On a growing share of public construction work, the carbon declaration attached to a concrete mix or a rebar shipment decides whether the material can be installed. Procurement teams preparing 2027 bids need to settle that paperwork before they settle on a supplier. A mix can meet every strength requirement in the specification and still be turned away on a covered state contract if its documentation is the wrong kind.

The document in question is an environmental product declaration (EPD). California’s Department of General Services (DGS) Buy Clean guidance describes it as an independently verified and registered report of a product’s environmental impact over its life cycle. An EPD only reports a number. Whether that number is acceptable depends on a separate global warming potential (GWP) limit set by the buyer, so holding a declaration and passing a procurement test are two different questions for a supplier.

New York Is Preparing Lower Concrete Limits for 2027

The nearest deadline is in Albany. Under State Finance Law Section 136-d, the Office of General Services (OGS) made its concrete GWP limits mandatory on January 1, 2025. Its Buy Clean Concrete Guidelines state that the limits will be revised downward starting January 1, 2027, or within six months of that date, provided enough data is available for analysis. No new values have been published. Any bid priced this winter is being built against a threshold that may change before the concrete is poured.

The current limits are tiered by specified compressive strength. The ceiling starts at 275 kilograms of carbon dioxide equivalent (kg CO2e) per cubic yard for mixes up to 2,500 pounds per square inch (psi). It climbs to 541 kg CO2e per cubic yard for mixes between 6,001 and 8,000 psi. The OGS program page explains that these values sit at 150% of the Eastern Region averages in a 2022 life cycle assessment (LCA) by the National Ready Mixed Concrete Association. The same page says the 2027 revision will draw on New York-specific data gathered through Executive Order 22 reporting.

Coverage is narrower than it may sound. The guidelines reach state agency building contracts of at least $1 million that use at least 50 cubic yards of concrete. On the transportation side, they cover Department of Transportation contracts of at least $3 million with a concrete pay item of at least 200 cubic yards. Acceptable declarations can be product-specific, plant-specific or supply-chain-specific, as long as they are third-party reviewed. A waiver exists when compliant concrete cannot feasibly be sourced, though it requires documented justification.

Three States Use One Document Three Different Ways

California built its program around steel, glass and insulation. The Buy Clean California Act covers structural steel, concrete reinforcing steel, flat glass and insulation, and ready-mixed concrete is not on the list. Its current limits took effect January 1, 2025. Reinforcing steel now carries a ceiling of 755 kg CO2e per metric ton, down from 890 in the table that took effect in 2022, and the next update is scheduled for January 1, 2028. DGS reviews the limits every three years and can only move them lower.

The California test is also stricter about where a number comes from. A declaration qualifies only if it covers a single manufacturer and a single facility, or if a companywide EPD breaks out GWP for each plant. For projects run by the state’s Real Estate Services Division (RESD), the contractor requirements say facility-specific EPDs must be reviewed before material is accepted for installation. Install early and payment can be withheld, with the contractor liable for removal costs.

Washington sits at the opposite end. Its Buy Clean and Buy Fair law, signed in March 2024, covers new state agency and higher education buildings over 50,000 square feet. Those projects have reported EPDs for concrete, wood and steel since July 2025. A January 2026 report to the Legislature from the state Department of Commerce confirms the law sets no reduction mandate. The report floats GWP limits as a possible expansion and notes that Commerce may update reporting standards by January 2027.

Put side by side, the programs treat one file very unevenly. A companywide average EPD could satisfy Washington’s disclosure rule. New York wants a declaration specific to the product, plant or supply chain, and California rejects the average outright unless each facility is reported separately. Suppliers working across all three markets need a requirements matrix tied to individual contracts, because a file accepted in one state proves little in the next.

A Lower Carbon Number Only Holds Up in a Fair Comparison

Carbon intensity tells a buyer something useful only when the products being compared do the same job. New York ties each limit to a strength class, so a 3,000 psi slab mix and a 6,000 psi structural mix are measured against different ceilings. California’s steel limits apply to unfabricated product from raw material extraction through the factory gate. A declaration drawn on another boundary, or for a product doing another job, can make one option look better without making the building any better.

Whole-project accounting is the next layer. In June 2026, New York’s GreenNY Embodied Carbon Working Group launched a whole building and infrastructure LCA pilot so state agencies could test a methodology developed in 2025. OGS says feedback from the pilot will shape future LCA guidance. That work could eventually shift attention from individual material declarations to the total embodied carbon of a project, including transport and construction equipment.

The cost of producing declarations deserves a fair hearing too. Washington’s report notes that a $3.5 million federal Environmental Protection Agency grant for EPD development was eliminated in early 2025. State lawmakers also have not funded the EPD assistance for small manufacturers written into the law. Smaller producers may struggle to document every plant at once. Buyers who want competition on public jobs should expect that gap to narrow the field of qualified bidders.

Where Procurement Teams Can Get Ahead

The workable fix is to move the declaration question to the front of sourcing. Requests for quotation can name the declaration type each program accepts, the limit a product must meet and the party responsible for securing approval. Supplier qualification can confirm that an EPD matches the actual plant and mix proposed, which is the same verification discipline buyers increasingly apply when testing sustainability claims they cannot yet prove.

Substitutions need their own process. A change of plant or concrete mix can trigger a new review even when the replacement meets every engineering specification, and a swap made late in the job leaves little time for that review. Teams already working through specifying circular building materials will recognize the pattern, since product evidence has to travel with the material through every change order.

Manufacturers face a sequencing choice about which facilities to declare first. Producers adding capacity, such as the recent expansion of low-carbon cement supply in Indiana, have an opening to put plant-level data in front of public buyers early. Steelmakers have a separate puzzle, because the certificate-based approaches discussed in green steel book-and-claim debates work on another logic than California’s requirement that the figure belong to a physical facility.

Questions Still Open Before the 2027 Bid Cycle

New York has not said what its lower limits will be or whether the revision will land in January or slip toward mid-2027. Washington’s Commerce Department owed lawmakers a second report in September 2026 carrying recommendations from its technical work group. Whether the Legislature turns disclosure into limits will matter for every supplier now filing there.

California’s 2028 update will add new insulation limits and could tighten steel again, since DGS can only move its numbers down. Buyers collecting facility-level declarations now will have their own baseline for judging those changes. For steel suppliers, the unanswered question is how much room the 2028 limits will leave for plants that still lack a facility-level declaration.