The unregulated energy use and carbon emissions from buildings – and how that 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, sky is the limit. For now.

Business case for regulating embodied carbon – industrial competitiveness and sustainable cities

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.

Benefits to society from reducing embodied carbon in construction

The ten leading governments who are already moving embodied carbon agenda forward

This is based on our unofficial survey, and covers national or regional regulatory programs that are expected to cover also buildings other than government buildings for embodied carbon purposes.

Jurisdiction Regulatory program Timeline
Belgium Regulation requiring materials life-cycle environmental impact disclosure in case any green marketing is practised In vigor
California, US Regulation requiring carbon disclosure for some materials on state funded projects, later to have emission limits (AB-262) 2020
Denmark Initially voluntary section in construction code requiring life-cycle assessment-based evaluation of the whole building Not set
Finland Regulatory, mandatory limits for life-cycle carbon impacts for most building types, including embodied carbon 2024
France 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. 2020
Minnesota, US Requirement to show 10 % reduction in life-cycle impacts of building materials for any state funded projects In vigor
Netherlands Regulatory, mandatory limits for life-cycle impacts of construction materials for offices and residential buildings In vigor
Norway Regulatory declaration of embodied carbon at minima, expected later to have mandatory emission limits 2022
Sweden Regulatory declaration of embodied carbon which is expected to have mandatory emission limits later on 2022
Washington, US One attempt (HB 2412) at implementing California-like regulation; expected to be pursued in a different form Not set


Honourable mention goes to Slovenia, who is developing policy using European Commission’s Level(s) assessment method for buildings. As it is not clear yet if this is to become regulation it is not featured in the above table. If we missed one, please ping me at

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 vast majority of construction activity takes place in cities and cities hold specific legal powers. This is also a reason we’re embarking on an exciting new project called 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, where 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 same rules for example to quantify carbon reductions. Such claims require a level of verification, which often takes form of third-party verification (in case of Environmental Product Declarations) or external software verification (in case of code-compliant life-cycle assessment software). Such verification programs have been successful.

In case of Environmental Product Declarations, most government programs accept Environmental Product Declarations calculated according to 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 cost of compliance.

Not accepting Environmental Product Declarations 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. Belgian government very unusually set up their own EPD program for this. The legislation entered in vigor in 2015, and as of this writing October 2019, not a single EPD had been published. What went wrong in the Belgian experiment? The requirement to work with the government’s EPD program with significant extensions to established standards increased cost of compliance to manufacturers. Belgian firms produce EPDs continuously. They just publish them elsewhere.

Product data is tightly connected with software solutions. While at a level of single city with single building inspection department it can be workable and also worthwhile to enforce use of a single software platform, for regulatory purposes in all but microstates 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), 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, similar approach is used via a commercial certification that is applied on private buildings, there also three software are verified and approved. Open market for LCA software tools is also the stated government position in case of Finland and Sweden. This ensures market a good access to competing solutions that seek to innovate and help find better environmental solutions, and make life-cycle assessment more automated for example.

Competitive market for accepted LCA software ensures that designers working on projects can leverage full power of modern, automated and self-optimizing design tools that work seamlessly with accepted LCA software. 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 for construction that is verified and accepted for all mentioned regulatory LCA methods and 40 other standards and certifications. It allows speed and innovation in design with open BIM integration API and integrates nearly all construction materials EPDs worldwide.

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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