Embodied carbon regulation - alignment of industry policy recommendations

Author: Various

Date published

31 January 2024

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Embodied carbon regulation - alignment of industry policy recommendations

Date published


Date published

31 January 2024



Political party leaders urged to make manifesto commitments for embodied carbon regulation in the UK.

Leading construction industry and built environment experts from 11 organisations demand policy action in election year.

UK Green Building Council (UKGBC), The Institution of Structural Engineers (IStructE), Institution of Civil Engineers (ICE), Chartered Institute of Building (CIOB), Construction Industry Council (CIC), Chartered Institution of Building Services Engineers (CIBSE), UK Architects Declare, RIBA, RICS, Association for Consultancy and Engineering (ACE), and Part Z and have joined forces to send a consistent message to UK political party leaders about the urgent need for regulation of embodied carbon emissions in construction.

They assert that this is necessary as buildings and construction form a substantial part of UK carbon emissions, which are a main driver of climate change. UK policy has stalled, and urgent action is needed.  

The group of experts has issued a paper to political leaders with a key ask: to include in their manifestoes a commitment to move to reduce embodied carbon emissions in construction within two years of starting government.

Additionally, the experts list specific steps for action:  

  • In 2024: Policy signalled confirming the dates and interventions below. 

  • By 2026: Mandate the measurement and reporting of whole-life carbon emissions for all projects with a gross internal area of more than 1000m2 or that create more than 10 dwellings. 

  • By 2028: Introduce legal limits on the upfront embodied carbon emissions [those emissions due to the use of materials in the initial construction] of such projects, with a view to future revision and tightening as required. 

The group says these actions are essential as around 1 in 10 tonnes of the UK’s total greenhouse gas emissions are “embodied carbon” emissions. These relate to the production and use of construction materials, which account for a substantial part of the UK’s overall carbon emissions. 

Will Arnold, head of climate action at the Institution of Structural Engineers explains: “These equate to 64 million tonnes CO2e per year, more than the country’s aviation and shipping emissions combined. Despite their magnitude, embodied carbon emissions remain unregulated in the UK.” 

Louise Hutchins, Head of Policy for UKGBC says: “With time running out to keep global temperatures to 1.5C it’s astounding that 1 in 10 tonnes of UK climate emissions are still unregulated. From Europe to California, embodied carbon emissions are already regulated so we know it’s feasible. And we know from our members that industry is keen to play its part, but it needs government to set a nationwide approach to drive action at scale and pace.” 

Simon Sturgis from Part Z, and lead author of the RICS Professional Standard on Whole Life Carbon Calculations and Special Advisor to the Environmental Audit Select Committee says: “These initiatives are supported by hundreds of businesses, including some of the UK’s largest housebuilders, developers, contractors and financial institutions, all of which can be found on the Part Z website – such as Barratt Homes, British Land and NatWest. All see such regulation as important for consistency and accelerated action in this area.” 

Amanda Williams, head of environmental sustainability at the Chartered Institute of Building (CIOB) says: “There have been numerous industry initiatives over recent years, calling for government action to reduce the construction industry’s embodied carbon emissions. We now join forces as an expert group to pull these proposals together, uniting with one voice for change and asking Government to ensure the UK keeps pace with those who are currently leading this agenda.” 

Dr Anastasia Mylona, Technical Director at CIBSE says: “Building services account for up to 25% of the embodied carbon of new buildings and up to 75% of retrofit buildings, yet the embodied carbon of MEP products is the least understood and quantified. Recognising the significant impact of building services in the whole life carbon assessment of buildings, CIBSE has published TM65 to provide a methodology to quantify embodied carbon at product level. We are envisaging that better defined embodied carbon and industry led guidance will enable the regulation of embodied carbon emissions.” 

Professor Stephen Hodder MBE, CIC Climate Change Committee Chair, says: “Over the years, numerous construction industry initiatives have called for government action in reducing the construction industry’s embodied carbon emissions. CIC welcome the collaboration with this expert group to pull these proposals together, uniting with one voice for change, encouraging the sector to do better in the fight against climate change.” 

Lewis Barlow, ICE Trustee for Carbon and Climate says: “The construction industry has been calling for government action to address embodied carbon emissions for many years. Tools and methodologies to minimise these emissions across the built environment - such as PAS 2080 - already exist, however we still need clear governmental direction to ensure their consistent use and to help maintain our national trajectory towards net zero. We are pleased to unite with fellow industry experts to champion this message." 

Zoe Watson, member of the UK Architects Declare Steering Group and Head of Sustainability at Allies and Morrison, concludes: “With 2024 a general election year, we call on party leaders to make these manifesto commitments and for the next government to act on them.” 
Muyiwa Oki, RIBA President says: “Our message is clear - embodied carbon regulation is critical to reaching net zero. As built environment professionals we understand our duty to reduce emissions and have been leading the charge. We now need urgent action from the next government to deliver a greener future that we deserve."

Amit Patel, RICS Head of Construction Professional Practice, says: “Measurement and reporting of whole life carbon emissions can be achieved through the integration of International Cost Measurement Standards (ICMS), RICS’ Whole life carbon assessment for the built environment and the Built Environment Carbon Database to enable accurate project benchmarking.”

The authors note that these policy recommendations would be complementary to the ‘carbon pricing mechanism’ announced by the government in 2023 and which are due to be introduced in 2027, as well as to existing UK initiatives that incentivise the use of lower carbon cement and steel.

About embodied carbon in construction

 - ends - 

For further information please contact: The Institution of Structural Engineers (IStructE) Newsroom on +44 (0)7930 53 45 43. 

Notes to Editors 

About the Institution of Structural Engineers (IStructE): https://www.istructe.org

The Institution of Structural Engineers dates to 1908 and is now the world’s largest membership organisation dedicated to the art and science of structural engineering. It has over 29,000 members working in 138 countries around the world. Professional membership is one of the leading global benchmarks of competence and technical excellence. Members undergo rigorous technical assessment and commit to continual learning and development.  The Institution drives higher standards and shares knowledge because its members’ work is vital to public safety and meeting the challenges of the future. The Institution provides a voice for its members, promoting their contribution to society as innovative, creative problem solvers and the guardians of public safety. 

About Architects Declare:  UK Architects Declare is a network of architectural practices across the UK committed to addressing the climate and biodiversity emergency. Launched in 2019 by recipients of the Stirling Prize, AD quickly attracted support from other architectural practices and more than 1,300 UK practices have now signed our declaration. Under the wider banner of Built Environment Declares, variations on our declaration have now spread to cover 43 built environment groupings across 28 different countries, with over 7,900 signatories globally. UK Architects Declare has a dual approach, with a common focus on building agency and delivering change: Supporting and encouraging our signatory practices on pathways to delivering their declaration, through guidance, events and discussions; Demonstrating where leaders - in government, institutions and industry - can change the systems behind the crisis and move us away from degenerative ‘business-as-usual’, beyond ‘sustainability’ and towards fully regenerative solutions.

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