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To choose low-carbon steel for a construction project, first reduce the steel required where the design can do so safely and practically, then compare eligible offers using applicable Environmental Product Declarations (EPDs) and their reported global warming potential (GWP). Require disclosure in the specification, check that EPDs cover comparable products and life-cycle stages, and set any GWP limit to fit the project’s requirements and available supply. Recycled content alone does not show the embodied carbon of the steel you will receive.
What does “low-carbon steel” mean for a construction project?
For procurement, “low-carbon steel” is useful only when the project defines how it will be identified. A product’s label, production route, or recycled-content percentage is not enough to establish its embodied carbon. The practical evidence is the reported GWP in an applicable EPD, interpreted against project requirements and other offers with comparable scope and methodology.
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An EPD is an environmental declaration that reports impacts for a defined product and life-cycle scope. GWP is the climate-impact figure to examine when comparing embodied carbon. An EPD is not, by itself, a guarantee that one offer is lower-carbon than another: differences in product coverage, underlying data, methodology, and product category rules can make a direct comparison misleading. The American Institute of Steel Construction (AISC) recommends requiring EPD disclosure in construction specifications and cautions that EPD comparisons have limits. See its guidance on specifying structural steel to reduce embodied carbon and its specification strategies for embodied-carbon reduction.
There is no single GWP threshold in the available guidance that applies to every steel product, project, market, and jurisdiction. A project may require disclosure only, set a direct GWP threshold or reduction target, or combine the two. The appropriate approach depends on the governing procurement rules, the steel being specified, the availability of comparable EPDs, and the project’s supply, cost, and schedule constraints.
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What should you decide before asking for bids?
Agree on the project’s carbon and performance goals early, while the design and procurement teams can still influence material quantity and sourcing. The Institution of Structural Engineers (IStructE) advises aligning sustainability goals with the client and wider design team and considering cost, time, and logistics across the supply chain. SE 2050 similarly puts reducing material use early in design ahead of specifying lower-embodied-carbon materials.
- Set the project objective. Decide whether the project needs transparent carbon disclosure, a defined reduction target, a maximum GWP, or compliance with an applicable public procurement or rating-system requirement. Clarify the intended scope with the owner and design team.
- Review material quantity with the structural team. Ask whether the design can use less steel while still meeting structural performance and project constraints. This is not a procurement substitution: the engineer and design team must evaluate whether any proposed change is safe and practical.
- Identify the products and performance requirements. Define the steel products that are eligible for bidding and keep those requirements consistent when comparing offers. Carbon criteria should not obscure whether an offer meets the project’s actual product and performance needs.
- Check the governing rules and market. Confirm which jurisdictional, funding, solicitation, or rating-system requirements apply. Consider whether the proposed disclosure or threshold can be met by suppliers for the required products and delivery schedule.
- Tell the supply chain before tender. Communicate the carbon objective and documentation expectations early enough for the delivery team and suppliers to assess availability, logistics, cost, and timing. IStructE recommends considering these supply-chain factors alongside sustainability goals in its steel specification guidance.
Early coordination matters because a carbon criterion that arrives only at bid evaluation can leave the team without comparable documentation or practical alternatives. The goal is to make the evidence request, design assumptions, and evaluation method clear before suppliers price the work.
How should you use EPDs to compare steel offers?
Request applicable product- or mill-specific EPDs, record the reported GWP and life-cycle scope, and verify that the documents are sufficiently comparable before ranking offers. Do not treat two numbers as comparable simply because both are labeled GWP.
- Request the EPD for the offered steel. Ask bidders to identify the EPD supporting the specific product or mill offer, rather than relying on a generic statement about a company’s sustainability or production. AISC recommends EPD disclosure in construction specifications; its EPD resource page is another point of reference.
- Record the declared GWP and scope. Capture the value reported and the life-cycle stages included. If the project’s requirement is limited to a particular set of stages, make sure the EPD and the project’s comparison basis align. For example, Canada’s federal standard described below calls for A1–A3 disclosure supported by EPDs in its stated scope; that is not a universal boundary for all projects.
- Check product category rules and methodology. Review whether the EPDs use applicable product category rules and sufficiently compatible methods and data. If key assumptions or boundaries differ, flag the comparison instead of presenting the figures as equivalent. AISC specifically warns that differences in data, methodology, and product category rules can limit EPD-to-EPD comparisons.
- Interpret the result in project context. Use the EPD figures as evidence for the specified steel, but consider them within the project’s whole-building life-cycle assessment (LCA) where appropriate. A product-level result is one input to the building-level decision, not a substitute for the project’s broader assessment.
- Retain the evidence with the bid evaluation. Keep each offer’s EPD, declared value, scope, and any noted comparability limits together with the decision record. That makes the basis for acceptance or rejection clear to the owner and project team.
If EPDs are not comparable, the right response is not to choose the lowest-looking figure without qualification. Ask for clarification or additional documentation, establish a common comparison basis where the project can do so, or identify the uncertainty in the evaluation. AISC’s embodied-carbon specification strategies recommends interpreting EPDs in whole-building LCA context rather than treating every declaration as directly interchangeable.
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Should the specification use an EPD requirement or a GWP limit?
Requiring EPD disclosure creates the evidence needed to evaluate steel offers; a direct GWP limit or reduction target sets a carbon performance requirement. A project can use both, but should not assume that a disclosure requirement alone guarantees a lower-carbon outcome.
| Approach | What it does | When it can fit | Key caution |
|---|---|---|---|
| Require EPD disclosure | Requires bidders to provide environmental information for the offered product or mill. | Useful when the project needs transparent evidence and wants to assess offers against a defined comparison method. | EPD figures may not be directly comparable if product scope, methods, data, or category rules differ. |
| Set a direct GWP threshold or target | Specifies a carbon criterion for eligible offers or a reduction objective. | Useful when the owner or governing program has a clear, applicable performance requirement. | The criterion must match the required product, available market, and applicable policy; a poorly scoped limit can produce unusable or misleading bid comparisons. |
| Combine disclosure and a direct criterion | Requires evidence and evaluates it against a stated carbon requirement. | Useful when the project needs both documentation and a defined carbon outcome. | State the comparison basis and what documentation will demonstrate compliance. |
AISC describes a direct GWP threshold as a more direct way to address embodied carbon than relying on a recycled-content minimum. The threshold should be selected for the project’s market, required product, and applicable policy—not copied from an unrelated project or treated as a universal steel target. Its December 10, 2025 article, “How to specify structural steel to reduce embodied carbon,” recommends that construction specifications require EPD disclosure.
Why isn’t recycled content enough?
Recycled content describes one aspect of material sourcing; it is not a proxy for the embodied carbon of the steel delivered to the project. AISC notes that recycled content can correlate with lower GWP, but says it does not establish the carbon impact of the actual steel offer. If a program requires recycled-content reporting, include it as a separate requirement, not as a replacement for EPD evidence and direct GWP evaluation.
This distinction prevents a common specification mistake: setting a recycled-content minimum and then assuming the requirement has selected the lowest-carbon eligible steel. Ask for the project-relevant EPD and evaluate its declared GWP on a comparable basis. If the procurement rules call for both recycled content and GWP information, address each criterion independently.
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How do you compare bids without overstating the carbon difference?
Compare bids using a consistent set of product, carbon, design, and delivery criteria. Rank offers on GWP only after checking EPD comparability, and do not let a favorable carbon figure compensate for a failure to meet essential project requirements.
| Evaluation item | What to record | Why it matters |
|---|---|---|
| Product and performance compliance | Whether the offered steel meets the specified product and performance requirements. | Carbon comparisons are meaningful only among offers that are eligible for the project. |
| Design quantity and assumptions | The steel quantity and design assumptions used for the bid, including any proposed changes. | A per-product comparison can miss the effect of differing material quantities; design changes require review by the design team. |
| Carbon evidence | EPD reference, declared GWP, life-cycle stages, product scope, and identified method or category-rule differences. | Documents the basis and limits of any carbon ranking. |
| Project threshold | Whether the offer satisfies the stated GWP limit, target, or disclosure requirement. | Shows compliance against the project’s own rule rather than an assumed industry-wide target. |
| Supply and delivery | Availability, sourcing, logistics, and schedule implications raised by the supplier and delivery team. | A carbon objective must be achievable within the project’s delivery constraints. |
| Commercial evaluation | Cost and any other project-specific bid criteria. | Allows the owner to assess carbon alongside the project’s other stated requirements. |
Where bids use different EPD scopes or rules, label the result as a limitation rather than calculating a false precision. If a whole-building LCA is being used, keep the steel comparison consistent with that assessment’s assumptions. The point is not to make every uncertainty disappear; it is to disclose which offers satisfy the same requirements and what cannot be compared reliably.
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A useful specification makes the required evidence and evaluation basis explicit. Adapt the following illustrative language to the project’s applicable product requirements, jurisdiction, and solicitation; it is a drafting aid, not a substitute for the governing standard or project specification.
Illustrative requirement: “With each bid for the specified steel products, submit the applicable product- or mill-specific Environmental Product Declaration supporting the offered steel. Identify the reported GWP, the product scope and life-cycle stages covered, and the applicable product category rules or methodology stated in the declaration. The project will evaluate GWP only among offers with sufficiently comparable product scope and life-cycle boundaries, and will apply the project’s stated GWP threshold or target, if applicable. Identify any proposed product or design substitution and its effect on project requirements, quantity, availability, logistics, cost, and schedule.”
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Before issuing the specification, fill in the project’s actual product scope and carbon criterion, if one applies. Do not insert an arbitrary numerical limit just to make the clause look precise. The available sources support the use of project-appropriate thresholds, not one universal value. State how the project will handle EPD differences and whether the bid must include disclosure even where the project is not setting a threshold.
What does the Canadian federal standard require?
Canada’s Standard on Embodied Carbon in Construction is a jurisdiction-specific example, not a general benchmark for every steel project. In the stated steel eligibility context, the standard uses a “lowest-performing 20%” threshold, subject to reasonable sourcing, and calls for A1–A3 disclosure supported by EPDs. The standard’s effective date for relevant design services is September 1, 2025.
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Those details should be used only when the standard applies to the project and its stated scope. They do not mean that all steel procurement must meet a lowest-performing-20% threshold, nor that A1–A3 is the required boundary for every owner, region, or solicitation. Confirm the current rules for the project’s location, funding, and procurement before using a jurisdictional example as a contract requirement.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What are the most common mistakes when specifying low-carbon steel?
Most avoidable problems come from treating a single data point as a complete carbon comparison or setting a requirement too late to influence design and sourcing.
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- Equating recycled content with low GWP: recycled content can be informative, but does not substitute for the embodied-carbon evidence of the offered steel.
- Comparing EPD numbers without checking scope: verify product scope, life-cycle stages, data, methodology, and product category rules before ranking.
- Copying a threshold from another project: use a limit only when it fits the product, market, and governing policy for this project.
- Waiting until bids arrive to request documentation: set expectations before tender so suppliers and the delivery team can consider availability and logistics.
- Optimizing the product while ignoring quantity: consider material reduction through design first, with the structural team evaluating safety and practicality.
- Overlooking project-wide impacts: interpret product declarations in whole-building LCA context where appropriate.
- Ignoring schedule and sourcing: test carbon objectives against availability, logistics, cost, and timing rather than assuming any preferred offer can be delivered.
- Presenting a limited comparison as a definitive ranking: disclose when EPD evidence is not sufficiently comparable instead of claiming a precise difference.
How can a project team make the decision?
Use this sequence to turn a broad sustainability goal into a procurement decision the team can explain:
- Set the objective with the client and design team. Decide what the project is trying to achieve and which rules govern the procurement.
- Review steel demand. Ask the structural team whether material use can be reduced safely and practically before pursuing a product substitution.
- Specify disclosure. Require applicable EPDs for the offered steel and identify the GWP and scope information bidders must provide.
- Choose the evaluation method. Decide whether disclosure will be used for comparison, whether a project-specific GWP threshold or target applies, or whether both are needed.
- Test comparability and feasibility. Confirm the EPD basis and discuss availability, logistics, cost, and timing with the delivery team and suppliers before tender.
- Evaluate eligible bids consistently. Compare product requirements, design quantity, EPD scope and GWP, threshold compliance, sourcing, cost, and schedule. State any limitations.
- Keep the decision record. Retain the EPDs, comparison basis, and rationale for the selected offer so the carbon decision is traceable.
The central principle is straightforward: reduce demand where the design permits, require evidence for the steel being offered, and compare like with like. A sound specification does not claim that one production route or recycled-content figure proves low carbon. It sets a project-relevant rule, makes the EPD comparison transparent, and accounts for the practical conditions needed to deliver the steel.
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Does an EPD certify that a steel product is the lowest-carbon option?
No. An EPD reports environmental impacts for a defined product and scope; it does not establish that the product is lowest-carbon among all available offers. A project must compare applicable declarations on a sufficiently consistent basis and interpret them in context.
Can a project set a GWP limit before the final steel supplier is known?
Yes, if the limit is grounded in the project’s required products, available market, and governing rules. Check feasibility with the design and supply teams early, and make the EPD basis and compliance method clear in the procurement documents.
Who should review a proposed steel substitution for carbon reasons?
The structural engineer and wider design team should assess whether a proposed change preserves project performance and is safe and practical. Procurement should also check that the substitution’s documentation, delivery implications, and commercial terms meet the project’s stated requirements.
Is a product EPD enough to understand a building’s embodied carbon?
Not necessarily. A product declaration addresses a defined product and life-cycle scope, while a building-level assessment considers impacts in the context of the project. AISC advises interpreting steel EPD comparisons within whole-building LCA context where appropriate.
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