A 2025 Guide for Construction Professionals
For LEED professionals and general contractors, understanding the difference between embodied carbon and carbon offsets has become increasingly crucial, especially with recent regulatory changes. Let’s break down these concepts and explore their implications for the construction industry while examining emerging technologies and practices that are reshaping how we approach carbon management in construction.
What is Embodied Carbon?
Embodied carbon refers to the total greenhouse gas emissions generated during the manufacturing, transportation, installation, and disposal of building materials. Think of it as the carbon footprint of your building materials from cradle to grave. This includes everything from the energy used to extract raw materials to the emissions from trucks delivering materials to your construction site.
For example, when you use concrete in construction, its embodied carbon includes:
- Emissions from limestone extraction
- Energy used in cement production
- Transportation of materials to the mixing plant
- Delivery to the construction site
- Future demolition and disposal
The Impact of Material Choices
Different building materials carry vastly different embodied carbon loads. Traditional Portland cement, for instance, accounts for approximately 8% of global CO2 emissions. However, innovative alternatives like low-carbon concrete blends can reduce embodied carbon by up to 50%. Steel production similarly contributes significantly to global emissions, but recycled steel and emerging green steel technologies offer promising alternatives.
Understanding Carbon Offsets
Carbon offsets, on the other hand, are investments in environmental projects that reduce greenhouse gas emissions to compensate for emissions elsewhere. These might include funding renewable energy projects, forest conservation, or methane capture programs. While offsets don’t reduce your project’s direct carbon footprint, they help balance out its environmental impact.
Quality of Carbon Offsets
Not all carbon offsets are created equal. High-quality offsets should be:
- Verifiable by third-party organizations
- Additional (representing emissions reductions that wouldn’t have happened otherwise)
- Permanent (ensuring long-term carbon reduction)
- Socially responsible and beneficial to local communities
Key 2025 Regulatory Updates
As of early 2025, several important regulations have been implemented that affect how general contractors must approach embodied carbon:
- Federal Buy Clean Initiative: Contractors working on federal projects are now required to provide Environmental Product Declarations (EPDs) for key materials, including concrete, steel, glass, and aluminum. This regulation aims to create transparency in material sourcing and encourage the use of lower-carbon alternatives. (Federal Buy Clean)
- State-Level Programs: Various states have introduced mandatory reporting requirements for embodied carbon in new construction projects over 50,000 square feet. For example, New York’s Executive Order 22 mandates that contractors submit EPDs and disclose material quantities for commonly used construction materials. (ogs.ny.gov)
These regulations underscore the growing emphasis on reducing embodied carbon in the construction industry, necessitating that general contractors stay informed and compliant with both federal and state-level requirements. You can take advantage of Green Badger’s previous blog post on Uncovering Embodied Carbon in EPDs to learn how to find this information on an EPD.
Regional Variations in Requirements
In the United States, approaches to regulating embodied carbon in construction vary significantly across regions, reflecting diverse priorities and strategies. Here’s an overview of these regional variations:
West Coast States: Stringent Requirements
West Coast states, particularly California, have implemented some of the nation’s strictest embodied carbon regulations. As of July 1, 2024, California mandates that all commercial buildings over 100,000 square feet disclose and improve their embodied carbon metrics. This regulation requires project teams to assess and report the embodied carbon of their building materials, encouraging the selection of low-carbon alternatives. (rmi.o)
Midwest States: Incentive Programs
In the Midwest, states are increasingly adopting incentive-based approaches to encourage the reduction of embodied carbon. For instance, Minnesota has introduced programs that offer financial incentives projects demonstrating significant reductions in embodied carbon through the use of sustainable materials and construction practice. These initiatives aim to motivate builders and developers to prioritize low-carbon materials without imposing mandatory requirements. (Minnesota Climate Action Framework)
Northeast States: Gradual Phase-In Periods
Northeastern states are implementing gradual phase-in periods for embodied carbon regulations, allowing the construction industry time to adapt. New York, for example, has enacted the Low Embodied Carbon Concrete Leadership Act (LECCLA), which requires state-funded projects to procure low-embodied carbon concrete. This legislation is being introduced in stages, providing contractors and suppliers time to develop and source compliant materials. (netl.doe.gov)
Southern States: Voluntary Programs with Future Mandatory Plans
Southern states are currently focusing on voluntary programs aimed at reducing embodied carbon, with plans to transition to mandatory regulations in the future. These voluntary initiatives encourage builders to adopt sustainable practices and report embodied carbon metrics, serving as a preparatory phase before the implementation of compulsory standards. This approach allows the industry to gradually adjust to new expectations and develop the necessary infrastructure for compliance.
Practical Implications for General Contractors
To comply with current regulations and meet LEED requirements, contractors should address:
- Material Selection and Documentation: Maintain detailed records of material sources and their associated EPDs. This documentation is crucial for both regulatory compliance and LEED certification.
- Supply Chain Management: Develop relationships with suppliers who can provide low-carbon materials and proper documentation. Consider local sourcing to reduce transportation emissions.
- Project Planning: Include carbon assessment in the early planning stages. This allows for strategic decisions about material choices and construction methods that can significantly reduce embodied carbon.
Digital Tools and Technology
The construction industry is increasingly adopting digital tools to track and manage carbon emissions:
- Building Information Modeling (BIM) with carbon tracking capabilities
- Green Badger ESG software for automated environmental tracking, LEED documentation, and real-time carbon footprint monitoring across construction projects
- Automated reporting systems for regulatory compliance
This digital transformation is making it easier for contractors to track, report, and optimize their environmental impact while maintaining compliance with evolving regulations. Green Badger’s platform specifically helps streamline the often complex process of ESG reporting and LEED documentation, saving valuable time while ensuring accuracy in environmental impact calculations.
Balancing Embodied Carbon and Offsets
While carbon offsets can play a role in achieving sustainability goals, the construction industry is increasingly focusing on reducing embodied carbon first. This approach, known as the “reduce then offset” strategy, prioritizes:
- Choosing materials with lower embodied carbon
- Optimizing construction methods to reduce waste
- Using local suppliers when possible
- Implementing effective waste management strategies
- Using carbon offsets only for unavoidable emissions
Cost Considerations
While low-carbon alternatives often come with higher upfront costs, many contractors are finding that:
- Long-term operational savings often justify initial investments
- Green building certifications can command premium rents
- Tax incentives and grants can offset additional expenses
- Market demand for sustainable buildings continues to grow
Looking Forward
The construction industry is experiencing a significant shift toward carbon accountability. As regulations continue to evolve, contractors who proactively address embodied carbon issues will have a competitive advantage. Many clients now expect contractors to demonstrate carbon literacy and have concrete strategies for reducing environmental impact.
Emerging Trends
Several emerging trends are shaping the future of carbon management in construction:
- Increased use of mass timber and bio-based materials (Green Badger ebook)
- Development of carbon-negative concrete alternatives
- Integration of circular economy principles in material selection
- Advanced prefabrication techniques to reduce waste and emissions
Practical Steps for Implementation
To stay ahead of regulatory requirements and meet client expectations, consider these actions:
- Invest in training for project managers and estimators on carbon accounting and documentation.
- Develop partnerships with suppliers who can provide low-carbon alternatives and proper documentation.
- Implement tracking systems for material sourcing and carbon impacts.
- Consider hiring sustainability consultants for larger projects.
- Stay informed about upcoming regulatory changes and industry best practices.
Conclusion
Remember, while carbon offsets can be part of your sustainability strategy, the primary focus should be on reducing embodied carbon through smart material choices and efficient construction practices. This approach not only ensures regulatory compliance but also positions your company as a leader in sustainable construction.
By understanding and effectively managing both embodied carbon and carbon offsets, construction professionals can better navigate the evolving regulatory landscape while contributing to a more sustainable built environment. The key to success lies in staying informed, being proactive, and maintaining a balanced approach to carbon management that considers both immediate project needs and long-term sustainability goals.
