ACAN’s Push for Embodied Carbon Regulation: Transforming UK Construction

How embodied carbon regulation could reshape the construction industry and help the UK achieve net zero by 2050.

By Medha deb

Created on Sep 27, 2025

How embodied carbon regulation could reshape the construction industry and help the UK achieve net zero by 2050.

ACAN’s Campaign: Shining a Spotlight on Embodied Carbon

The construction sector is at a crossroads in the fight against climate change. While energy efficiency has received regulatory attention for years, the carbon footprint embedded in the construction, materials, and end-of-life demolition of buildings — known as embodied carbon — remains largely unregulated in the UK. The Architects Climate Action Network (ACAN) is spearheading a movement to change this, calling for urgent regulatory reform to cap embodied carbon and align industry practices with the UK’s net zero commitments.

What Is Embodied Carbon, and Why Does It Matter?

Embodied carbon comprises all greenhouse gas emissions associated with the extraction, manufacture, transportation, assembly, maintenance, and disposal of building materials and construction processes. Unlike operational carbon — emissions produced while running a building — embodied carbon is emitted before a building is occupied and continues to accrue throughout its lifecycle, particularly during refurbishment and demolition.

According to ACAN, embodied carbon can account for as much as 75% of a building’s total emissions over its entire lifespan in some cases.
Traditional UK regulations focus almost exclusively on operational efficiency, such as heating or cooling, ignoring these upfront emissions.

This oversight is particularly significant as the building sector is responsible for a substantial share of global carbon emissions. Addressing only operational emissions neglects immense opportunities for net reductions.

ACAN’s Core Campaign Demands

To address the “huge blind spot” in current building regulations, ACAN proposes a comprehensive regulatory approach. The central elements of their campaign are:

Setting Limits on Embodied Carbon: Implement strict caps on embodied carbon for all new construction projects by 2025.
Expanding Building Regulations (“Part Z”): Mandate the assessment, reporting, and reduction of embodied carbon within a new building regulations section, enabling compliance through Whole Life-Cycle Carbon Assessments in line with British Standard BS EN 15978.
Introducing Material Carbon Limits: Amend Regulation 7 to impose carbon thresholds on specific high-impact materials — such as concrete and steel — to drive down embodied emissions.
Life-Cycle Assessment at Multiple Stages: Require Whole Life-Cycle Carbon Assessments to be submitted at key planning and construction stages: pre-application, full planning, and practical completion.
Building Carbon Databases: Develop an open-access UK Environmental Product Declaration (EPD) database and a repository for anonymized life-cycle carbon data from new buildings to foster best practices and transparency.

Why Is Regulatory Action Essential?

ACAN and other sustainability advocates argue that voluntary reporting is insufficient. The UK’s legal obligations under the Climate Change Act 2008 and the Paris Agreement require comprehensive emissions cuts — including both operational and embodied carbon — to achieve true net zero by 2050. Without regulation, the construction industry will continue to miss critical emissions targets, undermining national and global climate goals.

What Is “Part Z”?

The concept of a new section within UK Building Regulations — dubbed “Part Z: Embodied Carbon Emissions” — lies at the heart of ACAN’s proposals:

All developments must assess, report, and reduce embodied carbon as compliance criteria.
Limits would be tailored by building type (residential, commercial, etc.), driving industry-wide improvements.
Assessment methodology would be standardized via British Standard BS EN 15978.

Key Policy Recommendations from ACAN

ACAN’s technical documents and briefing notes map out a phased approach. Core recommendations include:

Adopt RICS “Whole Life Carbon Assessment for the Built Environment” as the UK-wide standard (from 2021)
Revise building materials regulations to address carbon limits specifically (Regulation 7)
Mandate embodied carbon reporting for all planning submissions
Enforce lower carbon limits in stages: introduce in 2025, tighten in 2028, and continually review toward net zero by 2040

**ACAN’s Proposed Regulatory Timeline**
Year	Milestone
2021	Adopt standardized methodology (RICS, BS EN 15978); begin policy revision
2022	Mandatory embodied carbon assessment and reporting for all new developments
2025	Enforce strict carbon limit values for all projects
2028	First scheduled tightening of limit values for all developments
2030–2040	Continued downward review of carbon limits; all new/refurbished buildings to be net-zero by 2040

UK vs. International Approaches: How Does Regulation Compare?

While the UK remains behind on embodied carbon regulations, other European countries are taking bold action:

France will implement embodied carbon caps for all new buildings from 2024, accompanied by a national assessment methodology and databases.
Finland will follow suit, introducing strict embodied carbon requirements from 2025.

Both nations have proven that it’s feasible to legislate whole life-cycle carbon assessments and set enforceable thresholds — a model ACAN urges the UK to emulate swiftly to avoid falling further behind its climate ambitions.

Key Steps Taken by France and Finland

Development of standardized assessment methods
Creation of accessible national carbon databases
Implementation of building-specific carbon caps

The Importance of Data & Transparency

ACAN emphasizes that data collection and sharing are foundational for effective regulation:

Freely accessible Environmental Product Declarations (EPDs): Every building material supplier above a certain threshold should submit EPDs to a central database, used by professionals across the industry.
Whole Life-Cycle Carbon Assessment Data: An anonymized database of assessments from real-world buildings will improve benchmarking and accelerate best practice.

These steps ensure that policies are grounded in robust evidence, providing a level playing field and driving innovation in low-carbon materials and methods.

Challenges and the Road Ahead

Although progress is underway, significant barriers remain:

Industry Resistance: The vast scale of the UK building sector and inertia in material supply chains slow adoption of new standards.
Lack of Regulatory Infrastructure: Building carbon assessment skills, data infrastructure, and enforcement mechanisms will require upfront investment and government coordination.
Knowledge Gaps: Many designers, contractors, and policymakers are unfamiliar with life-cycle assessment, highlighting the need for training and widespread awareness campaigns.

Nonetheless, ACAN insists that only through robust regulation, phased implementation, and international collaboration can the UK construction sector truly decarbonize.

Benefits of Regulating Embodied Carbon

Bringing embodied carbon under regulatory control offers powerful climate, economic, and social benefits:

Rapid emission reductions from adoption of low-carbon materials, efficient design, and adaptive reuse of existing buildings
Long-term cost savings as the sector transitions to sustainable supply chains and circular construction models
Reputational gains for the UK as a global leader in sustainable building practices
Healthier, more resilient communities benefiting from less resource-intensive, more durable built environments

Contribution to Net Zero

Without embodied carbon regulation, net zero targets will not be met. Reducing operational carbon alone will leave a massive gap in the UK’s carbon accounting. This is particularly urgent as the world locks in infrastructure for decades to come.

Frequently Asked Questions (FAQs)

Q: What is the difference between operational and embodied carbon?

A: Operational carbon refers to emissions generated during the operation of a building (heating, cooling, lighting, etc.), while embodied carbon encompasses emissions from material production, construction, maintenance, and demolition.

Q: Why has embodied carbon been overlooked in UK building regulation?

A: Historic focus on energy efficiency and operational savings overshadowed embodied emissions, which are less visible but increasingly significant as operational emissions decrease with efficiency improvements.

Q: What is a Whole Life-Cycle Carbon Assessment?

A: It is a comprehensive analysis of all carbon emissions associated with a building from material extraction through to demolition, based on standardized methodologies such as BS EN 15978.

Q: How quickly could embodied carbon limits impact construction emissions?

A: If implemented on ACAN’s proposed timeline, strict limits from 2025 would immediately drive material and design changes, with scheduled tightening further lowering sector-wide emissions by 2040.

Q: Is regulation of embodied carbon achievable?

A: Yes. International examples from France and Finland demonstrate the feasibility of standardizing assessments, maintaining databases, and enforcing carbon limits on all new construction.

The Broader ACAN Agenda

ACAN’s broader advocacy includes campaigning for

decarbonizing the UK’s entire building stock,
pushing for low-carbon material adoption (such as structural timber), and
driving policies that make circular, sustainable construction the industry norm.

With collective action from architects, policymakers, builders, and suppliers, the UK can move from laggard to leader in regulating embodied carbon, setting standards that match the urgency of the climate crisis.

Additional Resources

ACAN’s detailed policy report and briefing notes (2021)
British Standard BS EN 15978 for life-cycle assessment
Case studies from France and Finland on embodied carbon regulation

References

Author

medha deb

Medha Deb is an editor with a master's degree in Applied Linguistics from the University of Hyderabad. She believes that her qualification has helped her develop a deep understanding of language and its application in various contexts.

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