processes used by EPA programs (e.g., ENERGY STAR, WaterSense) should be applied to the Draft Label Program; and (5) other feedback, questions, comments, or additional information for consideration.

Comments are due by March 18, 2024 and can be submitted through the federal eRulemaking portal here using Docket No. EPA-HQ-OPPT-2024-0038. EPA will also host a webinar on the Draft Label Program Approach on February 27, 2024 from 12pm to 1pm ET. Registration is due by 5pm ET on February 26, 2024 and can be completed through Zoom here.

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