The trade association for energy infrastructure & systems

Discussions across industry and reviews of existing standards and policy has shown that there does not appear to be a single accepted definition of product embodied carbon which the built environment can adhere to. The definition of what product embodied carbon is within the whole life cycle assessment can vary dramatically with heavy interpretation.  

This leads to confusion across different market actors and increases workload for the supply chain in having to provide differing information to meet the requirements of varying viewpoints. For us to have one approach to move forward in addressing embodied carbon, we need to agree on definitions and to have a single language for sustainability and circularity.

As the Trade Association for manufacturer of energy related infrastructure systems and building services, BEAMA has had discussions across our membership to back an existing definition of embodied carbon for MEP products. You can read this definition here.

Tied into the lack of an agreed definition and terminology, there are additional complexities which makes comparing product embodied carbon data difficult.  

There are various standards, programmes, documents, accreditations, and companies which offer support to estimate the embodied carbon footprint of a product. This has led to varying methodologies to calculate embodied carbon which can draw from one of many different global databases – even two companies following the same methodology may end up with different results unless they use the same base data. Each difference and database make it harder to compare information.

There are common methodologies used in the market, including Environmental Product Declarations (EPDs), Product Environmental Profile (PEPs) and CIBSE’s TM65 Assessment. Even these more common methodologies can be misunderstood, including the differences between them, when to ask manufacturers for them, the scope of the methodologies, and what they include. However, depending on the product and the company, it can be counterproductive to request data in a certain form or database, or even make bespoke data requests. Reasons include cost, international alignment, product specificities, time constraints and third-party assurance.

Guidance does exist in how to compare different methodologies. Instead of focussing on requesting one of these, the market could adopt a flexible approach by requesting product embodied carbon data applicable to certain life cycle stages.

Providing embodied carbon data for a product is still a relatively new requirement for the built environment. From a manufacturer perspective, it is not always easy to know where to find the relevant information as discussed in the section on comparability. As there no legal requirement in the UK to provide embodied carbon data for products, there is no legal guidance or clarity to provide support or direction.

It can take time to establish a commercial proposition for the high resource and budget cost associated with obtaining and, if required, verifying the information. It also takes time to gather the data, with mechanical and electrical products known to have highly complex global supply chains.

Complex global supply chains can make sourcing reliable and accurate product embodied carbon data difficult for manufacturers. In the UK, we have an increasing focus on embodied carbon, but it may not be under the same spotlight for countries around the globe which host parts of UK supply chains. As the market gives manufacturers time to prepare for a future more heavily focussed on product embodied carbon, so too do manufacturers need to give the same message to their supply chains.

Where data does exist, it may not be up to date and/or readily available. It may also not be comprehensive enough to meet the requirements for the built environment to create Net Zero buildings and infrastructure. This is especially the case as technological advances can mean data can become out of date quickly.

For example, new materials could alter the values of an existing EPD or PEP, typically with five-year validity from publication, which could then require recalculation. This in turn can incur a heavy fee. However, this example scenario is easier to manage for methodologies which require no third-party accreditation, such as CIBSE’s TM65 Assessments.

The final challenge is the lack of Government policy and regulation to provide guidance to the built environment. Without this key political steer, the market has been left to create their own programmes and requirements to fill this next step on the journey to Net Zero. Well created policy which guides the market on how to address embodied carbon in buildings and infrastructure will help to provide certainty and clarity to the supply chain and consistency across the market.

Government has noted that they are working on regulation for whole-life carbon assessments in buildings, and the recent RIIO-ED2 has bought embodied carbon into the spotlight for energy projects. Policy and regulation in this area can help to unite the market and supply chain to collaborate on adopting embodied carbon practices in the UK.

Policy and Regulation

The final challenge is the lack of Government policy and regulation to provide guidance to the built environment. Without this key political steer, the market has been left to create their own programmes and requirements to fill this next step on the journey to Net Zero. Well created policy which guides the market on how to address embodied carbon in buildings and infrastructure will help to provide certainty and clarity to the supply chain and consistency across the market.

Government has noted that they are working on regulation for whole-life carbon assessments in buildings, and the recent RIIO-ED2 has bought embodied carbon into the spotlight for energy projects. Policy and regulation in this area can help to unite the market and supply chain to collaborate on adopting embodied carbon practices in the UK.