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What does embodied carbon regulation look like in the construction sector?

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Last month’s IPCC report emphasised that deep emissions cuts across all sectors and systems are required to combat the impacts of human-led climate change. (IPCC, 2023) 

The UK government has committed to achieving a 68% reduction in the country’s carbon emissions by 2030, compared to 1990 levels. 

In line with the Paris Agreement, the UK has also pledged to achieve net-zero emissions by 2050. 

Since the built environment accounts for 25% of the UK's total greenhouse gas emissions, it will be a key sector for emission reductions regulation and efforts going forward. (UK Green Building Council, 2021)

The climate impact of the built environment is predominantly caused by operational and embodied carbon emissions. Reducing emissions across the whole lifecycle of buildings will certainly be key to achieving net zero.

This article will explore the regulatory momentum of operational, whole life and embodied carbon emissions, including: 

  • UK targets and policies around embodied and operational carbon. 
  • International regulation on embodied carbon. 
  • Industry goals and roadmaps for reducing embodied carbon. 
  • Solutions to reduce embodied carbon.

What is the difference between operational, embodied and whole life cycle carbon emissions?

Operational carbon emissions: those associated with the energy used to run a completed building. For example, heating, cooling, lighting and more. (Net Zero Carbon Guide, 2023)

Embodied carbon emissions: the total emissions caused by the materials and construction stages of a building. This includes emissions relating to the extraction, manufacture, transportation and assembly of every element in a building. (UKGBC, 2021)

Whole life-cycle carbon emissions: the carbon emissions deriving from the materials, construction and use of a building over its entire life, including its demolition and disposal. (Greater London Authority, 2022)

How are the built environment’s carbon emissions currently regulated in the UK? 

Current UK government policies focus primarily on reducing operational emissions.

For example, in 2022 the government updated building regulations to include requirements that emissions from newly built homes be around 30% lower than the 2021 standards.

Another policy, The Future Homes Standard, aims to ensure that new homes built from 2025 produce 75-80% fewer carbon emissions than homes built under the current regulations. 

These regulations aim to reduce the operational emissions of buildings by installing low-carbon technologies, such as solar panels and heat pumps, and increasing energy efficiency. 

Embodied carbon is a key theme of industry net zero targets, frameworks and the government’s future carbon budgets. However, there is no current government policy that requires the assessment or control of embodied carbon emissions from buildings.

Nevertheless, reporting on and reducing embodied carbon allows a clearer understanding of the whole life and scope 3 emissions (LINK) of a build. It also reduces regulatory risks as embodied carbon becomes the next area of focus for net zero policies. 

What are the upcoming government policies on embodied carbon?

Despite the lack of current regulation, action is coming on embodied carbon.

  1. In the 2021 Net Zero Strategy, the government set out its intention to improve disclosure standards and further report on embodied carbon.
  1. Moreover, in 2023, the government announced that it will consult this year on how to mainstream the measurement and reduction of embodied carbon.
  1. In addition, a government consultation on mitigating carbon leakage opened in March 2023 and will include discussions on an embodied emissions reporting system. It will also set an upper limit on these emissions for specific industrial products. 
  1. Currently going through parliament, The Carbon Emissions (Buildings) Bill surrounds reporting requirements of whole-life carbon emissions and limit setting on embodied carbon emissions.

The bill includes requirements for embodied carbon in buildings over 1,000m². 

If passed, the reporting of whole-life carbon emissions within a building’s application would be legally required. 

The development of the bill has come from pressures within the industry itself. Efforts have been spearheaded by the Plan Z proposal which has the backing of key stakeholders including the London Energy Transformation Initiative, the Concrete Centre and the Royal Institute of British Architects. 

How is the local government taking action on embodied carbon emissions in the UK?

There is also momentum from local government.

  1. The Greater London Authority (GLA) set out in its London Plan of 2021 requirements for all developments over a certain size to calculate embodied impacts following the RICS methodology.
  1. Beyond London, other local authorities like the West Midlands Combined Authority and Brighton & Hove City Council have included embodied carbon and whole-life carbon assessments in their city plans.

What does embodied and whole life carbon regulation look like in Europe? 

Other countries in Europe already have policies in place that address whole life and embodied carbon emissions. 

  1. The Netherlands require that new buildings larger than 100m2 have whole-life carbon calculations and carbon mitigation cost estimates using a national assessment method, database and approved tools.
  1. In Sweden, since 2022, the calculation and reporting of the embodied carbon emissions has been required in order for new buildings to receive building permit approvals. 

    This policy also involves first gathering data on the state of embodied emissions within the sector and then setting limits allowed in building projects. 
  1. France’s new ‘RE2020’ policy has required whole-life cycle carbon calculations for all new houses built and refurbished since 2022. 

Within this policy, targets for reducing emissions will get progressively tighter each year and will apply to an increasingly wider scope of building projects.

The ratcheting of targets and progressive increase in scope of RE2020 aim to enable the French construction sector to reach net zero by 2050. 

The ‘RE2020’ also takes a dynamic life-cycle approach that reflects the climate emergency by taking into account the time factor of emissions and, therefore, giving more weight to emissions produced now. 

How is industry leading the efforts to reduce embodied carbon?

Leading industry stakeholders have come together to steer the industry in the right direction. 

  1. In the absence of easily understood and consistently applied carbon assessment standards, the Royal Institution of Chartered Surveyors (RICS) issued its Professional Statement on Whole Life Carbon.

    The RISC statement includes a framework for measuring and reporting whole-life carbon emissions and aims to provide principles and practical guidance for whole-life carbon assessment to be adopted across the UK industry. 
  1. The UK Green Building Council (UKGBC) has developed its Net Zero Whole Life Carbon Roadmap for the UK Built Environment, which sets out a vision for achieving net-zero embodied carbon in buildings by 2050. 
  1. The Royal Institute of British Architects (RIBA) produced its 2030 Climate Challenge, guidance on embodied and whole-life carbon assessment for architects which aims to encourage them to take a more holistic approach to designing for net-zero carbon.
  1. UK Net Zero Carbon Buildings Standard (UK NZCBS) is an industry-led initiative which aims to provide a single benchmark for addressing carbon reduction.

    The NZCBS will provide a consistent standardised approach to assessing whether a building can be defined as net zero, in line with the UK’s climate targets. 
  1. Plan Z is a proposed amendment to the Building Regulations 2010 and a proof of concept document that encouraged the initiation of the Carbon Emissions (Buildings) Bill mentioned previously.

    The proposal sets out requirements for the assessment of whole-life carbon emissions and the limitation of embodied carbon emissions for all major building projects. 

These industry-led initiatives show a growing consensus across the sector on the importance of whole life carbon reduction to reach net zero.

Conclusion -  How can OSTO reduce embodied carbon emissions?

The government has set out its intention and action is currently in motion regarding reporting and restricting embodied carbon emissions. 

Local governments and European countries have already set the precedent for these types of regulations setting out a clear path for the UK as a whole. 

Efforts from inside the industry are also leading the way with guidance, policy proposals and measurement ferameworks.

The direction of travel for the industry is clear and it is a case of when, not if, this regulation will come into effect. 

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