Summary
Details
- California
AB 2446 imposes binding obligations on new construction projects meeting size thresholds in California.
Obligations include:
Perform a life-cycle assessment (LCA) of construction and material carbon intensity (product stage + construction phases).
For each project meeting threshold, include an Environmental Product Declaration (EPD, Type III) or equivalent verified LCA for building materials used.
Comply with the carbon-intensity reduction trajectory established by the statewide framework once adopted.
Exceptions:
Projects below the size thresholds — i.e. small residential developments (<5 units) or small non-residential buildings (<10,000 sq ft) — are not subject to the LCA / EPD requirement under AB 2446.
The law allows a framework-design period; until CARB publishes the official measurement and reporting methodology (due July 2025), compliance may follow interim guidance or preparatory best-practice assessments.
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What’s Required
Establish a framework to measure and reduce the carbon intensity of materials used in new building construction in California (residential and non-residential).
For new residential developments of 5 or more units, or new non-residential buildings over a threshold (e.g., 10,000 sq ft), require submission of a life-cycle assessment (LCA) covering product stage + construction phases (materials, energy use, waste) or an Environmental Product Declaration (Type III EPD) for the building materials used.
Use the framework to set a baseline (2020) for carbon intensity, and track reductions in subsequent projects.
Important Deadlines
AB 2446 was signed into law in 2022.
The state agency California Air Resources Board (CARB) must develop and publish the measurement & reporting framework by July 1, 2025.
The law sets a target of a 40% net reduction in the carbon intensity of building materials by 2035, relative to the 2020 baseline.
For a larger ambition, the law aims for an 80% net reduction by 2045, with interim goals: 20% reduction by 2030 and 40% by 2035 (per one version of the proposal).
Current Status
AB 2446 is fully enacted (signed into law in 2022).
As of 2025, CARB is actively working on the required framework to define baseline, LCA methodologies, EPD requirements, and reporting mechanisms.
The law shifts California’s building and construction sector toward embodied-carbon measurement, aligning with broader climate and sustainability goals for buildings.
Penalties for Non-Compliance
The statute itself does not specify detailed penalty amounts; compliance obligations are structural (framework, reporting, LCA/EPD) rather than fee-based.
Projects failing to provide required LCA/EPD data when required may be subject to regulatory refusal or delays in permitting, once the framework is active.
Non-compliance could affect eligibility for state building permits or public procurement contracts that reference embodied-carbon compliance.
Examples of Known Violations
As of 2025, no publicly documented enforcement actions or sanctions under AB 2446 are available, the framework is still being developed, and the first LCA/EPD requirements have not yet come into force.
Stakeholders anticipate that the first compliance obligations will begin after CARB issues the formal guidelines in 2025–2026.
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