EPA Guidance on Asphalt EPDs: What Contractors Must Know About Low Embodied Carbon Materials

The Environmental Protection Agency (EPA) has emerged as a key authority on environmental product declarations (EPDs) for the asphalt industry, offering direct answers to contractors navigating the shift toward low embodied carbon (LEC) materials. With federal infrastructure projects increasingly requiring EPD documentation, understanding how these declarations function has become essential for both asphalt producers and paving contractors. This article draws on guidance from Joseph Shacat, Special Advisor for Implementation at the EPA and former Director of Sustainable Pavements at the National Asphalt Pavement Association (NAPA), to clarify what contractors need to know about EPDs, mix design qualifications, and available federal resources. For a broader overview of safe practices in asphalt operations, refer to our guide on Asphalt Safety Comprehensive Guide to Hazard Management in hot mix asphalt operations.

Understanding Environmental Product Declarations for Asphalt

An environmental product declaration is the standardized document that quantifies the embodied carbon of a construction material. For asphalt mixtures, embodied carbon is measured as the global warming potential (GWP) of the product across its manufacturing stages. The EPD serves as the primary evidence that a mix meets the low embodied carbon requirements specified in a project contract.

What an EPD Covers for Asphalt Mixes

For asphalt mixtures specifically, EPDs include environmental impact data from three key life cycle stages collectively known as cradle-to-gate:

1. Raw material extraction and manufacturing (Stage A1) – This covers the production of asphalt binder, aggregates, and other mix components, including the energy and emissions associated with extracting and processing these materials.
2. Transportation of raw materials (Stage A2) – This accounts for the emissions generated when raw materials are moved from their source to the asphalt plant, with aggregate haul distance being the most significant factor.
3. Asphalt plant operations (Stage A3) – This includes the energy consumed during mix production at the plant, including burner fuel consumption, drying operations, and overall plant efficiency.

Starting with EPD Development

For asphalt producers wondering how to begin making mixes that qualify as low embodied carbon materials, the EPA explains that the requirements depend on the specific program or policy governing the project. Some policies focus purely on disclosure, meaning a producer only needs to provide an EPD to meet the project owner’s requirements. Other policies set specific embodied carbon thresholds that the EPD must meet. The EPA provides a variety of technical assistance resources to support manufacturers through this process, accessible through the EPA Greener Products program.

Before pursuing EPD certification, contractors should familiarize themselves with the major production facilities involved in asphalt manufacturing. Our article on Asphalt Plants and Pavement Construction Equipment a Complete guide to hot mix asphalt production provides detailed insight into plant operations that directly affect EPD outcomes.

Factors That Determine a Mix Design’s Environmental Status

Multiple factors influence the embodied carbon associated with an asphalt mix, and they extend well beyond the mix design itself. Understanding these variables helps producers make strategic decisions to lower their carbon footprint while maintaining performance standards.

Raw Material Stage Factors

In the A1 life cycle stage, the most significant factor is the virgin asphalt binder content. Mixes with higher recycled material contents tend to have lower embodied carbon because they displace virgin binder that carries a heavier environmental footprint. Key considerations include:

• Aggregate quality – Less absorptive aggregates can reduce the virgin binder content needed in the mix, directly lowering embodied carbon compared to using more absorptive rock.
• Binder modifications – Modified binders have higher embodied carbon content than neat binders. Many embodied carbon policies account for this by establishing separate thresholds or limits for mixes containing modified binders.
• Hydrated lime versus liquid anti-strips – Hydrated lime used in the mix can contribute significantly to embodied carbon. Liquid anti-strip additives can serve as a suitable low-carbon alternative when project specifications permit them.

Transportation Stage Factors

The A2 life cycle stage is dominated by aggregate haul distance. Locally sourced materials reduce transportation emissions, while more efficient transport modes such as rail or barge can produce significantly lower embodied carbon than truck transport when available.

Production Stage Factors

The A3 stage revolves around plant energy efficiency and burner fuel type. Producers can improve their EPD performance through several strategies:

• Managing aggregate moisture content to reduce drying energy requirements
• Using warm mix asphalt technologies to lower production temperatures
• Switching to lower carbon fuels such as natural gas
• Participating in the ENERGY STAR APEX program, a free EPA resource that helps asphalt mix producers manage and reduce energy consumption

Procurement and Documentation for Low Embodied Carbon Projects

Paving contractors who purchase asphalt mix from third-party suppliers face distinct responsibilities when working on projects that require LEC materials. Understanding the procurement process, documentation requirements, and timeline considerations is critical to successful project execution.

Verifying Supplier Compliance

Contractors must confirm that their asphalt supplier can provide an EPD for the specific mix being purchased. Once obtained, the EPD must be checked against the project owner’s embodied carbon policy to verify it meets the required thresholds. This verification process requires careful attention to contract language and supplier negotiations.

Timeline and Negotiation Considerations

1. Supplier readiness – If a supplier has not yet developed EPDs, it can take several months to complete the necessary training and data collection. Contractors should factor this into project scheduling.
2. Cost negotiation – There is a real cost to developing EPDs, so this must be factored into contract negotiations between the paving contractor and the material supplier.
3. Alternative sourcing – If a supplier’s EPD does not meet project embodied carbon thresholds, contractors may need to work with the supplier to identify alternative mix designs or find other nearby asphalt plants that meet the owner’s specifications.

Required Documentation

In most cases, the EPD itself serves as the primary documentation for a project using LEC materials. Contractors must always check project specifications for any additional documentation or reporting requirements beyond the standard EPD. As with other project compliance matters, reviewing and revising contract language ensures that all expectations are clearly agreed upon by both parties before work begins. Contractors should also maintain clear communication with project owners about what documentation is required at each phase of construction. Some agencies may request preliminary EPD data during the bidding phase, while others require final certified documents only at project completion. Understanding these timing requirements upfront prevents last-minute compliance gaps. For builders managing broader construction projects alongside paving work, practical insights on managing multiple subcontractors and schedules can be found in our article on Cabinet Doors Hot Water Decks and Wood Repairs expert answers to common home building questions.

Federal Funding Programs and Incentives for LEC Materials

The federal government has established multiple programs to help contractors develop EPDs and meet the growing demand for low embodied carbon materials. These programs provide financial incentives, technical assistance, and market access for asphalt producers and paving contractors who invest in sustainability.

EPA C-MORE Program

The EPA’s Construction Material Opportunities to Reduce Emissions (C-MORE) program is the cornerstone of federal support. It provides:

• Technical assistance for EPD development and data collection
• Grants to offset the cost of developing environmental product declarations
• A low embodied carbon label program to help manufacturers and purchasers navigate the marketplace
• Direct advisory services where companies can contact the EPA for personalized help

Key Federal Funding Sources

The EPA emphasizes that this is a rapidly evolving space with substantial opportunities for asphalt mix producers, material suppliers, and paving contractors. Federal agencies are actively purchasing low embodied carbon construction materials, creating a growing market for companies that invest in EPD development. The C-MORE program continues to develop its label program to help manufacturers and purchasers navigate this expanding marketplace.

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Strategic Considerations for Contractors

As federal funding flows to state DOTs and federal agencies, contractors who prepare now will be best positioned to compete for projects requiring LEC materials. Key recommended actions include:

• Starting the EPD development process early to avoid timeline conflicts on upcoming projects
• Engaging with the EPA’s direct advisory services for personalized guidance
• Exploring ENERGY STAR APEX program participation to improve plant efficiency and EPD performance
• Building relationships with suppliers who already have or are developing EPD capabilities
• Monitoring the C-MORE label program as it continues to evolve and define market standards

The transition to low embodied carbon materials in asphalt construction is not a future possibility but a present reality. With billions of dollars in federal funding tied to EPD compliance, understanding these requirements is now a business necessity for any contractor working on government infrastructure projects. The EPA has made its resources and expertise available to help the industry navigate this transition, and contractors who take advantage of these tools will find themselves ahead of the curve as sustainability requirements continue to tighten.