A new Washington law will require many manufacturers to commission independent engineering reviews of their emissions reduction options—and most don't know it yet.
Most Washington manufacturers haven't heard of the decarbonization assessment requirement buried in SB6246, but if your facility is classified as emissions-intensive and trade-exposed (EITE), it will directly affect your compliance calendar and budget planning.
Here's what the law requires: Starting December 1, 2028, and every four years thereafter, covered EITE facilities must commission an independent, licensed professional engineer—someone with no affiliation to your company—to conduct and certify a detailed decarbonization feasibility assessment. This isn't an internal review. It's a third-party engineering study.
The assessment examines the technical and economic feasibility of reducing or eliminating greenhouse gas emissions from your facility. Specifically, it must analyze capital costs, operating costs, and other factors relevant to decarbonization pathways. The engineer certifies the findings, and you file the completed assessment with the state.
The requirement applies to facilities in listed NAICS sectors including aerospace, food processing, wood products, chemicals, and others classified as trade-exposed under Washington's Climate Commitment Act. Smaller manufacturers in these sectors are included if they meet the emissions threshold.
SB6246 becomes effective June 11, 2026. However, the assessment requirement itself doesn't trigger until your first filing deadline: December 1, 2028. After that, assessments are due every four years. This gives facilities roughly 2.5 years to prepare, identify a qualified engineer, and budget for the work.
The provision is codified in Section 1, subsection (9)(b), pages 8–9 of the bill.
The assessment serves as a documented baseline of your facility's decarbonization options and their costs. It's not a mandate to implement every recommendation, but it creates a record of what's technically and economically feasible at your site. This information may inform future compliance decisions under the Climate Commitment Act, including potential use of allowances or investment in emissions reduction projects.
For manufacturers, the practical implications include:
The requirement is part of Washington's broader effort to track emissions reduction pathways for trade-exposed industries. Unlike some climate rules, this one focuses on feasibility analysis rather than immediate emissions cuts, giving facilities time to evaluate options without prescribing specific actions.
If your facility falls under the EITE classification, now is the time to understand which sectors and emission thresholds apply to you, and to begin identifying qualified engineers who can conduct these assessments.
Source: Washington State SB6246, Section 1, subsection (9)(b), effective June 11, 2026.