A renewed call for embodied carbon regulation to the new government
The Part Z authors have written to the new Labour government and MPs from all parties to reinvigorate the campaign behind the industry-backed proposal for embodied carbon regulation.
Our renewed call for action summarises the key motivations for the Part Z proposals, which are set out below. We suggest Part Z supporters refer to these in their dialogue with government.
Embodied carbon emissions make up one tenth of the UK’s current annual emissions, more than aviation and shipping combined.
As they are unregulated, they have barely decreased in 30 years, despite existing initiatives to decarbonise material manufacturing.
The current lack of regulation in this area is resulting in Local Authorities and private businesses having to invest their own funds into developing localised solutions. This is leading to inconsistent requirements across the country’s construction projects, costing the industry and the public sector time and money.
The lack of direction also reduces interest from those who would otherwise choose to invest in material decarbonisation and low-carbon buildings, growing these exciting new areas of the economy.
The solution to this is to amend the Building Regulations (2010) with a new Part Z. This proposal is widely supported by the UK construction industry, and follows a precedent demonstrated by many of our competitors in Europe and beyond.
It is an opportunity to grow the UK economy, save businesses money, and reduce the country’s carbon footprint in line with our legally binding commitment to Net Zero.
Regulating embodied carbon is the most impactful policy government can introduce to reduce emissions in the buildings sector.
The below information was included in the letter to outline further essential context to the Part Z proposals.
How important is embodied carbon?
The UK Green Building Council estimates the UK releases around 50 million tonnes of embodied carbon per year – more than aviation and shipping combined. Outside of crises, this figure has not substantially reduced over the past 30 years, despite existing initiatives to decarbonise material manufacturing.
The UK Green Building Council Net Zero Roadmap (2021) also shows that during the period 2024-2050, the built environment will be responsible for the release of around 1700 million tonnes of greenhouse gas emissions. Less than one tenth of these emissions are tackled by existing regulation and the forthcoming Future Homes Standard and the Future Buildings Standard.
Meanwhile, embodied carbon due to new construction accounts for over half of the total, but is currently unregulated, and has been explicitly omitted from both Standards by the previous Government.
Who is asking for embodied carbon regulation?
The Part Z campaign has received more than 200 statements of support from across the construction industry calling for embodied carbon regulation. This includes support that ranges from household names such as Barratt Homes, NatWest, abrdn, Morgan Sindall and British Land, down to SME design firms and housebuilders. Many of the statements are available at www.part-z.uk/industry-support and the Part Z authors can provide a full record on request.
Such regulation has been recommended by the Climate Change Committee (CCC) since 2018. In their 2023 Progress Report to Parliament they highlighted the stark lack of progress on their longstanding recommendation of “Set out a plan to make an assessment of whole-life carbon and material use of public and private construction projects mandatory by 2025, to enable minimum standards to be set” (CCC progress report).
Embodied carbon regulation was also highlighted as vital in a 2022 report from the House of Commons Environmental Audit Committee (EAC) following an inquiry into the sustainability of the built environment. The report, entitled ‘Building to net zero: costing carbon in construction’ referred to embodied carbon regulation as “the single most significant policy the Government could introduce” (Committee publications).
Finally, it is also worth noting that this regulation would bring closer alignment with the EU. Earlier this year, the European Commission updated the Energy Performance of Buildings Directive, requiring the reporting of embodied carbon from 2028, and introducing limits two years later (Energy Performance of Buildings Directive Recast). Several European countries, such as France, the Netherlands, Denmark and Sweden already have such regulations in place.
What would embodied carbon regulation do?
Regulation will accelerate the decarbonisation of the construction sector by bringing:
Investment: Regulation will give a clear indicator to investors that low-carbon materials and low carbon buildings are worth investing in. The UK is home to world-leading carbon-neutral cements and concretes, but these innovations struggle to find funding under current government policy. The approaches that have been taken recently to stimulate private investment through targeted government interventions, such as has been seen with internal combustion engine vehicles, are welcomed. The clear market signal of embodied carbon regulation will drive private investment in the decarbonisation of the construction industry, generating economic growth.
Consistency: Regulation will bring consistency across the country’s many construction projects, from housing to hospitals. Not only will this increase the UK’s pace of decarbonisation, it will also save time and money for developers and local authorities. Presently, more than 42 local authorities are investing their limited money in creating local policy to fill the void left by national regulation. The experience of leading local authorities has shown that these policies can have a positive impact, but the details of these policies are inconsistent across the country, leading to costs that are ultimately passed onto the public. National regulation would offer the most effective means to put an end to such wasteful behaviour. There is agreement on this by both the Royal Town Planning Institute (blog post) and the Greater London Authority’s planning team (Q171 of EAC evidence hearing).
Widespread implementation: Industry would respond to such regulation overnight, as it already has all the necessary standards, guidance and tools. Leading businesses regularly calculate and reduce embodied carbon on their projects, and it has had a de-facto national guidance document since 2017 in the form of a Professional Standard from the Royal Institution for Chartered Surveyors (Whole life carbon assessment for the built environment). The recommendations of the CCC and the progress report of the UKGBC show that such voluntary action is not enough, but if regulation were introduced, the industry would be ready.
How would embodied carbon regulation be introduced?
The Building Regulations are regularly amended through Statutory Instruments, and this route could be taken to introduce embodied carbon regulation:- no need for any new Acts. The Part Z authors have already written the required amendment and documentation that could be adopted by the Secretary of State, available to view at www.part-z.uk. The Ministry of Housing, Communities and Local Government has also been conducting research over the past year that would make them well placed to deliver on such an amendment. They also previously committed to “consult on [their] approach to measuring and reducing embodied carbon in new buildings”. (The Future Homes and Buildings Standards consultation)
The topic has also been debated in both houses. In 2022, a Private Members’ Bill – the Carbon Emissions (Buildings) Bill – was debated in the House of Commons. Labour offered its support for the Bill at the time, with Jonathan Reynolds (now Secretary of State for Business and Trade) saying, “We support it. I agree with [Jerome Mayhew MP’s] proposition that industry would welcome further regulation in this area” (Hansard record).
In 2023, the same content was used in proposed Amendment 280 to the Levelling-up and Regeneration Bill that was debated in the House of Lords. This gained cross-party support, including by The Baroness Hayman of Ullock (Hansard record).
There is likely to be widespread support for this regulation in Westminster today, given its ability to generate economic growth whilst strengthening the UK’s global climate leadership.