Amazon isn’t a policymaker. But in U.S. construction, they’re starting to play a similar role—especially when it comes to concrete.

Through AWS, Amazon is building data centers at enormous scale. These projects involve thousands of cubic yards of concrete per site, sourced from regional suppliers who need to meet specific environmental standards. There’s no formal legislation involved, but the effect is the same: suppliers are being pushed to prove emissions reductions and verify their data.

This kind of private-sector influence is shifting how EPDs get used in real projects.

Why EPDs Are Becoming Standard Practice

Environmental Product Declarations (EPDs) aren’t new. But how they’re used is changing.

Historically, many producers relied on one or two generic EPDs—often created at the industry level and rarely updated. A few market segments, like public infrastructure or LEED-certified buildings, required them. But for most commercial work, they weren’t even mentioned.

Today, that’s no longer the case.

Large buyers are starting to treat EPDs as a core part of the procurement process. That includes:

• Requiring product-specific rather than industry-average EPDs

• Setting Global Warming Potential (GWP) thresholds for eligible mixes

• Asking for digital EPD submittals tied to batching and QC systems

It’s no longer enough to have an industry-average EPD on file. Producers are expected to deliver the right documentation, in the right format—often as part of the initial bid.

For many, that means standing up new systems just to stay competitive.

Policy Comes First, but Private Demand Is Accelerating It

States have been laying the groundwork for low-carbon construction for years. Buy Clean laws in places like California, Colorado, and Oregon focus on using verified, lower-emissions materials in public projects. Thirteen states are now working together through the Federal-State Buy Clean Partnership.

Policy alone does not cover everything, though. Many producers say the biggest short-term pressure is coming from large private buyers. Companies like Amazon are putting carbon limits directly into project specs and supplier contracts. Instead of waiting for legislation, these buyers want verified data and stricter mix designs now.

Public policy and private procurement work together. The more states implement Buy Clean—and the more private buyers follow suit—the faster carbon performance becomes a baseline requirement instead of an extra.

What Amazon Is Asking For

Amazon has not published a single company-wide policy, but their recent large-scale projects illustrate how they’re pushing suppliers on embodied carbon in specific projects.

Examples from some of AWS’s U.S. data center builds:

• Northern Virginia: Concrete with at least 20% lower embodied carbon than local industry baseline mixes. (Smart Energy Decisions, 2024)

• Virginia region projects with Holcim: Use of Holcim’s ECOPact concrete, which delivers 35–45% CO₂ reductions compared to conventional mixes. (Holcim US)

• Procurement tracking across sites: Integration of the EC3 tool to evaluate mix options and screen submittals for embodied carbon. AWS has cited EC3 use for its data centers in Virginia, Oregon, and other regions. (Building Transparency)

• Oregon: Collaboration with American Rock Products to co-develop and supply a local concrete mix meeting AWS’s carbon goals. (About Amazon)

These are documented, recurring examples—and together, they clearly signal that Amazon will use similar requirements for data centers going forward.

They also indicate that Amazon is making verified EPDs a basic cost of entry for big projects.

Commercial Pressure Brings Three Big Challenges

Producers aren’t just being asked to cut carbon; they’re doing it under commercial pressure, tight timelines, and shifting specs.

Pace and Learning Curve
EPDs and low-carbon specs are new for many suppliers. But big buyers like Amazon move fast. There’s little time to figure things out while keeping bids moving.

Inconsistent Requirements
There’s no universal standard. Specs can change units (cubic meter vs. cubic yard), require recent production data (this year vs. older), or switch from industry-average to mix-level declarations.

Moving Targets
Emissions targets and project specs can change late in the process. That means verified EPDs may need updates or adjustments at the worst possible time.

None of these challenges are unsolvable—but they require better systems and tighter coordination.

How Producers Are Responding

The most proactive producers are treating carbon data like any other part of the submittal process: something to prepare, systematize, and deliver at speed.

Common changes include:

• Maintaining up-to-date EPD libraries tied to plant and mix design

• Training quality control and technical services teams to model GWP at bid time—not after award

• Uploading mix data into EC3 before submitting to the buyer

• Preemptively flagging material substitutions that might affect emissions performance

Some teams have also shifted how they approach internal R&D. Instead of waiting for a customer to ask for a low-carbon mix, they’re pre-verifying options that meet likely thresholds—so they’re ready when the spec lands.

The leading producers are demonstrating that this is just as much about responsiveness as compliance.

Why This Matters Upstream

Procurement decisions don’t just affect submittals. They reach into mix design, sourcing, and production.

To hit a lower GWP target, producers often need to:

• Increase the use of SCMs like slag cement or fly ash

• Shift to lower-clinker cement blends

• Adjust mix water or admixture usage

• Reconsider material sourcing to reduce transport emissions

But SCMs aren’t universally available. Regional supply constraints and spec limitations (e.g., DOT restrictions on certain ash classes) can limit options. In some areas, producers may need to coordinate closely with material suppliers or invest in new testing to validate performance.

What starts as a procurement spec ends up influencing materials strategy—and over time, that reshapes operations.

EPDs Are Becoming a Filter

For many producers, EPDs are no longer optional. They’re a bid requirement.

Amazon—along with Meta, Microsoft, Google, and others—is using them to:

• Screen suppliers before RFPs are issued

• Disqualify mixes that exceed set GWP limits

• Benchmark competing bids based on emissions, not just cost

Ready or Not, It’s Happening

Amazon isn’t writing laws. But their purchasing standards are already shaping which suppliers win work, how producers prioritize verification, and how emissions get tracked across the supply chain.

This isn’t just a trend in tech infrastructure—it’s a signal that large buyers are willing (and able) to enforce decarbonization expectations through procurement alone.

As more firms follow suit, the cost of being unprepared will rise. And in a market where margins are already thin, not being ready with clean, verifiable data could be the difference between getting the job—and getting passed over.

Carbon limits are showing up in bid specs. Submittals are being reviewed for GWP. Buyers are comparing suppliers based on EPD quality. And private-sector leaders (like Amazon) are moving faster than many state programs.

For suppliers, the opportunity is clear: treat carbon the way you treat cost, compliance, and quality. Build the systems now. You will see returns.