Dr Lee Jones, Head of Sustainability at NBS (Powered by Hubexo), asks if the UK construction industry is ready for embodied carbon compliance regulations.
The UK construction industry stands at a potential inflection point. While no formal regulatory changes have been confirmed, there is growing momentum – both globally and domestically – towards embedding embodied carbon into building performance standards.
The European Union has already taken decisive steps through the Energy Performance of Buildings Directive (EPBD) and the adjacent Levels Framework, and it’s conceivable that the UK could explore similar pathways in the future.
Recently, the UK has seen notable developments, including the government’s appointment of AECOM to assess readiness for potential changes, and former Environment Secretary Steve Reed’s speech on the circular economy, in which he announced that a new strategy would be published outlining how the government plans to address related issues, including those affecting the construction sector.
The circular economy and embodied carbon go hand in hand; essentially, it means that more accounting of what goes in and comes out must be measured.
Yet despite this prospective development, the industry is largely unprepared for a formal inclusion of any embodied carbon in building regulations.
The regulatory horizon
Embracing the principles of whole-life carbon accountability, such as mandatory embodied carbon reporting, could position UK construction as a global leader in sustainable development.
Aligning with emerging international benchmarks not only supports the UK’s 2050 Net Zero ambitions but also fosters innovation, resilience, and long-term value. Alignment, however, represents both a challenge and an opportunity for forward-thinking organisations.
The potential challenge is significant, most firms lack the tools and skills needed to track embodied carbon properly, and the numbers don’t lie. The NBS Sustainable Futures Report 2024 found that while 70% of construction projects now have sustainability targets, only 40% actually achieve their ‘green goals’.
That’s a glaring gap between the industry’s ambition and its achievement. However, as we shall see, there’s also a significant opportunity for early adopters.
The issue: Inconsistent data
The most concerning issue is the inconsistency in carbon assessment methodologies. The recent AECOM report commissioned by the government found up to a 70% variation in embodied carbon calculations, depending on the methodology used.
This vast discrepancy undermines benchmarking efforts and encourages gamification, where companies might opt for tools or data sets that provide the lowest (i.e. most favourable) emission metrics, rather than the most accurate ones.
These inconsistencies stem from several factors. They include different scoping mechanisms used across various assessment tools, variable methodology and input parameters, lack of comprehensive datasets for comparison, varying quality of available data, and different functional units and service life assumptions.
Unfortunately, inconsistent carbon reporting has the potential to undermine trust in the entire process. Without reliable data, the industry cannot set meaningful targets, progress towards carbon reduction slackens, and a lack of standardisation postpones effective regulation.
As the AECOM report states: “The variation between the outputs of carbon assessments limits the ability to compare results across different developments. This is a challenge for developing consistent datasets of carbon assessments. In turn, this impacts the development of consistent benchmarks and targets.”
The solution? AECOM’s recommendations
AECOM proposes a comprehensive approach to address these critical issues:
A standardised methodology – Developing a common methodology for all carbon tools, both public and private, covering whole-life carbon, key building elements, and modelling assumptions. Standardisation would produce comparable and reliable results, regardless of which tool is used.
Independent confirmation – Implementing independent verification processes to ensure accuracy in carbon assessment tools. This would involve close checking of data sources, methods, scope, and outputs, creating a trusted carbon assessment framework.
Clear guidance – Providing clear guidance on how generic carbon factors should be reported, ensuring consistency across the industry and reducing the potential for manipulation or misinterpretation.
Defined scopes and consistent reporting – Establishing consistent reporting mechanisms to improve benchmarking and data tracking. This includes clear definitions of scope, specifying building type, element categories, and lifecycle modules (as per BS EN 15978 and BS EN 17472).
Assessor training and affordable tools – Upskilling carbon assessors with proper training and creating a clear definition of what makes someone a ‘competent carbon modeller’. Additionally, ensuring access to affordable tools, especially for SMEs, removing cost and knowledge barriers.
At NBS, we would strongly support the UK’s adoption of AECOM’s recommended measures to build a trusted carbon framework.
After all, without consistency, accountability isn’t possible, and without accountability, meaningful progress on carbon reduction will remain elusive. SMEs and designers will require reliable, cost-effective tools to comply with potential carbon regulations.
Practical advice: Getting ahead of regulation
As Head of Sustainability at Hubexo and for the NBS platforms, I would suggest the following actionable steps for organisations looking to prepare for the expected regulatory changes:
Track carbon from project inception – Early decisions have the most significant impact on a building’s overall carbon footprint, so the integration of carbon planning and tracking from the beginning of each project is crucial.
Upskill your teams – Don’t wait for policy; start building internal carbon capability now. This includes training staff on carbon assessment methodologies and potentially hiring specialists with the right expertise.
Define competency – Determine what a competent assessor looks like within your organisation. This includes an understanding of lifecycle assessment principles, familiarity with relevant standards, and the ability to interpret results meaningfully.
Normalise Carbon Data – NBS Source surfaces carbon data in an easy-to-read manner and standardises the declared units by using density or thickness information to allow for uniform metric comparisons. This approach helps avoid potential errors when comparing Environmental Product Declaration (EPDs) with different units (e.g., KgCO2e per metres squared versus kilograms).
A common risk when comparing separate EPDs is that they may comprise different units or scopes, making meaningful comparisons difficult; for example, when one manufacturer includes components supplied by others, while another manufacturer only covers what they directly produce.
At NBS, we support the need for a standardised methodology for carbon calculation to ensure valid product comparisons.
Without this standardisation, it’s extremely difficult to make meaningful comparisons between products. We would also recommend that manufacturers are clear on their claims, including what is and what is not included in their carbon footprint reporting, to avoid any risk of ‘greenwashing’.
Taking these steps now represents a proactive move to prepare for any potential regulatory changes, along with the opportunity to take a lead on this issue within the industry, and a chance to stand out to increasingly carbon-conscious clients.
Looking forward
The construction industry’s green momentum is growing. The NBS Sustainable Futures Report 2024 shows that when ‘don’t-knows’ are removed, nearly nine in ten industry professionals report having worked on a project with sustainable outcome targets.
However, cost remains the main barrier cited to achieving sustainability, particularly in the current economic landscape. This emphasises the need for affordable, accessible tools and methodologies that can be implemented at scale.
NBS is helping organisations prepare for this regulatory shift through several key initiatives. The NBS platform provides structured sustainability data. NBS Source allows specifiers to filter products based on aspects such as embodied carbon criteria, recycled content, and more.
Additionally, the NBS sustainability report export feature in both NBS Source and NBS Chorus includes valuable carbon reporting data to help ease specifiers into this expected transition.
Seizing the opportunity
Embodied carbon regulations would represent not just a compliance challenge to the UK construction industry, but a significant competitive opportunity for forward-thinking organisations.
As the NBS Sustainable Futures Report 2024 reveals, sustainability targets now drive 70% of construction projects, meaning organisations without demonstrated carbon competency will lose business to those who can deliver. While competitors scramble to react should regulations finally hit, early adopters will have mastered their processes, established unassailable expertise, and captured market leadership.
Organisations that embed carbon considerations from project inception avoid the expensive chaos of late-stage redesigns and gain an edge by developing inherently efficient solutions that their reactive competitors may not match. In the war for talent, firms with genuine carbon capabilities will attract the sustainability-minded professionals that stragglers will need but cannot secure.
Preparing for a future where lifecycle emissions are central to design and delivery is not just prudent; it’s a strategic advantage. By anticipating and shaping what responsible construction looks like, the industry can help define the standards of tomorrow.