Unregulated energy use and carbon emissions from buildings

– and how it is changing.

Unregulated energy use and carbon emissions from buildings – and how it is changing.

Embodied carbon in construction is the next frontier for cutting carbon emissions

Embodied carbon means the greenhouse gas emissions from construction processes and materials over their life-cycle, including transport, construction site, maintenance, replacements and end of life disposal. This matters as construction materials, transport and processes are all energy-intensive, and manufacturing of key materials used in construction is responsible for 11 % of the global greenhouse gas emissions. As manufacturing and machinery use a lot of fuels, it makes this energy “dirty” and carbon-intensive.

Building codes and regulations target building energy use and set legal threshold values. If you don’t meet the code, you don’t get a construction permit – a clear process and very strong incentive. Not so for embodied carbon (and energy). For embodied carbon emissions, the sky is the limit. For now, anyway.

The business case for regulating embodied carbon – industrial competitiveness and sustainable cities

A number of governments have woken up to the issue and started working on regulations. They have excellent reasons to do so. Carbon regulations encourage industry to invest in energy and carbon efficiency, innovation and prefabrication, thus increasing the competitiveness of your industry. If your export markets start to set requirements on product carbon intensity, your export firms are going to start at a double competitive disadvantage: higher manufacturing and transport carbon emissions.

While benefits to the industry are clear, at the same time, embodied carbon reductions benefit the broader society in many ways, some of which are shown in illustration below. As embodied carbon regulations lead to less fuel intensive processes and manufacturing, this leads to cleaner air, and as prefabrication increases, it will lead to less transport, waste and also increased quality of jobs. Speaking of jobs, this will also support new circular business models which create more of them.

The governments driving forward the embodied carbon agenda


Jurisdiction Regulatory program Timeline
Belgium Regulation requiring materials life-cycle environmental impact must be disclosed if any environmental claims are made in marketing. In force
California, US Regulation requiring carbon disclosure for some materials on state funded projects, later to have emission limits (AB-262) 2020
Tanska Regulation requiring carbon calculation requirements for all new buildings and carbon limit values for buildings over 1000 m2 expected by 2023, expanding to  all buildings
by 2025.
Suomi Regulatory, mandatory limits for life-cycle carbon impacts for most building types, including embodied carbon 2024
Ranska Regulatory, mandatory limits for life-cycle carbon impacts for most building types, including embodied carbon. Supporting regulation for product environmental data is already in place. 2022
Minnesota, US Requirement to show 10 % reduction in life-cycle impacts of building materials for any state funded projects In force
Alankomaat Regulatory, mandatory limits for life-cycle impacts of construction materials for offices and residential buildings In force
Norja Regulatory declaration of embodied carbon at minima, expected later to have mandatory emission limits 2022
Ruotsi Regulatory declaration of embodied carbon which is expected to have mandatory emission limits later on 2022
London, UK The New London Plan requiring Whole Life Carbon Assessments and Circular Economy Statements for any development of more than 150 residential units or buildings over 30 m in height and commercial buildings over 2500 m2. In Force


Honourable mention goes to the United States, where the Climate Leadership and Environmental Action for our Nation’s (CLEAN) Future Act was introduced to the United States’ Congress in March 2021.

An ambitious climate change bill aiming to achieve net-zero emissions by 2050, the CLEAN Future Act includes plans to develop a national EPD database, a labelling system to promote construction products with lower embodied emissions and embodied carbon thresholds for public constructions works.

The bill is just at the beginning of its journey through Congress, but it is very likely that significant elements of the CLEAN Future Act will become law before the end of 2021.

The main policies should be captured above, but if one is missing, please ping me at panu.pasanen@bionova.fi.

The next level of regulations is going to come from cities. Where no broader regulatory limits apply, cities can go one further by setting a tighter limit. In countries without existing regulations, cities are shaping this market and are also in a prime position to do so, as the vast majority of construction activity takes place in cities and cities hold specific legal powers. This is also why were were very excited to work on the City Policy Framework for Dramatically Reducing Embodied Carbon with Carbon Neutral Cities Alliance.

“I’m from the government and here to help” – how to do it and how to not do it

Governments have the legal power to draft detailed rules for embodied carbon reduction and enforce compliance with them, although enforcement is mostly left to agencies or supervised bodies.

The role of the markets is to provide innovation, efficiency and ways to do better. This is achieved by competition where all competitors follow the same rules, for example, to quantify carbon reductions. Such claims require a level of verification, which often takes the form of third-party verification (in the case of EPDs or Environmental Product Declarations) or external software verification (in the case of code-compliant life-cycle assessment software). Such verification programs have been successful.

In the case of Environmental Product Declarations, most government programs accept EPDs calculated according to the European Standard EN 15804 with third-party verifications that are published via an EPD program operator. This approach works well, as this standard is widely adopted by the industry and recognized, thus reducing the cost of compliance.

Not accepting EPDs would amount to a barrier to innovation and also a technical trade barrier. This would mean a new innovative or highly circular product can’t get their carbon reduction impacts recognized by the regulatory practise. Relying on only domestic data is woefully inadequate as construction products, especially the more technical and innovative ones, are widely traded.

One unsuccessful case in this category is the Belgian EPD program. Belgium introduced a regulatory requirement for manufacturers wishing to use sustainability claims in marketing to publish an EPD to back up their claims. The Belgian government very unusually set up their own EPD program for this, B-EPD. The legislation entered into force in 2015 but, for the first four years, not a single EPD was published via the program. 

What went wrong in the Belgian experiment? The requirement to work with the government’s EPD program with significant extensions to established standards increased the cost of compliance to manufacturers. In fact, Belgian firms produce EPDs continuously. They just publish them elsewhere.

Product data is tightly connected with software solutions. While at the level of a single city with a single building inspection department it can be workable and also worthwhile to enforce the use of a single software platform, for regulatory purposes in all but microstates the open market for software has been shown to work well. This approach has to be always based on independent tool verification.

Independent software verification programs are in place for regulatory use in France (8 verified software options), Netherlands (4 verified software) and Minnesota (3 verified software). Furthermore, Switzerland (5 verified software) and Austria (3 verified software) also practise this approach for non-regulatory government uses. In the UK, a similar approach is used via a commercial certification that is applied to private buildings, there also three software solutions which are verified and approved.

The open market for LCA software tools is also the stated government position in the case of Finland and Sweden. This ensures good market access to competing solutions that seek to innovate and help find better environmental solutions, by making life-cycle assessment more automated for example.

A competitive market for accepted LCA software ensures that designers working on projects can leverage the full power of modern, automated and self-optimizing design tools that work seamlessly with accepted LCA software. The competitive market for tools also pushes the tool developers to seek to integrate all available data that is accepted by the government requirements to give greater scope for innovation and new products so the designers can reduce embodied carbon in their buildings.

If you are interested in LCA software, you might be also interested in One Click LCA

One Click LCA is an easy to use, automated LCA software solution for construction that is verified and accepted for all the above-mentioned regulatory LCA methods and 40 other standards and certifications. It allows speed and innovation in design with open BIM integration API and integrates with nearly all construction materials EPDs worldwide.

One Click LCA’s product-level tools, enable consultants and manufacturers to calculate and disclose product impacts via product carbon footprints and by generating fully EN and ISO compliant EPDs.

Author - Panu Pasanen

Author - Panu Pasanen

CEO at Bionova, developer of One Click LCA

A building LCA expert with over 15 years of LCA experience. Besides working with certifications, he actively participates in LCA standardization worldwide.

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City Policy Framework for Dramatically Reducing Embodied Carbon


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Embodied Carbon Review One Click LCA

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