Regulations and policies driving embodied and whole-life carbon

Governments around the world are starting to introduce legislation to reduce embodied carbon in construction. Here’s a summary of the jurisdictions driving the embodied carbon agenda.

Regions

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European Union

Jurisdiction	Regulation/policy	Status	Timeline
European Union	Sustainable finance taxonomy criteria for large buildings EU Taxonomy	Mandatory	Made legally binding since June 2021
	Carbon Border Adjustment Mechanism (CBAM)	Proposal accepted	Reporting system for goods at high risk (iron and steel, cement, aluminium)from 2023* Fully operational in 2026
	Construction Product Regulation (CPR)	Under revision	Expected 2025-2030
	Energy Performace of Buildings Directive (EPBD)	Under revision	Expected 2027-2030**

*Under the Commission’s proposal, importers will have to report emissions embedded in their goods without paying a financial adjustment in a transitional phase starting in 2023 and finishing at the end of 2025, giving time for the final system to be put in place.

**The revised Energy Performance for Buildings Directive (EPBD) will include mandatory GWP disclosure for new buildings over 2000 m2 by 2027 and for all buildings by 2030.

Nordics

Jurisdiction	Category	Regulation/policy	Status	Timeline
Sweden Klimatdeklaration	National	National carbon reporting for new buildings over 100m2, limits by 2027	Mandatory	In force since January 2022
Norway TEK 17	National	The regulation does not set limit values but does require that apartment buildings and commercial buildings to prepare a greenhouse gas calculation based on the Norwegian NS 3720:2018 methodology	Mandatory	In force from 1 July 2022, with a transition period of one year
Finland Rakennusten vähähiilisyyden arviointimenetelmä	National	Regulatory, mandatory limits for life-cycle carbon impacts for most building types, including embodied carbon	Mandatory	Expected 2024
Denmark Baeredygdighetsklassen	National	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 2029	Mandatory	From 2023 onwards

Western Europe

Jurisdiction	Category	Regulation/policy	Status	Timeline
Belgium	National (for product)	Regulation requiring materials life-cycle environmental impact must be disclosed if specific environmental claims are made in marketing	Mandatory	In force since 2014
France RE2020	National	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	Mandatory	In force since 2022
Netherlands Milieuprestatie van gebouwen (or MPG)	National	Milieu Prestatie Berekening (MPG) is mandatory for all office buildings over 100 m2 and all residential buildings.	Mandatory	In force since 2013
Germany Bewertungssystem Nachhaltiges Bauen (BNB)	National	National LCA requirement for federal government buildings	Mandatory*

*mandatory only for buildings commissioned by the federal state of Germany

The UK

Jurisdiction	Category	Regulation/policy	Status	Timeline
London, UK The London Plan	Local	The London Plan requires 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	Mandatory	In force since March 2021

North America

Jurisdiction	Category	Description	Status	Timeline
Canada
Vancouver, Canada Vancouver Building bylaws VBBL	Local	All rezoning projects shall report the GWP or embodied carbon in kgCO2e/m2 as calculated by a whole-building life-cycle assessment. *	Mandatory	Since 2017

Toronto, Canada Toronto Green Standard	Local	Whole building LCA demonstrating 20% embodied carbon reduction from baseline required for all city-owned developments	Mandatory	In force since May 2022
The US
Colorado, U. S Buy Clean Colorado legislation	Local	The Buy Clean Colorado legislation sets out requirements for policies to be created that set emissions limits for key construction materials used in federal construction and infra projects	Mandatory	Passed into law in 2021
Maryland, US Buy Clean Maryland Act	Local	To establish a maximum acceptable global warming potential for certain categories of eligible materials used in certain eligible projects		Introduced in 2022, under review
California, U.S Buy Clean California Act (BCCA)	Local	Regulation requiring carbon disclosure for some materials on state-funded projects. Beginning July 1, 2022, the awarding authorities will determine GWP limit compliance of eligible materials using Environmental Products Declarations (EPDs)	Mandatory	In force since July 2022

*The new emission target requires greenhouse gases in B.C. to be 16% below 2007 levels by 2025.