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Buy Clean laws by state: embodied carbon rules for concrete, steel and glass (2026)

A registry of every enacted state Buy Clean law and federal program, with the materials covered, the GWP limits, and the dates requirements took effect.
Primary data
State statutes and agency GWP limit tables (CA, CO, MN, NY, OR, WA, MD, NJ, MA); Pub. L. 117-169 and 119-21; Census Vintage 2025
Data period
Laws and limits in force on 2026-10-18; population July 1, 2025
Latest release used
2026-10-18
Next release
Quarterly re-check (next check January 2027)
Geography
United States: states with enacted laws, plus federal programs
Sources
41 (37 Tier 1)
Short answer

Buy Clean laws are enacted in nine states as of October 2026. California, Colorado, Minnesota and New York enforce global warming potential limits on materials such as concrete, rebar and structural steel; Oregon and Washington require EPD disclosure only. The federal Buy Clean order was revoked in January 2025, and IRA funding was rescinded in July 2025.

9states with an enacted Buy Clean law (October 2026)[38][2][14][18]
4states enforcing GWP limits: CA, CO, MN, NY[1][6][15][18]
20.8%of US residents live in a state with GWP limits in force[37]
$4.5BIRA embodied carbon appropriations whose unobligated balances were rescinded on 2025-07-04[28][29]

Buy Clean laws by state: registry of laws, rules and federal actions

Checked quarterly. Last checked 2026-10-18. Entries are neutral records of public data; each links to its source record.

Jurisdiction or programMaterials and requirement typeDateEvidenceSource
California: Buy Clean California Act (DGS)Structural steel, rebar, flat glass, insulation. Facility-specific EPD and GWP limit on public works; 7 limits; rebar and mineral wool limits lowered on 2025-01-01.2022-07-01bothRecord
California: CALGreen embodied carbon (BSC)Steel, rebar, glass, mineral wool, concrete. Reuse, whole-building LCA (10% cut) or product GWP limits on nonresidential projects of 100,000 sq ft or more, including private buildings; 50,000 sq ft from 2026-01-01.2024-07-01agency rule or guidanceRecord
California: AB 2446 (CARB framework)All building materials. Framework due 2025-07-01 toward a 40% net cut in building-material emissions by 2035-12-31; planning, not a procurement rule.2025-07-01statuteRecord
Colorado: Office of the State ArchitectAsphalt, cement and concrete, glass, post-tension steel, rebar, structural steel, wood. EPD and GWP limit on state public projects above $500,000.2024-01-01bothRecord
Colorado: Department of TransportationConcrete, asphalt, rebar. EPD and GWP limit at the 90th percentile; structural steel and precast limits TBD.2025-07-01bothRecord
Minnesota: Buy Clean Buy Fair (Admin, MnDOT)Ready-mix concrete and rebar in buildings (limits); other steel, CMU, precast (EPD). Applies to projects advertised from 2026-07-15; remaining limits due 2028-01-15.2026-01-15bothRecord
New York: Buy Clean Concrete (OGS)Concrete. Mandatory GWP limits with EPD on agency contracts of $1 million or more; lower limits planned from 2027-01-01.2025-01-01bothRecord
Oregon: ODOT EPD programConcrete, asphalt, steel. EPD disclosure on highway contracts of $3 million or more; EPDs may not be scored before 2027-01-01.2022-06-03bothRecord
Washington: Buy Clean and Buy FairStructural concrete, rebar, structural steel, engineered wood. EPD, HPD and supplier reporting; projects over 100,000 gross sq ft, all covered projects from 2027-07-01.2025-07-01bothRecord
Maryland: Buy Clean Maryland ActCement and concrete. DGS limits due 2026-01-01; EPD before installation from 2026-07-01. Published limits not located.2026-07-01statuteRecord
New Jersey: low embodied carbon concrete creditsConcrete. Tax credits up to 5%, 3% or 8% of concrete cost on state projects; EPD cost credit up to $3,000 per facility.2023-01-30statuteRecord
Massachusetts: ECICCConcrete, steel, glass, asphalt, wood (plan scope). First Embodied Carbon Reduction Plan submitted; no binding limit located.2026-01bothRecord
Massachusetts: H.3002 (2023 to 2024)Concrete. Low-embodied carbon concrete bill; no further action taken.2024-12-31statuteRecord
Connecticut: HB 6027 (2025)Concrete, mass timber, other materials. Proposed procurement standard; referred to committee, no later action listed.2025-01-22statuteRecord
New Mexico: HB 153 (2026)Low-carbon construction materials rebate. Vetoed by the Governor, per AISC; official page not rendered.2026-03-01trade body statementRecord
Federal: Buy Clean Initiative (EO 14057)Federal procurement policy. Executive order revoked by EO 14148.2025-01-20agency rule or guidanceRecord
Federal: GSA low embodied carbon requirementsConcrete, asphalt, steel, glass. IRA Section 60503 funding; unobligated balances rescinded by Pub. L. 119-21.2025-07-04bothRecord
Federal: FHWA Low Carbon Transportation MaterialsAsphalt, concrete, glass, steel. $1.2 billion awarded to 39 state DOTs; unobligated balances rescinded.2025-07-04bothRecord
Federal: EPA EPD grants and label programAll construction materials (EPD data and labels). IRA Sections 60112 and 60116; unobligated balances rescinded.2025-07-04statuteRecord

Buy Clean laws by state: the October 2026 count

Nine states have enacted a Buy Clean law for construction materials. Four of them enforce numeric global warming potential (GWP) limits, two require disclosure only, and three rely on a pending limit, a tax credit or a planning process.

California, Colorado, Minnesota and New York enforce GWP limits on at least one construction material used in state-funded projects as of 2026-10-18 (California DGS, Colorado OSA, Minnesota Department of Administration, New York OGS). That is 4 of 9 enacted states, or 44.4%.

Oregon and Washington require environmental product declarations (EPDs) but set no ceiling (ODOT EPD Manual, 2026 edition, Washington 2ESHB 1282 final bill report). Maryland's 2023 statute orders limits for cement and concrete by 2026-01-01, but CB&C did not locate published Maryland limits on an official page on 2026-10-18 (Maryland DLS fiscal note).

New Jersey uses tax credits rather than mandates (P.L.2023, c.4), and Massachusetts has a planning law whose first Embodied Carbon Reduction Plan was submitted in January 2026 (Mass.gov ECICC). The nine-state count matches the State Climate Policy Dashboard's 'Enacted' list, updated 2026-03-05 (State Climate Policy Dashboard).

Buy Clean laws by state, October 2026

Code 5 = GWP limits in force (CA, CO, MN, NY); 4 = statute requires limits, not yet located (MD); 3 = EPD disclosure only (OR, WA); 2 = tax credit or planning law (NJ, MA); 1 = bill introduced or vetoed, not enacted (CT, NM). Blank = no Buy Clean law found.

Buy Clean laws by state, October 2026US tile map of Buy Clean status. California, Colorado, Minnesota and New York have GWP limits in force; Maryland's statute requires limits; Oregon and Washington require EPD disclosure only; New Jersey offers tax credits and Massachusetts has a planning law; Connecticut and New Mexico have bills that were not enacted. All other states are blank.AKMEVTNHWA: 3WA3IDMTNDMN: 5MN5ILWIMINY: 5NY5RIMA: 2MA2OR: 3OR3NVWYSDIAINOHPANJ: 2NJ2CT: 1CT1CA: 5CA5UTCO: 5CO5NEMOKYWVVAMD: 4MD4DEAZNM: 1NM1KSARTNNCSCDCOKLAMSALGAHITXFLPR1 to 11 to 22 to 33 to 55 to 55 to 5Status code (1 to 5)

Source: CB&C reading of state statutes and agency pages (CA DGS, CO OSA, CDOT, MN Admin, NY OGS, ODOT, WA Legislature, MD DLS, NJ Legislature, Mass.gov, CT General Assembly, AISC for NM), checked 2026-10-18

Buy Clean laws by state compared: materials, requirement type, scope and dates Download CSV
Jurisdiction and programLegal basisMaterialsRequirement typeProject scopeKey effective dateEvidence
California: Buy Clean California ActPublic Contract Code 3500 to 3505 (AB 262, 2017)Structural steel, rebar, flat glass, insulationFacility-specific EPD plus GWP limit (7 limits)Public works by 9 named awarding authorities and agencies under Management Memo 18-012022-07-01 (contracts awarded)both
California: CALGreen Sections 5.105 and 5.409Building Standards Code (2022 Supplement)Steel, rebar, flat glass, mineral wool, ready-mixed concreteChoice of building reuse, whole-building LCA (10% cut) or product GWP limits (175% of BCCA)Nonresidential projects of 100,000 sq ft or more; 50,000 sq ft from 2026-01-01; includes private buildings under BSC authority2024-07-01agency rule or guidance
Colorado: Office of the State ArchitectC.R.S. 24-92-117 (HB21-1303)Asphalt, cement and concrete, glass, post-tension steel, rebar, structural steel, woodEPD plus GWP limit (post-tension steel: no limit yet)State public projects above $500,0002024-01-01 (solicitations)both
Colorado: Department of TransportationC.R.S. 24-92-117 (HB21-1303)Concrete, asphalt, rebar (structural steel and precast TBD)EPD plus GWP limit at 90th percentileCDOT horizontal projects2025-07-01 (advertised)both
Minnesota: Departments of Administration and TransportationMinn. Stat. 16B.312 (2023)Ready-mix concrete and rebar in buildings (limits); structural steel, CMU, precast (EPD only)EPD plus GWP limit; more limits due 2028-01-15State buildings over 50,000 gross sq ft; trunk highway projects of two or more lane-miles2026-07-15 (advertised)both
New York: Office of General ServicesState Finance Law 136-d (Chapter 724 of 2021)ConcreteEPD plus mandatory GWP limitAgency contracts of $1 million or more with 50 cubic yards; DOT $3 million or more with 200 cubic yards2025-01-01 (mandatory)both
Oregon: Department of TransportationOregon Laws 2022, c.74 (HB 4139); OAR 731-005-0910Concrete, asphalt paving mixtures, steelEPD disclosure; no scoring use before 2027-01-01Highway construction and maintenance contracts of $3 million or more2022-06-03 (law effective)both
Washington: Department of Commerce and awarding authorities2ESHB 1282 (C 344 L 24), RCW 39.116Structural concrete, rebar, structural steel, engineered woodEPD, HPD and supplier data for 90% of product cost (disclosure)State-funded buildings over 100,000 gross sq ft, then over 50,000 from 2027-07-012025-07-01 (reporting)both
Maryland: Department of General ServicesChapter 202 of 2023 (HB 261)Cement and concrete mixturesStatute requires GWP limits by 2026-01-01 and EPD before installationState capital building projects of 7,500 sq ft or more2026-07-01 (solicitations)statute
New Jersey: tax creditsP.L.2023, c.4 (S287)ConcreteTax credit up to 5% (low embodied carbon), 3% (carbon capture), 8% (both); EPD cost credit up to $3,000 per facilityState projects; bid statement for 50 cubic yards or more2023-01-30 (approved)statute
Massachusetts: ECICCChapter 239 of the Acts of 2024Cement and concrete, steel, glass, asphalt, wood (plan scope)Planning: embodied carbon reduction plan, update every 2 yearsState-managed construction (plan)January 2026 (plan submitted)both

Transcribed from statutes and agency pages checked 2026-10-18. 'Evidence' shows whether the entry rests on statute text, an agency rule or guidance page, or both.

Source: [2][1][3][5][8][14][15][18][9][10][12][22][20][24] California Legislative Information; California Department of General Services, Procurement Division; California Building Standards Commission; Colorado Office of the State Architect; Colorado Department of Transportation; Minnesota Office of the Revisor of Statutes; Minnesota Department of Administration; New York State Office of General Services; Oregon State Legislature; Oregon Department of Transportation; Washington State Legislature; Maryland Department of Legislative Services; New Jersey Legislature; Commonwealth of Massachusetts (Mass.gov)

Disclosure versus limits: what Buy Clean laws require

Every Buy Clean program starts with an EPD. The split is whether the GWP printed on that EPD must fall under a state ceiling, and whether the ceiling is set at an industry average, a percentile or a multiple of a regional benchmark.

Environmental product declaration (EPD): An independently verified and registered document that reports a product's environmental impact over its life cycle; Buy Clean programs read the GWP figure from it. California requires facility-specific EPDs verified under ISO 14025 (DGS FAQ 1.1 and 5.2).

Global warming potential (GWP): Greenhouse gas emissions expressed as kilograms of CO2 equivalent per unit of product, on a 100-year basis in California's limits (DGS FAQ 1.5). Most limits cover cradle-to-gate stages A1 to A3.

  • Industry average: California sets each limit at the industry average of facility-specific GWP from public EPDs, and may only lower it (DGS FAQ 4.4, PCC 3502).
  • 90th percentile: CDOT's 2025 limits for concrete, asphalt and rebar are set at the 90th percentile of EPD data (CDOT limits memo).
  • Multiple of a benchmark: New York's concrete limits equal 150% of the NRMCA Eastern Region average, and CALGreen's product limits equal 175% of Buy Clean California values or of NRMCA Pacific Southwest benchmarks (NYS guidelines, CALGreen Table 5.409.3).
  • Regional benchmark: Minnesota's concrete limits are based on NRMCA North Central benchmark values (Minnesota GWP limits).
  • Disclosure only: Washington requires EPD, health product declaration and supplier data for at least 90% of the cost of each covered product, with no ceiling (final bill report).

Oregon's law bars ODOT from using EPDs to rank or score bids before 2027-01-01, which keeps Oregon a disclosure state until at least that date (Oregon Laws 2022, c.74).

Materials coverage: concrete in 8 states, insulation in 1

Concrete is the material most often covered, appearing in 8 of the 8 states with material rules. Rebar and structural steel follow in 5 states each; flat glass and wood appear in 2 states, and insulation only in California.

Materials coverage matrix: which construction materials each Buy Clean state covers Download CSV
StateConcreteRebarStructural steelAsphaltFlat glassWoodInsulation
CaliforniaCALGreen onlyLimitLimitNoLimitNoLimit
ColoradoLimitLimitLimitLimitLimitLimitNo
MinnesotaLimit (buildings)Limit (buildings)EPD; limit due 2028Limit due 2028NoNoNo
New YorkLimitNoNoNoNoNoNo
OregonEPDEPDEPDEPDNoNoNo
WashingtonEPDEPDEPDNoNoEPDNo
MarylandLimit required by statuteNoNoNoNoNoNo
New JerseyTax creditNoNoNoNoNoNo
States covering material (of 8)8553221

'Limit' = binding GWP ceiling in force; 'EPD' = disclosure only; Massachusetts excluded (planning only). California concrete is covered through CALGreen, not the Buy Clean California Act.

Source: [1][3][5][15][18][9][12][22][20] California Department of General Services, Procurement Division; California Building Standards Commission; Colorado Office of the State Architect; Minnesota Department of Administration; New York State Office of General Services; Oregon State Legislature; Washington State Legislature; Maryland Department of Legislative Services; New Jersey Legislature

Colorado has the widest list: 7 material categories, from asphalt to wood structural elements, although post-tension steel still has no limit because of insufficient data (Colorado OSA).

New York, New Jersey and Maryland cover concrete only (NYS guidelines, P.L.2023, c.4, Maryland fiscal note). California's Buy Clean Act does not cover concrete; California concrete limits come from CALGreen (CALGreen Table 5.409.3).

Colorado and Washington are the only states that cover wood products (Washington names engineered wood), and Colorado is the only one with wood GWP limits, for example 137.19 kg CO2e per cubic meter for glued laminated timber (OSA EE-5.1).

Stacked rebar bundles and steel beams at a public works construction site
Illustrative photograph. Generated image, not a specific project.

GWP limits compared: the same concrete can pass in one state and fail in another

For ready-mix concrete near 4,000 psi, the ceiling runs from 301 kg CO2e per cubic meter in Colorado to 566 under California's CALGreen, a spread of 265. For fabricated steel and flat glass, Colorado's ceilings sit 5.6% to 32.4% above California's.

Maximum GWP for ready-mix concrete of about 4,000 psi, by program

kg CO2e per cubic meter; lower is stricter. Strength bands: CO and MN 4,000 psi; NY 3001 to 4000 psi; CALGreen 3500 to 4499 psi

Maximum GWP for ready-mix concrete of about 4,000 psi, by programHorizontal bar chart of concrete GWP limits near 4,000 psi: Colorado 301, Minnesota 312, New York 471 and California CALGreen 566 kilograms CO2e per cubic meter. The CALGreen ceiling is 1.88 times Colorado's.kg CO2e per m3Colorado OSA (2026)301Minnesota (2026)312New York (2025)471California CALGreen566

Source: Colorado OSA EE-5.1 (January 2026); Minnesota Department of Administration (2026-01-15); NYS OGS Buy Clean Concrete guidelines; California Building Standards Commission, 2022 CALGreen Supplement Guide

Colorado OSA caps 4,000 psi ready-mix at 301 kg CO2e per cubic meter for 2026, Minnesota caps 4000 psi normal-weight mixes in buildings at 312, New York caps the 3001 to 4000 psi band at 471, and CALGreen caps the 3500 to 4499 psi band at 566 (OSA, Minnesota, New York, CALGreen). New York's ceiling is 1.56 times Colorado's; CALGreen's is 1.88 times.

Part of the gap is design, not stringency: New York and CALGreen deliberately set limits above regional averages (150% and 175%), while Colorado and Minnesota sit near their benchmarks. Minnesota's limit is 3.7% above Colorado's.

Same material, different ceiling: California vs Colorado limits for fabricated steel and flat glass

kg CO2e per metric ton; California Buy Clean (limits from 2025-01-01) vs Colorado OSA (2026)

Same material, different ceiling: California vs Colorado limits for fabricated steel and flat glassGrouped bar chart comparing California and Colorado GWP limits. Colorado's ceiling is higher for every material: rebar 1,030 vs 778, hot-rolled 1,220 vs 1,080, plate 1,730 vs 1,590, hollow sections 1,990 vs 1,830 and flat glass 1,510 vs 1,430.05001,0001,5002,0002,500kg CO2e per metric ton7781,030Rebar1,0801,220Hot-rolled section1,5901,730Plate1,8301,990Hollow sections1,4301,510Flat glassCalifornia BCCAColorado OSA

Source: California DGS, Buy Clean California Act Table 1; Colorado Office of the State Architect, Max GWP Limits EE-5.1 (January 2026)

On fabricated products, Colorado's 2026 ceilings exceed California's 2025 ceilings by 32.4% for rebar, 13.0% for hot-rolled sections, 8.8% for plate, 8.7% for hollow sections and 5.6% for flat glass (DGS Table 1, OSA EE-5.1).

Minnesota's mill-gate rebar limit of 0.755 metric tons CO2e per metric ton equals California's 755 kg unfabricated limit; Minnesota's fabricated equivalent is 0.854 (Minnesota Table 2).

GWP limits compared for the same materials across Buy Clean programs Download CSV
Material (unit)California BCCA 2025California CALGreenColorado OSA 2026Colorado CDOT 2025Minnesota 2026New York 2025
Ready-mix concrete about 4,000 psi (kg CO2e per m3)Not covered566 (3500 to 4499 psi)301365.1 (Class D)312471 (3001 to 4000 psi)
Rebar, mill gate or unfabricated (kg CO2e per metric ton)7551,560Not publishedNot stated755Not covered
Rebar, fabricated (kg CO2e per metric ton)778Not published1,030915.9 (scope not stated)854Not covered
Hot-rolled sections, fabricated (kg CO2e per metric ton)1,080Not published1,220TBDEPD onlyNot covered
Steel plate, fabricated (kg CO2e per metric ton)1,590Not published1,730TBDEPD onlyNot covered
Hollow structural sections, fabricated (kg CO2e per metric ton)1,830Not published1,990TBDEPD onlyNot covered
Flat glass (kg CO2e per metric ton)1,430Not published1,510Not coveredNot coveredNot covered

Strength bands, LCA scopes (mill gate versus fabricated) and regional baselines differ, so cross-state comparisons are indicative. CALGreen rebar 1,560 is the published 1.56 metric tons per metric ton.

Source: [1][3][6][8][15][18] California Department of General Services, Procurement Division; California Building Standards Commission; Colorado Office of the State Architect; Colorado Department of Transportation; Minnesota Department of Administration; New York State Office of General Services

Rack of concrete test cylinders in a materials testing laboratory
Illustrative photograph. Generated image, not a specific project.

What is Buy Clean California, and how CALGreen reaches private buildings

Buy Clean California is the oldest state Buy Clean law and the only one to have tightened its limits: the rebar ceiling fell 15.2% and mineral wool ceilings fell 16.4% to 19.5% on 2025-01-01. A separate building-code rule, CALGreen, applies embodied carbon requirements to large private nonresidential buildings.

The Buy Clean California Act (Public Contract Code 3500 to 3505) was added by AB 262 and took effect on 2018-01-01; it applies to public works contracts awarded on or after 2022-07-01 (California Legislative Information). DGS publishes 7 limits for structural steel (hot-rolled, hollow sections, plate), rebar, flat glass and two densities of mineral wool board (DGS).

Buy Clean California GWP limits: 2022 versus 2025 Download CSV
MaterialUnitLimit from 2022-01-01Limit from 2025-01-01Change (%)
Hot-rolled structural steel, unfabricatedkg CO2e per metric ton1,0101,0100.0
Hollow structural sections, unfabricatedkg CO2e per metric ton1,7101,7100.0
Steel plate, unfabricatedkg CO2e per metric ton1,4901,4900.0
Concrete reinforcing steel, unfabricatedkg CO2e per metric ton890755-15.2
Concrete reinforcing steel, fabricatedkg CO2e per metric ton920778-15.4
Flat glasskg CO2e per metric ton1,4301,4300.0
Light-density mineral wool boardkg CO2e per m2 at RSI 13.332.68-19.5
Heavy-density mineral wool boardkg CO2e per m2 at RSI 18.166.82-16.4

Fabricated-product limits for structural steel were also unchanged. DGS may lower limits every three years and may not raise them.

Source: [1][2] California Department of General Services, Procurement Division; California Legislative Information

DGS must review limits every 3 years and may not raise them; the next update is scheduled for 2028-01-01 and will add insulation subcategories after SB 1207 broadened 'mineral wool board insulation' to 'insulation' (PCC 3502(c), DGS news).

CALGreen Sections 5.105 and 5.409, effective 2024-07-01, require nonresidential projects of 100,000 square feet or more under Building Standards Commission authority to reuse an existing structure, show a 10% GWP cut in a whole-building life cycle assessment, or meet product GWP limits; the threshold fell to 50,000 square feet on 2026-01-01 (2022 CALGreen Supplement Guide).

AB 2446 sets a separate target: a 40% net cut in building-material emissions by 2035-12-31, with a 20% interim target by 2030-12-31, and directed the California Air Resources Board to develop a framework by 2025-07-01 (Health and Safety Code 38561.3). This report did not verify the framework's status.

Timeline of Buy Clean adoptions, 2017 to 2027

State adoptions clustered in 2021 to 2024; no new state enacted a Buy Clean law in 2025 or 2026 in this review. Binding requirements arrived later than the laws, from 2022 in California to 2026 in Minnesota and Maryland.

States with an enacted Buy Clean law, cumulative, 2017 to 2026

Year of the first enacted state law (CA 2017; CO and NY 2021; OR 2022; NJ, MN and MD 2023; WA and MA 2024)

States with an enacted Buy Clean law, cumulative, 2017 to 2026Line chart of cumulative states with enacted Buy Clean laws: 1 from 2017 to 2020, 3 in 2021, 4 in 2022, 7 in 2023 and 9 from 2024 through 2026, with no new state law in 2025 or 2026.0246810.0States2017201820192020202120222023202420252026

Source: CB&C from state statutes and bill histories (CA PCC 3500, CO HB21-1303, NY SFL 136-d, OR Laws 2022 c.74, NJ P.L.2023 c.4, MN 16B.312, MD Ch. 202, WA C 344 L 24, Mass.gov ECICC)

  • 2018-01-01: Buy Clean California Act takes effect; contracts covered from 2022-07-01 (PCC).
  • 2021-07-06: Colorado HB21-1303 signed; OSA solicitations covered from 2024-01-01, CDOT projects advertised from 2025-07-01 (OSA, CDOT).
  • 2022-06-03: Oregon HB 4139 takes effect; ODOT program due by 2025-12-31 (Oregon Laws 2022, c.74).
  • 2022-06-20: New York State Finance Law 136-d takes effect; concrete limits mandatory from 2025-01-01 (NYS guidelines).
  • 2023-01-30: New Jersey P.L.2023, c.4 approved (NJ Legislature).
  • 2023: Minnesota enacts 16B.312 and Maryland enacts Chapter 202 (MN Revisor, MGA).
  • 2024-06-06: Washington Buy Clean and Buy Fair Act takes effect; reporting from 2025-07-01 (final bill report).
  • 2024: Massachusetts Chapter 239 creates the Embodied Carbon Intergovernmental Coordinating Council (Mass.gov).
  • 2026-07-01 and 2026-07-15: Maryland solicitation rule and Minnesota limits apply.
  • 2027-01-01: New York plans lower concrete limits; Oregon may begin scoring EPDs. 2027-07-01: Washington reporting extends to all covered projects.

From the first state law in 2017 to the ninth in 2024 took 7 years. Bills in Connecticut (HB 6027, 2025) and Massachusetts (H.3002, 2023 to 2024) did not advance, and New Mexico's HB 153 was vetoed in 2026 according to AISC; see the registry for sources.

Federal Buy Clean after 2025: what official pages state

The federal layer has been largely unwound. The executive order behind the Federal Buy Clean Initiative was revoked on 2025-01-20, and Public Law 119-21 rescinded unobligated balances of all four IRA embodied carbon programs on 2025-07-04.

Executive Order 14148 revoked Executive Order 14057, which had created the Buy Clean Task Force (90 FR 8237, archived sustainability.gov page).

The Inflation Reduction Act appropriated $2.15 billion to GSA for low-carbon materials (Section 60503), $2 billion for FHWA low-carbon transportation materials grants (Section 60506), $250 million for EPA EPD assistance (Section 60112) and $100 million for EPA labeling (Section 60116), a combined $4.5 billion (Pub. L. 117-169). Public Law 119-21, approved 2025-07-04, rescinded the unobligated balances of all four (Sections 60011, 60015, 60021, 60024) (Pub. L. 119-21).

Before the rescission, FHWA awarded $1.2 billion to 39 state DOTs in November 2024, 60% of the $2 billion appropriation (USDOT). Massachusetts reported in August 2025 that its $31.9 million award had been cancelled (Mass.gov). EPA had selected 38 organizations for nearly $160 million in EPD grants on 2024-07-16 (EPA snapshot).

GSA's requirements covered 4 material categories (concrete including cement and CMU, asphalt, steel, glass); an assembly qualified when at least 80% of its cost or weight met them (GSA page, Internet Archive copy). On 2026-10-18, the live GSA requirements page, EPA's label page and FHWA's program page returned HTTP 404.

Federal Buy Clean programs and their status after 2025 Download CSV
Federal programAuthority and fundingWhat it required or funded2025 to 2026 status on official pages
Federal Buy Clean Initiative and Task ForceExecutive Order 14057 (December 2021)Task Force on embodied emissions in federal procurement; Federal-State Buy Clean Partnership of 13 statesEO 14057 revoked by EO 14148 on 2025-01-20; sustainability.gov/buyclean showed no Buy Clean content on 2026-10-18
GSA low embodied carbon material requirementsIRA Section 60503, $2,150,000,000LEC requirements for concrete (cement, CMU), asphalt, steel and glass on IRA-funded GSA work; assemblies qualify at 80% by cost or weightUnobligated balances rescinded by Pub. L. 119-21 Sec. 60021 on 2025-07-04; GSA page last updated 2025-05-19, live URL HTTP 404 on 2026-10-18
FHWA Low Carbon Transportation Materials grantsIRA Section 60506 (23 U.S.C. 179), $2,000,000,000Reimbursement and incentive funding for low-carbon asphalt, concrete, glass and steel; $1.2 billion awarded to 39 state DOTs in November 2024Unobligated balances rescinded by Sec. 60024; MassDOT reported its $31,933,577 award cancelled; FHWA program page HTTP 404 on 2026-10-18
EPA EPD assistance grants (C-MORE)IRA Section 60112, $250,000,000Grants to help manufacturers develop EPDs; nearly $160 million selected for 38 organizations (2024-07-16)Unobligated balances rescinded by Sec. 60011; live EPA pages not found on 2026-10-18
EPA low embodied carbon label programIRA Section 60116, $100,000,000Label and registry for low embodied carbon materials; Implementation Approach issued 2024-08-07Unobligated balances rescinded by Sec. 60015; live label page HTTP 404 on 2026-10-18

Status reflects official texts and page checks on 2026-10-18. Removal of a web page is recorded as a page status, not as a legal change.

Source: [27][36][28][29][30][34][35][33][32] Federal Register (National Archives); Office of the Federal Chief Sustainability Officer (archived); U.S. Government Publishing Office (govinfo); U.S. Government Publishing Office (govinfo); U.S. General Services Administration (archived); U.S. Department of Transportation; Commonwealth of Massachusetts (Mass.gov); U.S. Environmental Protection Agency; U.S. Environmental Protection Agency

How many people live in Buy Clean states

The four states with GWP limits in force hold 71.2 million residents, 20.8% of the US population. All nine enacted states hold 106.4 million, 31.1%.

Population of Buy Clean states by requirement type, July 1, 2025

Millions of residents (Census Vintage 2025)

Population of Buy Clean states by requirement type, July 1, 2025Horizontal bar chart: 71.2 million people live in the four states with GWP limits in force, 12.3 million in disclosure-only states, 9.5 million in New Jersey, 7.2 million in Massachusetts and 6.3 million in Maryland.Millions of residentsGWP limits in force (CA, CO, MN, NY)71.2EPD disclosure only (OR, WA)12.3Tax credit (NJ)9.5Planning only (MA)7.2Limits pending (MD)6.3

Source: U.S. Census Bureau, Vintage 2025 state population estimates (NST-EST2025-ALLDATA); classification by CB&C

Population of states by Buy Clean requirement type (Census Vintage 2025) Download CSV
Requirement typeStatesPopulation July 1, 2025Share of US population (%)
GWP limits in forceCalifornia, Colorado, Minnesota, New York71,200,70220.8
EPD disclosure onlyOregon, Washington12,274,6063.6
Statute requires limits (not yet located)Maryland6,265,3471.8
Tax-credit incentiveNew Jersey9,548,2152.8
Planning onlyMassachusetts7,154,0842.1
All 9 enacted statesAbove combined106,442,95431.1
United States50 states and DC341,784,857100.0

State population is a reach indicator only: Buy Clean rules apply to state-funded projects, not to all construction in a state (California's CALGreen rule is the exception for large nonresidential buildings).

Source: [37] U.S. Census Bureau

Adding the disclosure states and Maryland, 89.7 million residents (26.3%) live in states with an EPD or GWP requirement in statute or rule (Census Vintage 2025). California alone accounts for 39.4 million and New York for 20.0 million.

These figures measure the reach of the states, not of the rules: Buy Clean procurement rules apply only to state-funded projects above set thresholds.

Buy Clean laws address embodied carbon in materials. Operating emissions from existing buildings fall under building performance standards and new-building efficiency under the commercial energy code by state. Steel and glass buyers facing Buy Clean ceilings are also exposed to construction material tariffs, and the volume of affected work tracks new commercial construction.

Counts and distributions

Buy Clean states by requirement type

FormulaClassify each of the 9 enacted states by its strongest requirement in force on 2026-10-18

Inputs: fact rows for CA, CO, MN, NY, OR, WA, MD, NJ, MA effective dates; tracker row (fact sheet rows)

Result: 4 GWP limits; 2 disclosure only; 1 limits pending (MD); 1 tax credit (NJ); 1 planning (MA)

Fewer than half of enacted states (44.4%) enforce a ceiling; the rest collect data, pay incentives or plan.

Limitations: Maryland is classed pending because published limits were not located; reclassify if DGS publishes them.

Population in states with GWP limits

Formulasum(POPESTIMATE2025 for CA, CO, MN, NY) / US POPESTIMATE2025 x 100

Inputs: Census V2025 rows (fact sheet rows)

Result: 71.2 million; 20.8%

One in five US residents lives in a state that caps embodied carbon on at least one public-project material.

Limitations: Rules apply to state-funded projects, not to all construction; population is a reach indicator.

Population in all enacted Buy Clean states

Formulasum for 9 enacted states / US x 100

Inputs: Census V2025 rows (fact sheet rows)

Result: 106.4 million; 31.1%

Just under a third of residents live in a state with some Buy Clean law, including incentive and planning laws.

Limitations: Includes New Jersey (incentive) and Massachusetts (planning), which impose no EPD mandate.

Materials coverage counts

Formulacount of states (of 8 with material rules) covering each material in law or rule

Inputs: table t2 (fact sheet rows)

Result: Concrete 8; rebar 5; structural steel 5; asphalt 3; flat glass 2; wood 2; insulation 1

Concrete and steel suppliers face Buy Clean rules in the most states; glass and insulation makers mainly in California and Colorado.

Limitations: Counts treat a future limit (Minnesota asphalt, due 2028) and EPD-only coverage as coverage.

Concrete ceiling ratios near 4,000 psi

FormulaNY 471 / CO 301; CALGreen 566 / CO 301; CALGreen minus CO

Inputs: rows for CO OSA, NY, CALGreen, MN limits (fact sheet rows)

Result: 1.56; 1.88; spread 265 kg CO2e per cubic meter

A mix that passes in New York or under CALGreen can exceed Colorado's ceiling by more than half.

Limitations: Strength bands and regional baselines differ; NY band 3001 to 4000 psi, CALGreen 3500 to 4499 psi.

Colorado vs California steel and glass ceilings

Formula(CO limit - CA limit) / CA limit x 100, fabricated products

Inputs: rows for CO OSA 2026 and CA BCCA 2025 limits (fact sheet rows)

Result: Rebar 32.4%; hot-rolled 13.0%; plate 8.8%; HSS 8.7%; flat glass 5.6%

Colorado's ceilings are looser than California's for every shared material.

Limitations: EPD scopes and data vintages differ between programs.

California limit tightening, 2022 to 2025

Formula(2025 limit - 2022 limit) / 2022 limit x 100

Inputs: rows for CA 2022 and 2025 limits (fact sheet rows)

Result: Rebar -15.2% (unfabricated), -15.4% (fabricated); mineral wool -19.5% (light), -16.4% (heavy); steel sections and glass 0.0%

The first statutory review lowered 2 of 4 material categories.

Limitations: Only one review cycle so far.

IRA embodied carbon appropriations affected by the 2025 rescission

Formula60112 + 60116 + 60503 + 60506 appropriations

Inputs: IRA rows; Pub. L. 119-21 row (fact sheet rows)

Result: $4.5 billion appropriated; unobligated balances rescinded

All four federal funding lines behind Buy Clean were cut back to what had already been obligated.

Limitations: The amount actually rescinded is not stated in the law; obligated awards were not rescinded by these sections.

Download the calculations (CSV)

Key findings

  1. 9 states had enacted Buy Clean laws as of 2026-10-18, matching the State Climate Policy Dashboard list updated 2026-03-05.[38]
  2. 4 states (California, Colorado, Minnesota, New York) enforce GWP limits on construction materials in state-funded projects as of October 2026.[1][6][15][18]
  3. Oregon and Washington require EPD disclosure without GWP ceilings; Oregon may not score EPDs before 2027-01-01.[9][12]
  4. Concrete is covered in 8 states, rebar and structural steel in 5 states each, and insulation only in California (October 2026).[1][5][14][18][20][22]
  5. Colorado OSA caps 4,000 psi ready-mix concrete at 301 kg CO2e per cubic meter for 2026; CALGreen caps the 3500 to 4499 psi band at 566, 1.88 times higher.[6][3]
  6. New York's 2025 concrete limits equal 150% of the NRMCA Eastern Region average; the 3001 to 4000 psi limit is 471 kg CO2e per cubic meter.[18]
  7. California lowered its unfabricated rebar limit from 890 to 755 kg CO2e per metric ton (15.2%) on 2025-01-01.[1]
  8. Colorado's 2026 fabricated rebar ceiling (1,030 kg CO2e per metric ton) is 32.4% above California's 2025 ceiling (778).[6][1]
  9. Minnesota's mill-gate rebar limit (0.755 metric tons CO2e per metric ton, effective 2026-01-15) equals California's 2025 unfabricated limit.[15][1]
  10. CALGreen has applied embodied carbon rules to California nonresidential projects of 100,000 square feet or more since 2024-07-01, and 50,000 square feet since 2026-01-01.[3]
  11. Executive Order 14057, the basis of the Federal Buy Clean Initiative, was revoked on 2025-01-20.[27]
  12. Public Law 119-21 rescinded unobligated balances of four IRA embodied carbon programs with combined appropriations of $4.5 billion on 2025-07-04.[28][29]
  13. FHWA awarded $1.2 billion of its $2 billion low-carbon materials appropriation to 39 state DOTs in November 2024 before the rescission.[34][28]
  14. 71.2 million residents (20.8% of the US) live in the four states with GWP limits in force, per Census Vintage 2025.[37]

Executive summary

  • Nine states have enacted Buy Clean laws: California, Colorado, Minnesota, New York, Oregon, Washington, Maryland, New Jersey and Massachusetts.
  • Four states enforce GWP limits (44.4% of enacted states); 6 programs in those states have binding limits in force.
  • Concrete is covered in 8 states; rebar and structural steel in 5; asphalt in 3; flat glass and wood in 2; insulation in 1.
  • Ceilings for the same material differ widely: 4,000 psi concrete ranges from 301 (Colorado) to 566 (CALGreen) kg CO2e per cubic meter.
  • California is the only state to have lowered limits so far: rebar by 15.2% and mineral wool by 16.4% to 19.5% on 2025-01-01.
  • CALGreen extends embodied carbon rules to private nonresidential buildings of 50,000 square feet or more in California from 2026-01-01.
  • Federal Buy Clean was unwound in 2025: EO 14057 revoked on 2025-01-20 and unobligated IRA balances for GSA, FHWA and EPA programs rescinded on 2025-07-04.

Questions people ask

What is Buy Clean California?

Buy Clean California is the 2017 state law (Public Contract Code 3500 to 3505) that requires facility-specific EPDs and GWP limits for structural steel, rebar, flat glass and insulation on state public works contracts awarded on or after 2022-07-01. DGS sets 7 limits and lowered the rebar limit from 890 to 755 kg CO2e per metric ton on 2025-01-01 (DGS).

What is an EPD?

An environmental product declaration is an independently verified, registered document that reports a product's life-cycle environmental impact, including GWP in kg CO2e. Buy Clean programs compare the EPD's GWP with a limit or simply collect it (California DGS FAQ, NYS guidelines).

Which states have Buy Clean laws?

Nine states as of October 2026: California, Colorado, Minnesota and New York (GWP limits in force), Oregon and Washington (EPD disclosure), Maryland (limits required by statute), New Jersey (tax credits) and Massachusetts (planning).

Do Buy Clean laws apply to private projects?

Generally no: they apply to state-funded projects above thresholds such as $500,000 in Colorado or $1 million in New York. California is the exception through CALGreen, which since 2024-07-01 applies embodied carbon rules to nonresidential projects of 100,000 square feet or more, 50,000 from 2026-01-01 (CALGreen Guide).

What is low embodied carbon concrete?

Concrete whose cradle-to-gate (A1 to A3) emissions are below a set limit. New York's limit for 3001 to 4000 psi concrete is 471 kg CO2e per cubic meter, and Colorado OSA's 4,000 psi limit is 301 (NYS guidelines, OSA). New Jersey defines it as concrete certified to embody lower emissions than the baseline for conventional Portland cement concrete, and grants tax credits for it (P.L.2023, c.4).

Frequently asked questions

How many states have Buy Clean laws in 2026?

Nine states had enacted Buy Clean laws as of 2026-10-18; four of them (California, Colorado, Minnesota, New York) enforce GWP limits.

Which materials do Buy Clean laws cover most often?

Concrete, covered in 8 states, followed by rebar and structural steel in 5 states each; insulation is covered only in California.

When did Minnesota's Buy Clean limits take effect?

Minnesota published limits for ready-mix concrete and rebar in buildings effective 2026-01-15; they apply to projects advertised on or after 2026-07-15 (Minnesota Department of Administration).

What does New York's Buy Clean Concrete rule require?

Since 2025-01-01, concrete on state agency contracts of $1 million or more with at least 50 cubic yards, and DOT contracts of $3 million or more with 200 cubic yards, must have an EPD showing GWP below the state limit, such as 471 kg CO2e per cubic meter for 3001 to 4000 psi (NYS OGS).

Does Washington set GWP limits?

No. Washington requires EPD, health product declaration and supplier data for at least 90% of the cost of covered concrete, steel and engineered wood, starting 2025-07-01 for projects over 100,000 gross square feet (final bill report).

What is the Colorado Buy Clean threshold?

Colorado OSA rules apply to state public projects above $500,000 solicited on or after 2024-01-01; CDOT limits apply to projects advertised on or after 2025-07-01 (OSA, CDOT).

Is the federal Buy Clean Initiative still in effect?

Executive Order 14057, which created it, was revoked by Executive Order 14148 on 2025-01-20 (Federal Register).

What happened to GSA's low embodied carbon requirements?

Public Law 119-21 rescinded unobligated balances of the $2.15 billion IRA Section 60503 appropriation on 2025-07-04, and GSA's requirements page returned HTTP 404 on 2026-10-18 (Pub. L. 119-21).

How much did the IRA provide for low-carbon construction materials?

$4.5 billion across four sections: $2.15 billion (GSA), $2 billion (FHWA grants), $250 million (EPA EPD grants) and $100 million (EPA labels). Unobligated balances of all four were rescinded on 2025-07-04.

What share of Americans live in states with Buy Clean GWP limits?

20.8%, or 71.2 million of 341.8 million residents on July 1, 2025 (Census Vintage 2025).

Download the data

Every table in this report is available as a CSV under CC BY 4.0. The fact sheet lists each value with its source URL and access date.

For journalists and researchers

If you cite only a few, cite these

  1. 9 states with enacted Buy Clean laws; 4 with GWP limits in force (October 2026).[38][1][6][15][18]
  2. 4,000 psi concrete ceilings range from 301 (Colorado) to 566 (CALGreen) kg CO2e per cubic meter.[6][3]
  3. Federal Buy Clean order revoked 2025-01-20; $4.5 billion in IRA appropriations had unobligated balances rescinded on 2025-07-04.[27][28][29]

Most quotable statistics

  • Nine US states had enacted Buy Clean laws for construction materials as of October 2026, but only four (California, Colorado, Minnesota and New York) enforce GWP limits.[38][1][6][15][18]
  • Colorado caps 4,000 psi ready-mix concrete on state projects at 301 kg CO2e per cubic meter for 2026; California's CALGreen ceiling for a similar band is 566.[6][3]
  • California lowered its Buy Clean rebar limit by 15.2%, from 890 to 755 kg CO2e per metric ton, on 2025-01-01.[1]
  • Concrete is covered by Buy Clean rules in 8 states; insulation in only 1, California (October 2026).[1][5][18]
  • 20.8% of US residents, 71.2 million people, live in a state with Buy Clean GWP limits in force (Census Vintage 2025).[37]
  • Public Law 119-21 rescinded unobligated balances of four IRA embodied carbon programs worth $4.5 billion in appropriations on 2025-07-04.[28][29]

Press summary

Nine US states have enacted Buy Clean laws that target the embodied carbon of construction materials on public projects, according to a CB&C registry checked on 2026-10-18. Four states, California, Colorado, Minnesota and New York, enforce global warming potential limits; Oregon and Washington require environmental product declarations without ceilings; Maryland's statute orders limits that were not yet located on an official page; New Jersey offers tax credits; Massachusetts has a planning law. Concrete is covered in 8 states, rebar and structural steel in 5. Limits for the same material differ: 4,000 psi ready-mix is capped at 301 kg CO2e per cubic meter in Colorado and 566 under California's CALGreen code, which also reaches private buildings. At the federal level, Executive Order 14057 was revoked on 2025-01-20 and Public Law 119-21 rescinded unobligated balances of four IRA programs with $4.5 billion in appropriations on 2025-07-04. The four limit states hold 20.8% of the US population.

Suggested headlines

  • Nine states now have Buy Clean laws; only four cap embodied carbon
  • Same concrete, different verdict: state carbon ceilings range from 301 to 566
  • California tightens Buy Clean rebar limit by 15.2%
  • Buy Clean goes local as federal program is unwound in 2025
  • One in five Americans lives in a state with construction carbon limits

How to cite this report

Commercial Builders & Contractors. (2026). Buy Clean laws by state: embodied carbon rules for concrete, steel and glass (2026). Retrieved from https://commercialbuildersandcontractors.com/buy-clean-laws-by-state/

Reuse license

Data and tables are licensed CC BY 4.0. Attribution: “Source: Commercial Builders & Contractors, Buy Clean laws by state: embodied carbon rules for concrete, steel and glass (2026)” with a link to this page.

Methodology

Scope: state laws and agency rules that require EPDs, set GWP limits, or fund or plan embodied carbon reductions for construction materials on public projects, plus California's CALGreen building-code rule and federal programs. Local ordinances (for example city codes) are out of scope.

Source selection: statute text, session laws, bill histories and agency pages were opened on 2026-10-18 and saved in raw/. Removed federal pages are cited from the EPA 2025-01-19 snapshot site or Internet Archive copies, labelled as such. Tier 2 trackers (State Climate Policy Dashboard, BlueGreen Alliance, AISC) were used to find candidate states; every enacted state was confirmed on a primary source.

Classification: each state is placed by its strongest requirement in force on 2026-10-18. Maryland is classed 'limits pending' because its statute requires limits by 2026-01-01 but CB&C did not locate published limits; New Mexico's 2026 veto rests on an AISC statement because the official bill page did not render.

Conflicting information: where trackers and primary sources differed (for example AISC listing New Mexico as passed while also reporting a veto), the primary source or the more specific statement was used and the conflict noted in excluded.md.

Derived metrics: population shares use Census Vintage 2025 July 1, 2025 estimates; limit comparisons use the published limit in each program's own units. All calculations are in derived_metrics.csv and scripts/.

Limitations: limit comparisons mix strength bands, LCA scopes and regional baselines; population shares measure state reach, not project coverage; agency implementation (waivers, exemptions, project counts) is not measured.

Last updated 2026-10-18. The registry is re-checked quarterly.

This report presents published data with its limitations. It is not legal, financial or investment advice.

Sources, ranked by quality

Tier 1: primary and official sources (37)

Tier 2: trade bodies, market research, company data (3)

Tier 3: journalism and expert commentary (1)