A quiet revolution is underway in the way the federal government buys concrete, steel, and asphalt. Since 2022, the Inflation Reduction Act has been channeling $4.15 billion through the General Services Administration and the Federal Highway Administration—specifically to purchase construction materials with substantially lower embodied carbon. For contractors, ready-mix producers, steel fabricators, and asphalt manufacturers, this federal buying power has transformed what was once a niche sustainability preference into an active commercial requirement on hundreds of government construction projects.

The program is called Buy Clean, and understanding how it works—and how it is evolving—is becoming essential for any construction firm working on federal buildings, highways, or infrastructure projects.

The IRA's Construction Materials Mandate

The Inflation Reduction Act of 2022 directed three distinct pools of funding to reduce embodied carbon in federally funded construction. The General Services Administration received $2.15 billion to procure substantially lower embodied carbon (LEC) materials for federal building and paving projects across more than 150 projects in 32 states. The Federal Highway Administration received $2 billion to reimburse state and local DOTs for the incremental cost of procuring low-carbon construction materials—concrete/cement, glass, asphalt mix, and steel—in transportation projects. The Environmental Protection Agency received $250 million for grants and technical assistance to help manufacturers develop Environmental Product Declarations (EPDs) and improve embodied carbon measurement across the industry.

To be eligible for any of these programs, materials must meet EPA's determination of "substantially lower" embodied carbon—defined as performance in the best 20th percentile of greenhouse gas emissions compared to similar materials. If materials in the top 20% are unavailable in a project location, a 40th percentile standard applies. If 40th percentile materials are also unavailable, materials must at minimum beat the estimated industry average. This tiered availability approach was developed after advocacy from the Associated General Contractors and other construction industry organizations, according to the Carbon Leadership Forum.

Environmental Product Declarations: The New Compliance Currency

The mechanism for demonstrating compliance is the Environmental Product Declaration (EPD)—a standardized, third-party-verified document that quantifies the greenhouse gas emissions associated with producing a specific material. For GSA projects, contractors must submit a product-specific Type III EPD at the time of bid. There is no waiver process for the EPD requirement itself, according to the Carbon Leadership Forum.

In response to the federal demand, EPA awarded approximately $160 million in grants to 38 different organizations in 2024, covering 14 material types across five project categories—all aimed at improving EPD availability and quality for the U.S. construction sector. Of that total, $42.5 million went directly to the concrete sector to support EPD development and improve product category rules, according to an EPA program update. Additionally, the Department of Defense wrote an updated specification referencing EPA's labeling program, expanding federal procurement reach beyond GSA and FHWA.

EPA is also developing a formal labeling system that will designate products as "good," "better," or "best" based on their embodied carbon performance relative to threshold levels. This label, once implemented, is expected to create a publicly accessible online registry that federal procurement officers, state DOTs, and private owners can use to identify and specify low-carbon materials more easily, according to BuildingGreen.

What This Means for Concrete Producers and Contractors

The practical implication for ready-mix concrete producers is significant. GSA's standard requires EPDs and sets specific global warming potential (GWP) limits for concrete by compressive strength class. GSA considers all bids within 20% of the GWP limit; if none qualify, it considers all bids within 40% of the limits; if none qualify, it accepts better-than-average bids. This tiered system means that producers who invest in EPDs and optimize their mixes for lower carbon content are positioned to compete more effectively for a growing segment of the federal market.

For contractors working on Federal Highway Administration projects, the picture is similar: $2 billion in reimbursements is available to state and local DOTs that procure low-carbon concrete/cement, asphalt, glass, and steel. State DOTs that apply receive reimbursement for the cost premium of using lower-carbon materials—meaning the financial risk of low-carbon procurement shifts from the contractor to the federal program.

The GSA program alone covers more than 150 projects across 32 states. For concrete, 118 of those projects had concrete listed in the materials list as of mid-2024, according to the Carbon Leadership Forum. That represents a substantial and growing segment of federal construction activity where EPD compliance is a baseline requirement.

The Broader Market Signal

Federal buying power rarely stays contained within federal projects. When the government sets procurement standards—whether for fuel efficiency, accessibility, or now embodied carbon—those standards tend to migrate into state government procurement, institutional owner specifications, and eventually private development as awareness and supplier capability grow.

The Energy Futures Initiative's March 2026 report on low-carbon concrete found that several states in the Northeast have already begun adopting their own low-carbon procurement requirements for state-funded transportation projects, building on the federal framework. As the EPD database grows and the industry develops standardized mix designs that consistently meet lower-carbon thresholds, the cost premium of low-carbon concrete is expected to narrow—making compliance progressively less expensive for contractors and producers.

For construction firms, the near-term priority is straightforward: understand which federal projects are subject to Buy Clean requirements, ensure that ready-mix and material suppliers have valid EPDs for specified mixes, and develop internal tracking systems that can document compliance at bid time. The EPA's technical assistance program offers free EPD advisory services to manufacturers, a resource that suppliers to federal projects should be leveraging now.

Sources

Carbon Leadership Forum — GSA Low Carbon Materials Funding
U.S. EPA — Nearly $160 Million in Grants to Support Clean U.S. Construction Materials (July 16, 2024)
BuildingGreen — IRA Accelerates Low-Carbon Building Products (September 17, 2024)
SmartBrief — What the Federal Push for Low-Carbon Construction Means for Contractors (December 2023)
Energy Futures Initiative Foundation — Building Demand for Low-Carbon Concrete in the Northeastern United States (March 2026)
U.S. EPA — Technical Documents for Cleaner Construction Materials (December 19, 2024)
U.S. General Services Administration — GSA Low Embodied Carbon Concrete and Asphalt Standards (March 30, 2022)