# Buy Clean California - GWP Limits Published **URL:** \ **Category:** Policy\ **Tags:** legislation, steel, glass, insulation, rebar\ **Created:** [January 12, 2021, 12:05pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763 "2021-01-12T12:05:55Z")\ **Posts on this page:** 15\ **Page:** 1
**Author:** ![ryanzizzo](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/ryanzizzo/32/2343_2.png) [@ryanzizzo](https://community.carbonleadershipforum.org/u/ryanzizzo)\ **Post date:** [January 12, 2021, 12:05pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/1 "2021-01-12T12:05:55Z")
After several years of phasing in Buy Clean California, the GWP limits that will come into effect on July 1 2021 [have been published](https://www.dgs.ca.gov/PD/Resources/Page-Content/Procurement-Division-Resources-List-Folder/Buy-Clean-California-Act)! These limits are for: - structural steel (hot-rolled sections, hollow structural sections, and plate) - concrete reinforcing steel, - flat glass, and - mineral wool board insulation. ![Capture](https://us1.discourse-cdn.com/flex015/uploads/carbonleadershipforum/original/1X/7138881a77d015349195566e5dd295be6ca705ea.png) ---
**Author:** ![afeitel](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/afeitel/32/827_2.png) [@afeitel](https://community.carbonleadershipforum.org/u/afeitel)\ **Post date:** [January 12, 2021, 3:56pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/2 "2021-01-12T15:56:42Z")
I am new to the legislation aspect of embodied carbon! Is there a reason why concrete mix designs are not included in this Act? ---
**Author:** ![ryanzizzo](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/ryanzizzo/32/2343_2.png) [@ryanzizzo](https://community.carbonleadershipforum.org/u/ryanzizzo)\ **Post date:** [January 13, 2021, 9:26am UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/3 "2021-01-13T09:26:25Z")
Hi Alexis. Originally cement was targetted for inclusion, but industry pushed back making the argument that the product is ‘trade-exposed’ meaning that purchasers could easily change to buying lower-carbon imported cement only and the local California-based cement industry could collapse. The validity of the argument, and if it’s applicable to other included materials too, can be challenged. However, their argument won the day and it was excluded from this initial version of the Act. The state has said that they intend to expand the list of eligible materials covered in the future, which would presumably include cement in the future. Note that Portland, Oregon has a [Low Carbon Concrete procurement policy](https://www.portland.gov/sites/default/files/2020/concrete-epd-requirements-final-20190515.pdf) which is effectively Buy Clean only for concrete. ---
**Author:** ![afeitel](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/afeitel/32/827_2.png) [@afeitel](https://community.carbonleadershipforum.org/u/afeitel)\ **Post date:** [January 13, 2021, 4:39pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/4 "2021-01-13T16:39:48Z")
Ryan, I appreciate the response. And thank you for pointing me to the Portland requirements. Hopefully the cement / concrete suppliers will be more open in the future and evolve mix designs alongside engineers. ---
**Author:** ![mlewis](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/mlewis/32/1413_2.png) [@mlewis](https://community.carbonleadershipforum.org/u/mlewis)\ **Post date:** [January 13, 2021, 6:13pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/5 "2021-01-13T18:13:51Z")
Great question on Concrete! In addition to the Portland policy that Ryan shared, I would also mention the [Low Carbon Concrete Project - County of Marin](https://www.marincounty.org/depts/cd/divisions/sustainability/low-carbon-concrete-project) and the new bill HB 1103 introduced in [Washington State Legislature](https://app.leg.wa.gov/billsummary?BillNumber=1103&Initiative=false&Year=2021), which includes concrete, steel, and wood. Similar bills are being considered in other states as well - check out our [new map](https://carbonleadershipforum.org/clf-policy-toolkit/#map) to track! ---
**Author:** ![raphael.sperry](https://avatars.discourse-cdn.com/v4/letter/r/e56c9b/32.png) [@raphael.sperry](https://community.carbonleadershipforum.org/u/raphael.sperry)\ **Post date:** [January 14, 2021, 5:11pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/6 "2021-01-14T17:11:22Z")
I’m reading the notes and it seems they took industry averages and then added 15-35% to set an upper limit. So this is aimed at excluding worst performers. I suppose it’s a first step but doesn’t seem like it will push things a lot. Do you know if it will be reassessed as the industry average changes? ---
**Author:** ![mlewis](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/mlewis/32/1413_2.png) [@mlewis](https://community.carbonleadershipforum.org/u/mlewis)\ **Post date:** [January 14, 2021, 5:34pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/7 "2021-01-14T17:34:39Z")
In terms of updating, the current legislation requires that _Beginning on 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 legislation also prohibits the limits from moving upward if the average gets worse (let’s hope not!!) but there is no required trajectory to lower the limits towards net-zero. The FAQ section in the same DGS page where these limits were published is great! Answer to lots of questions like this: [Buy Clean California Act](https://www.dgs.ca.gov/PD/Resources/Page-Content/Procurement-Division-Resources-List-Folder/Buy-Clean-California-Act) ---
**Author:** ![zoe.kaufman](https://avatars.discourse-cdn.com/v4/letter/z/e5b9ba/32.png) [@zoe.kaufman](https://community.carbonleadershipforum.org/u/zoe.kaufman)\ **Post date:** [January 15, 2021, 6:29pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/8 "2021-01-15T18:29:58Z")
Question: why mineral wool? Why not XPS, for instance? ---
**Author:** ![JLee\_SF](https://avatars.discourse-cdn.com/v4/letter/j/e47774/32.png) [@JLee\_SF](https://community.carbonleadershipforum.org/u/JLee_SF)\ **Post date:** [February 28, 2022, 9:15pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/9 "2022-02-28T21:15:41Z")
Has anyone experienced push back from steel suppliers that they can’t meet GWP limits specifically for HR sections? We have started to put GWP limits on our general notes and in our specifications based off of median CLF baseline values (1.16) and the suppliers are saying that they can’t meet that and average around 1.25. Note, the project is in CA but does not fall under the BCCA. Our thinking is that if we want to see a change in the materials we have to request/go after more aggressive GWP targets. However, when suppliers are coming back to us and saying it’s not possible/ very difficult to achieve and thus left wondering was the data and/or the low/median/high values appropriate in the first place ? Furthermore, when we are looking at a baseline we are trying to hone in on an appropriate steel EPD to use that has a GWP of around 1.7 (high per CLF). Does anyone have an EPD they can share? I am using OneClick LCA and can’t seem to find one in their database. It’s either too high at 2.11 or too low at 1.36. ---
**Author:** ![ScottFarbman](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/scottfarbman/32/1445_2.png) [@ScottFarbman](https://community.carbonleadershipforum.org/u/ScottFarbman)\ **Post date:** [March 1, 2022, 8:09pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/10 "2022-03-01T20:09:29Z")
@zoe.kaufman I was thinking the same thing. Mineral has such a terrible carbon footprint. They have done an excellent job marketing it as a “green” product. ---
**Author:** ![Cecile\_Roman](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/cecile_roman/32/1233_2.png) [@Cecile\_Roman](https://community.carbonleadershipforum.org/u/Cecile_Roman)\ **Post date:** [March 2, 2022, 9:35pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/11 "2022-03-02T21:35:41Z")
Did you try EC3? These are the results I get by looking up Structural Steel HR sections, with USA as a location (no results when I try California). The results are in kg/lbs but seem consistent with the CLF baseline, with options both better and worse than the baseline value you give (assuming your unit is in kg CO2eq/kg steel). I’m not a steel specialist so I wouldn’t know if the products described in these EPDs are applicable to your situation. ![image](https://us1.discourse-cdn.com/flex015/uploads/carbonleadershipforum/original/2X/a/ab79f20cd2d96628b83a756e01f5677f64d17ed2.png) ---
**Author:** ![NateForrest](https://avatars.discourse-cdn.com/v4/letter/n/f9ae1b/32.png) [@NateForrest](https://community.carbonleadershipforum.org/u/NateForrest)\ **Post date:** [March 3, 2022, 5:20pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/12 "2022-03-03T17:20:34Z")
My apologies for resurrecting an old comment - the topic came through as a recent one due to the replies below and I was reading through what was already said. I think there’s an opportunity to clarify some things here, and also to offer some new information on this aspect of Buy Clean in California. There were a handful of reasons that cement and concrete were removed from the original Buy Clean act: 1. The CA cement industry’s emissions are already regulated under the state’s Cap & Trade program. Adding additional regulations would add cost but may not have resulted in appreciable differences in carbon emissions. 2. It is correct to say that the CA cement industry is trade exposed, but the risk to the industry is not through lower-carbon imported cements, it’s the opposite; imported cements tend to be higher carbon since they are produced in places without environmental regulations and also have transportation impacts because they are shipped mostly from Asia. If the cost of compliance with additional environmental regulation were to render the material unprofitable to manufacture in CA, then all of the cement would be imported. This would be counterproductive in both environmental terms, and also economic terms, making infrastructure more costly to deliver. 3. The CA cement industry was already working on it’s Roadmap to Carbon Neutrality; a plan outlining how the industry will reach net zero emissions by 2045 in line with Executive Order B-55-18. (you can read the document here: [https://issuu.com/askono/docs/cnca.carbonneutrality.vfinal](https://issuu.com/askono/docs/cnca.carbonneutrality.vfinal)._03.28.21_) This is the most aggressive carbon reduction plan for cement manufacturers in the US. Some more recent developments: 1. The trajectory of emission reductions for the CA cement industry is now embodied in the language of SB596 (Becker) - Greenhouse gases: cement sector: net-zero emissions strategy. This is the first industry-specific legislation regarding GHG reductions. Worth noting is that the CA cement industry supported this legislation and testified on its behalf. 2. The proposed SB778 (Becker) would set limits on embodied carbon for concrete mixes and also require the use of performance-based specifications for concrete on State of California procurements. The industry, through several trade associations, is working with the author to ensure the bill is workable for all parties. It’s passage is expected this year. ---
**Author:** ![jschwartzhoff](https://avatars.discourse-cdn.com/v4/letter/j/da6949/32.png) [@jschwartzhoff](https://community.carbonleadershipforum.org/u/jschwartzhoff)\ **Post date:** [March 10, 2022, 1:02am UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/13 "2022-03-10T01:02:37Z")
Question for both you and @zoe.kaufman - Can you go into this comment on mineral wool vs XPS? My understanding was that even the next gen XPS like foamular ngx had higher impacts than a similar rockwool product. Ec3 has mineral wool maxed out at 0.6691 kgco2e per 1ft^2, and which only a few of the XPS options meet or exceed. ---
**Author:** ![ScottFarbman](https://sea1.discourse-cdn.com/flex015/user_avatar/community.carbonleadershipforum.org/scottfarbman/32/1445_2.png) [@ScottFarbman](https://community.carbonleadershipforum.org/u/ScottFarbman)\ **Post date:** [March 10, 2022, 4:54pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/14 "2022-03-10T16:54:01Z")
@jschwartzhoff @zoe.kaufman Looking at EC3… I’m seeing: XPS: - Dupont Styrofoam = **0.536** kgCO2e / ft2 @ RSI-1 - Owens Corning NGX XPS = **0.885** kgCO2e / ft2 @ RSI-1 Polyiso: - GAF Energyguard = **0.243** kgCO2e / ft2 @ RSI-1 - Hunter Panel Polyiso = **0.283** kgCO2e / ft2 @ RSI-1 EPS: - Neopor Graphite Infused = **0.17** kgCO2e / ft2 @ RSI-1 - KORE EPS = **0.231** kgCO2e / ft2 @ RSI-1 Mineral Wool: - Rockwool Comfortboard 110 = **0.662** kgCO2e / ft2 @ RSI-1 - Rockwool Comfortboard 80 = **0.478** kgCO2 / ft2 @ RSI-1 If we go back to the original comment/post and look at the requirement for Mineral Wool Board (9.79 kgCO2e/m2 @ RSI-1), this value is NOT aggressive at all if you expand it to all rigid insulation types. It would really only exclude HFC blown XPS/Spray foam products. That said, if you are comparing XPS vs Mineral Wool, the best rigid mineral wool product out there has similar carbon performance to the best XPS product out there, while EPS and Polyiso are about 2-3x less carbon intensive. ---
**Author:** ![YureSuarez](https://avatars.discourse-cdn.com/v4/letter/y/c89c15/32.png) [@YureSuarez](https://community.carbonleadershipforum.org/u/YureSuarez)\ **Post date:** [August 15, 2022, 8:57pm UTC](https://community.carbonleadershipforum.org/t/buy-clean-california-gwp-limits-published/2763/15 "2022-08-15T20:57:44Z")
Does anyone know how does this limits work if I am using other product that is not Mineral wool? would I measure my insulation against 400kgCo2eq req?