Buy Clean Initiatives & Steel – mid-2025 updates:

Jurisdiction Coverage of Steel Requirements Timeline/Status
California (BCCA) Structural steel (hot-rolled sections, plate, HSS) and reinforcing steel Facility-specific EPDs required; maximum GWP limits set and periodically updated by CA Dept. of General Services Active since 2021; GWP thresholds enforced and under periodic review
Colorado (BCCO) Steel, concrete, glass, asphalt EPDs required for public projects; no binding GWP caps yet Enacted (2021); agencies currently collecting steel EPDs
Oregon Includes steel in lifecycle assessments for infrastructure materials Requires LCAs/EPDs for covered materials; working toward benchmarks Enacted (2022); early implementation, data gathering stage
Washington (Buy Clean, Buy Fair Act) Steel, concrete, and wood in state-owned buildings Embodied carbon reporting; state database to track EPDs; eventual procurement guidance linked to reporting Enacted (2024); reporting tools and rules under development
Maryland (Buy Clean Maryland Act) Steel not covered(concrete only) Cement/concrete only; framework could expand to steel later Enacted (2023); concrete GWP limits due by 2026
Minnesota (Buy Clean, Buy Fair Act) Steel explicitly within scope Task Force to set procurement standards; EPDs and possible GWP limits under discussion Enacted (2023); Task Force active, rules not finalized
Federal – GSA Structural steel and rebar for federal building projects Requires EPDs and compliance with low-embodied carbon procurement standards (dual standard with interim GWP benchmarks) Active since 2023; enforceable in federal procurement
Federal – FHWA Steel in highways/bridges (guardrails, rebar, etc.) Buy Clean rule proposed but on hold; would require EPDs and GWP thresholds Pending; uncertain timeline

Takeaway:

  • California → only state with enforceable steel GWP limits today.
  • Colorado, Oregon, Washington, Minnesota → steel covered, but rules
    are transparency / reporting only (for now).
  • Maryland → concrete only (no steel yet).
  • Federal (GSA) → active steel requirements in place, however, we’ve not had feedback
    from our initial contacts regarding status; FHWA stalled.
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