The Buy Clean California Act, (Public Contract Code § 3500-3505), states the Department of General Services (DGS) is required to establish and publish the maximum acceptable Global Warming Potential (GWP). Its targets embedded carbon emissions of structural steel (hot-rolled sections, hollow structural sections, and plate), concrete reinforcing steel, flat glass, and mineral wool board insulation. These materials must have a GWP that does not exceed the limit set by DGS.


Find key legislation dates below.


January 1, 2020 – Awarding authorities will require submission of a Environmental Product Declaration (EPD).

January 1, 2021 DGS will publish the maximum acceptable GWP for eligible materials.

July 1, 2021 – Awarding authorities will gauge GWP compliance of eligible materials with EPDs.


EPD submissions shall be developed according to the Product Category Rules (PCRs) found in the resources section below.


  • DGS released Management Memo MM 20-01 directing awarding authorities to require the submission of EPDs between January 1, 2020 through December 31, 2020.
  • Take a look at the revised frequently asked questions section below which, provides more information to Buy Clean California Act (BCCA) stakeholders.
  • Below are the California cities that are now supporting the BCCA through the following resolutions and executive directives:

November 6, 2019

DGS participated in a teleconference with the North American Insulation Manufacturers Association.


November 6, 2019

DGS participated in a teleconference with Sierra Club.


October 31, 2019

DGS conducted a second External Stakeholder Meeting.


October 23, 2019

DGS participated in a teleconference with UL Environment.


October 16, 2019

DGS participated in a teleconference with SCS Global.


October 9, 2019

DGS participated in a teleconference with Oregon Department of Environmental Quality.


September 27, 2019

DGS participated in a teleconference with UL Environment.


September 25, 2019

DGS conducted a follow-up Awarding Agency workshop.


August 6, 2019

DGS participated in a teleconference with California Department of Transportation.


July 23, 2019

DGS participated in a teleconference with the Concrete Reinforcing Steel Institute.


July 17, 2019

DGS participated in a teleconference with the American Institute of Steel Construction.


June 10, 2019

DGS participated in a teleconference with the American Center for Life Cycle Assessment.


DGS expects to continue engaging with internal and external stakeholders as we implement BCCA.

1.0 Environmental Product Declarations:

1.1 What is an Environmental Product Declaration, or EPD?

An Environmental Product Declaration (EPD) is an independently verified and registered document that reports a product’s environmental impact over its life cycle.

1.2 How do I obtain an EPD?

Contact a program operator to begin the EPD development process. A manufacturer will need to conduct a product life cycle assessment and utilize a program operator to verify and publish an EPD.

1.3 Where can I find a program operator?

You can find program operators at the Program Operator Consortium website.

1.4 What environmental impact category does the Buy Clean California Act use as a metric?

The Buy Clean California Act (BCCA) uses Global Warming Potential (GWP), which is reported as CO2 eq.

1.5 What is Global Warming Potential, or GWP?

Greenhouse gases (GHGs) are those that trap heat in the earth’s atmosphere. Carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), and perfluorocarbons (PFCs) are types of GHGs. While all GHGs have the effect of trapping heat, each gas has a different amount of impact. The various GHGs produced when manufacturing a product, for example, can be represented by an equivalent amount of carbon dioxide associated with the warming effect of a given quantity of a GHG. This amount is labeled carbon dioxide equivalent, or CO2 eq.

2.0 Eligible Materials:

2.1 What construction materials are affected?

Structural steel, concrete reinforcing steel, flat glass and mineral wool board insulation. Details are shown in Table 1.

Table 1: Description of eligible materials

Eligible material


Structural steel

Hot-rolled sections consisting of wide flange beams (W-shape), standard beams (S-shape), misc. beams (M-shape), channels, angles, tees, bearing piles.

Hollow structural sections with round, square, or rectangular cross-section.

Plate material.

Concrete reinforcing steel

Carbon steel bars per ASTM A615/A615M and low-alloy steel bars per ASTM A706/A706M. Coated concrete steel reinforcing bars are currently excluded.

Flat glass

Float or rolled glass that is clear or tinted.

Mineral wool board insulation

Board insulation made of rock or slag in light and heavy density categories.

2.2 Will any other construction materials be added to the BCCA?
It is likely that other materials will be added in the future.

3.0 Affected Entities:

3.1 Which state agencies have to comply with the BCCA?

The awarding authorities include: Department of Transportation, Department of Water Resources, Department of Parks and Recreation, Department of Corrections and Rehabilitation, Military Department, Department of General Services, Regents of the University of California, Trustees of the California State University and state agencies granted authority to work on public works projects under Management Memo 18-01.

4.0 GWP Limit:

4.1 Who is responsible for setting the GWP limit?

The Department of General Services (DGS), Procurement Division, Engineering Branch.

4.2 How many limits will DGS establish?

There will be seven limits established for compliance by January 1, 2021:

  • Three for structural steel (one each for hot-rolled sections, hollow structural sections, and plate)
  • One for concrete reinforcing steel
  • One for flat glass
  • Two for mineral wool board insulation (one each for light and heavy density types)

4.3 Where will DGS obtain the data to establish the GWP limit?

DGS will obtain the data from publicly available EPDs.

4.4 How will the GWP limit be determined?

The legislation requires the limit to be set at the industry average of facility-specific GWP for the material. Prior to the required publication date, DGS will assess the data collected to date to determine the average.

Since EPDs have a level of uncertainty in the reported GWP, DGS will add a tolerance to the baseline average to establish the GWP limit.

4.5 Will DGS exclude the GWP contribution from material fabricators when establishing the GWP limit?

Yes. For the four material types identified in the BCCA, the majority of GWP production is attributed to the manufacturer of the material rather than the fabricator. Therefore, the GWP limit will be based on manufacturer’s impacts.

For example, a steel mill consumes much more energy to melt iron ore (or steel scrap) and forming it into a steel beam than a typical fabricator whose operations would consist of welding, drilling, or finishing. GWP production is directly proportional to energy use.

4.6 Once the GWP limit is established, will it ever be changed?

Beginning January 1, 2024, and every three years thereafter, DGS will review the maximum acceptable GWP for each material and may adjust the limit downward* to reflect industry improvements.

* The BCCA legislation prohibits DGS from adjusting the limit upward.

4.7 Where and when will the GWP limit be published?

The GWP limits will be published on the BCCA webpage by January 1, 2021.

5.0 Compliance:

5.1 Who needs to submit EPDs to state agencies?

The successful bidder for a public works project must submit eligible material EPDs to the state agency awarding the contract.

5.2 Is there a particular type of EPD that must be submitted?

An EPD must meet certain requirements before an awarding agency can determine material compliance.

An EPD must:

  • Be a facility-specific manufacturer EPD
  • Be independently verified in accordance with ISO 14025 (Type III environmental declarations – Principles and procedures)
  • Be developed according to the guidelines of the applicable Product Category Rule (PCR) as identified by DGS
  • Have a validity date that has not expired
  • Represent an eligible material (as described in Table 1, Section 2.0)

An EPD must not:

  • Be an industry-wide/industry-average EPD
  • Be a fabricator’s EPD
  • Report the average GWP from multiple manufacturing facilities

5.3 What is a facility-specific manufacturer EPD?

A facility-specific manufacturer EPD is a product EPD in which the environmental impacts can be attributed to a single manufacturer and manufacturing facility.

5.4 What’s the difference between a manufacturer, a producer, and a fabricator?

With respect to the BCCA, a manufacturer is the entity that produces the basic construction material that typically requires additional processing by fabricators before use in a construction project.

Consider rebar for example, a steel mill who melts steel and forms it into rebar would be viewed as a manufacturer whereas a facility that turns straight lengths of rebar into shapes, bends, or welds rebar would be considered a fabricator.

The term “manufacturer” and “producer” is used interchangeably by the BCCA implementation team.

5.5 What is a Product Category Rule, or PCR?

A PCR is a set of rules, requirements and guidelines used to develop an EPD for a product group.

5.6 Where can I find the PCR that pertains to the eligible materials identified in the BCCA?

The current PCRs are located in the References and Resources section of the Buy Clean California Act webpage.

5.7 When do EPDs need to be submitted to state agencies during the bid cycle?

Contact the state agency conducting the solicitation for specific requirements.

5.8 How long is my EPD valid?

The expiration date is determined by the program operator and identified within the EPD. An expired EPD will not be accepted for compliance.

Program Operator Consortium (POC) develops PCRs, reviews and verifies EPDs, reports Life Cycle Assessment (LCA), and publishes customized Type III environmental declaration formats in accordance with the International Standard ISO 14025.


Find PCRs and EPDs on their website

UL Environment develops PCRs and verifies EPDs alongside the POC.

Find PCRs that are under development or may not be covered by the POC.
EPDs in the UL SPOT database. Once there, enter the product name, look for certifications, then EPDs.


Reference PCRs for eligible materials:

Structural steel and concrete reinforcing steel
Title: North American Product Category Rule for Designated Steel Construction Products
Valid through: May 5, 2020
Version: 1.0
Program operator: SCS Global Services


Flat glass
Title: GANA PCR for Flat Glass: UN CPC 3711
Valid through: September 30, 2020 (extended per PCRext 2020-105)

Program operator: NSF International


Mineral wool board insulation
Title: Part B: Building Envelope Thermal Insulation EPD requirements
Valid through: April 10, 2023
Version: 2.0
Program operator: UL Environment

External Outreach Materials


October 31, 2019

DGS held a second external stakeholder meeting. Presentation slides are available at the link below:

External Stakeholder Meeting Slides


June 26, 2018

DGS held its first external stakeholder meeting. Comment period responses are available at the link below: 

DGS Response Summary

If you would like a copy of all industry comments, please send a request via email to


Engineering Branch

Department of General Services
Procurement Divsion

707 Third Street, Second Floor
West Sacramento, California 95605

To ensure that your questions receive accurate and timely responses, please provide your name, phone number, and agency/organization name.