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Embodied carbon: the new challenge for built environment regulation

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Construction is a carbon-intensive sector.

Building and construction cause 39% of energy-related carbon emissions (UN Environmental and International Energy Agency 2017).

This makes the construction sector a key focus for international efforts to decarbonise. It is already subject to regulation and emissions restrictions.

Currently, British policy focuses on the operational carbon output of the sector – the type of carbon emitted once the building is in use. An example of this is policy that focuses on waste heat, like supporting heat pumps.

However, of the 39% of emissions, 11% are embodied carbon – the carbon emissions produced during the building process and in the materials used.

The apparent need to introduce embodied carbon has been highlighted most recently in the ‘Carbon Emissions Bill’ proposed by MP Duncan Baker in February 2022. But what will embodied carbon regulation look like for the built environment? Which stakeholders need to take note?

This article will cover several regulatory milestones that detail the likely trajectory of embodied carbon regulation in the UK. Architects, specifiers and materials suppliers must consider the impact that ‘whole life’ assessments and embodied carbon measurements will have on their future projects.

How might embodied carbon regulation look?

Britain’s method of achieving a net-zero construction sector is the carbon budgeting system. This means that the UK economy has a specified total maximum for carbon emissions as a whole.

As a carbon-intensive sector, no matter the balance of carbon input and output between UK industries, there will still be significant reductions for the built environment.

Moreover, most of these cuts will be made sooner rather than later. The sixth carbon budget (2033 – 37) recommends a 78% reduction in greenhouse gas emissions (Anne-Marie Trevelyan, Minister of Business, Energy & Clean Growth 2021).

But how does this relate to embodied carbon?

The sixth carbon budget includes policy recommendations for the built environment to consider the impact of materials substitutions ‘from high to low embodied carbon materials’ (CCC 2020).

It similarly recommends ‘whole life’ ‘mandatory’ carbon assessments as a pillar for future regulation, as well as the ‘facilitation of (whole life) benchmarking’ (CCC 2020).

‘Whole life’ carbon assessments are also a key recommendation of the UK Green Building Council’s Net Zero Roadmap.

Their landmark report supports mandatory reporting of whole life carbon for large buildings from 2023 and minimum limits for upfront embodied carbon by 2027 in all sectors (UKGBC 2021).

Future policy decisions will likely reflect the recommendations of the UKGBC.

As well as organisations and policymakers, there is also significant support for embodied carbon measurement and benchmarking from industry leaders.

For example, in December 2021, seventeen industry leaders wrote a letter demanding the urgent introduction of whole life assessments to the construction minister.

Signatories included Mark Robinson (Chief executive of SCAPE), Rick Willmott (Group Chief Executive of Willmott Dixon) and Mark Reynolds (Group CEO of MACE).

Overall, policymakers, organisations and industry leaders seem to be converging on whole life assessments as a crucial part of decarbonising the built environment.

How will this impact architects?

Architects are regularly named the central actors in reducing embodied carbon in these policy recommendations. However, this focus is not solely external to the sector.

Organisations like the Royal Institute of British Architecture (RIBA) emphasise the role of architects in reducing embodied carbon, particularly in new builds (see the RIBA 2030 Climate Challenge).

Moreover, architecture groups such as Part Z and the Architects Climate Action Network (ACAN) suggest whole-life assessments at three stages: pre-application enquiries, full planning submission and practical completion. They also call for introducing strict limit values on embodied carbon emissions for all developments by 2025 (ACAN 2022).

Click here for our architect’s guide on reducing a build’s carbon footprint.

How will this impact materials suppliers?

For materials suppliers, such as those within the concrete industry, reducing embodied carbon is the central point of decarbonisation.

The carbon footprint of cement makes up 8% of the world’s carbon dioxide emissions, more than any individual country other than China and the USA (Guardian 2021).

Therefore, the COP26 Global Cement and Concrete Association’s (GCCA) pledge to cut a quarter of their emissions by 2030 was a landmark moment for the built environment.

In 2020, the GCCA also published their Net-Zero Roadmap. It proposed solutions like investment in innovation and repurposing waste into greener material alternatives to prevent 5 billion tonnes of CO₂ (eq) emissions by 2050.

The organisation represents 40 of the world’s biggest concrete producers, 80% of the industry outside of China.

However, a net-zero concrete sector could be here sooner. Get in touch to learn more about OSTO™, our carbon-negative concrete aggregate.


The Carbon Emissions Bill is one example of the construction industry movement to include embodied carbon in target setting, benchmarking and regulation.

The introduction of ‘whole life’ assessments will likely affect key stakeholders throughout the construction sector and built environment supply chain.

This article will help you learn more about the carbon budgeting system and its impact on the built environment.