Steel

Steel is an alloy of iron and carbon. It often contains small quantities of silicon, phosphorus, sulfur, and oxygen. Steel can be repeatedly recycled without losing its properties, and may contain high recycled content. Steel products are often plated or coated, e.g. zinc-galvanized. Steel can be made into product categories including hot rolled structural steel, fabricated steel plate, fabricated hollow steel structural sections (cold-formed welded steel tubing produced in round, square, and rectangular shapes), steel reinforcing bars (rebar), and cold-formed steel framing.

Construction product assemblies (such as fabricated steel products including handrails, conduit, ductwork, pipes, metal raceways, etc.) qualify for IRA funding if at least 80% of the assembly’s total cost or total weight comprises materials that meet these Requirements.

GSA IRA LEC material requirements

GSA IRA limits for low embodied carbon steel

(EPD-reported GWPs, in kilograms of carbon dioxide equivalent per metric ton — kgCO₂e/t)

Steel product category	Top 20% limit	Top 40% limit	Better than average limit
Rebar (fabricated)	728	794	850
Rebar (unfabricated)	611	716	760
Hollow structural sections (fabricated)	1,778	1,854	1,898
Hollow structural sections from electric arc furnaces (unfabricated)	1,580	1,620	1,652
Hollow structural sections from integrated mills* (unfabricated)	TBD	TBD	TBD
Hot-rolled sections (fabricated)	1,022	1,128	1,163
Hot-rolled sections (unfabricated)	686	713	869
Cold-formed and galvanized (stud, track, framing, etc.)	2,228	2,324	2,408
Structural steel plate from electric arc furnaces (unfabricated)	987	1,152	1,190
Structural steel plate from integrated mills* (unfabricated)	TBD	TBD	TBD

*GSA recognizes merit in separate GWP limits for integrated mill and electric arc furnace steel production methods in these product categories. Once adequate data is available (e.g. from EPDs), GSA may develop and issue one or more limits for materials made via integrated steel mills.

Compliance documentation

A product-specific Type III (third-party verified) EPD that: (i) is based on the PCRs used to develop these limits: UL’s PCR Guidance for Building-Related Products and Services [PDF], Part B: Designated Steel Construction Product EPD Requirements (8/2020, version 2.0) or SCS Global Services’ PCR for Designated Steel Construction Products [PDF] (5/2015, version 1.0); and (ii) conforms with ISO 14025 and ISO 21930. Where feasible, EPDs must also rely on facility-specific data, including for the supply chain’s associated unit processes, such as fabricated steel’s upstream steel mill(s), rather than industry or manufacturer average data. If an EPD containing facility-specific data for the material’s most greenhouse-gas intensive processes is unavailable, an EPD without such data that meets Compliance Documentation criteria (i) and (ii) is sufficient.

If steel originates from an integrated steel mill: ENERGY STAR Energy Performance Score for supplying integrated steel mill, the manufacturing plant name(s) and location(s), and the data period of the Energy Performance Score(s) at the time of purchase. For more information, please see ENERGY STAR Energy Performance Scores explained below.

ENERGY STAR Energy Performance Scores explained

ENERGY STAR Energy Performance Scores show how efficiently a manufacturing plant uses energy on a 100-point scale. A score of 50 reflects average performance, 1 shows poor performance, and 100 reflects highest performance.

Contractors obtain Energy Performance Scores by requesting producers of cement, glass, asphalt mix, and steel (from integrated mills only) to provide the score. Or, contractors may request it from material suppliers (e.g. concrete producers).

Manufacturers of cement, glass and steel (from integrated mills only) produce a plant’s score by inputting 12 months of energy and production data in the industry-specific Energy Performance Indicator tool available at www.energystar.gov/epis. The score will show on the Statement of Energy Performance section of the EPI.

Energy Performance Scores can currently be produced for cement, flat glass, and integrated steel mills.