The proposals within Construction Products Reform (CPR) and UK Carbon Borders Adjustment Mechanism (CBAM) are likely to bring embodied carbon and commercial assessments closer together.
From 01/2027 UK CBAM will extend climate levies on the imported materials, such as cement, steel and aluminium, which are already levied against domestically through UK ETS (emission trading scheme). Understanding the embodied carbon content of a design therefore acts as a proxy to understanding both the design’s climate impact and potential of levies being passed through. This is particularly useful for products with complex supply chains and are therefore difficult to fully assess e.g. windows, MEP products, etc.
The CPR consultation outlines new requirements for manufacturers following the recommendation of the Grenfell review, including embodied carbon data covering construction products not already covered by other policies. If acted upon, the proposals in the consultation will help level the playing field by ensuring a minimum amount of information is available for products. This will therefore have potential to improve design opportunities and co-ordination.
An embodied carbon assessment with greater confidence levels requires a verified information. This can be provided as an EPD (environmental product declaration) or digital material passport, which have been growing in number, but to date are relatively limited in availability. A question that remains is whether the consultation is also a policy signal for future Building Regulation changes which currently explicitly exclude embodied carbon targets for buildings.