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Regulating Embodied Carbon: A Climate Imperative for All Products

Understanding embodied carbon and why regulation is crucial for climate action across building materials, products, and industry.

By Medha deb

Created on Sep 27, 2025

Understanding embodied carbon and why regulation is crucial for climate action across building materials, products, and industry.

Why Regulating Embodied Carbon Matters

As governments, industries, and citizens strive to combat climate change, attention has largely focused on cutting operational carbon—the emissions produced by using energy to heat, cool, and power buildings and products. However, an equally critical but less visible source of emissions demands our urgent attention: embodied carbon. Embodied carbon encompasses the greenhouse gases emitted through every stage of a product’s life—from raw material extraction and manufacturing to transportation, construction, and disposal.

The climate crisis calls for emissions reductions wherever possible, but without decisive action on embodied carbon, our efforts will fall short. As advances in efficiency and renewable energy shrink operational emissions, embodied carbon is becoming a larger slice of the carbon pie—sometimes totaling half or more of a building’s total emissions footprint.

Defining Embodied Carbon

Embodied carbon refers to the total carbon dioxide (CO₂) and other greenhouse gas emissions generated to create, transport, assemble, maintain, and dispose of products and buildings. It is described as “upfront carbon” because it is released before the product or structure is even used .

Material Extraction: Mining, logging, or harvesting raw materials (stone, metals, timber, etc.).
Processing & Manufacturing: Refining, smelting, and producing usable materials like cement or steel.
Transportation: Shipping heavy or processed materials to factories, retailers, and construction sites.
Construction & Assembly: Using energy-intensive equipment and machinery during the building process.
Maintenance, Repair & Replacement: Additional products and energy for repairs or upgrades over the product’s life.
End-of-Life: Demolition, deconstruction, transport, recycling, landfill, and emissions associated with disposal.

Unlike operational carbon, which is emitted over decades as a product or building is used, embodied carbon is locked in during manufacture and construction—making it impossible to mitigate or reverse through efficiency upgrades later on .

Embodied Carbon Versus Operational Carbon

Embodied Carbon	Operational Carbon
Emissions from materials and construction	Emissions from energy use during building’s or product’s lifetime
Locked in at the time of creation	Can be reduced through upgrades and behavioral changes after use begins
Up to 50% or more of new construction emissions	Historically dominant, but declining as grids decarbonize
Requires early design and procurement decisions	Can be addressed over time via retrofits or switching energy supply

The Global Significance of Embodied Carbon

Buildings and infrastructure are responsible for nearly 40% of annual global CO₂ emissions. Of these, embodied carbon accounts for around 13% now—rising sharply as operational carbon drops, especially in countries where the electric grid is already clean and efficiency is high, such as Sweden, Norway, and Canada .

Rapid urbanization means the built environment is projected to double globally by 2060. The materials chosen now shape emissions for decades. For example:

Cement, a key component in concrete, is responsible for around 7% of global CO₂ emissions—more than the entire aviation industry.
Once embodied carbon is emitted during construction or manufacturing, it cannot be “retrofitted away.”
Efforts to lower operational carbon make embodied carbon an increasingly important share of total emissions (up to 50% or more in new buildings by 2050).

Why Mass Regulation Is Needed

Improving operational efficiency—such as through better insulation, smart lighting, and renewable energy sourcing—has delivered major carbon savings over recent decades. However, as these emissions shrink, the urgency of addressing embodied carbon becomes unavoidable.

Market forces alone are not moving quickly enough. Most manufacturers lack strong incentives to innovate in low-carbon materials or processes unless regulations and public procurement standards push them to. Without clear, enforceable limits or pricing on embodied carbon, high-emissions materials and products continue to dominate the market.

What Makes Embodied Carbon So Challenging to Regulate?

Unlike operational carbon—where measurement and solutions are relatively straightforward—regulating embodied carbon presents tougher technical and policy hurdles:

Complex Measurement: Calculating a product or building’s true embodied carbon requires detailed “life cycle assessment” (LCA) across thousands of supply chain steps and emissions sources .
Data Transparency: Manufacturers may not know or disclose the full footprint of their materials, or can “game” reporting in the absence of robust standards.
Variation by Location & Process: Identical products may have different footprints depending on where and how they’re made, compounding regulatory complexity.

Quantifying Embodied Carbon: Life Cycle Assessment (LCA)

A life cycle assessment (LCA) is the standard method for quantifying embodied carbon and other environmental impacts across a product’s entire life—from “cradle to grave.” LCA results are often published as Environmental Product Declarations (EPDs), which serve as “nutrition labels” for environmental impacts. EPDs allow architects, builders, and procurement officials to compare carbon footprints when making decisions.

Case Study: Buildings and the Construction Sector

The debate over embodied carbon is particularly acute in construction, given buildings’ vast and durable impacts. As countries adopt stringent emissions targets, such as achieving net zero by 2050, it is clear that:

Switching to low-embodied carbon materials in construction is critical.
Concrete, steel, aluminum, insulation, and glass are among the most carbon-intensive materials.
The vast majority of a building’s embodied carbon is “spent” before anyone moves in, making it impossible to correct through later design.

Policy and Procurement: A New Frontier

Some governments and agencies are beginning to regulate embodied carbon by:

Requiring reporting of embodied carbon during procurement or permitting.
Mandating maximum carbon thresholds for new construction and public buildings.
Offering incentives and labels to favor lower-carbon products and construction techniques.
Developing databases and standards to benchmark best practices.

While still in early stages, examples include the Buy Clean initiatives in the United States, European Union’s carbon border adjustment plans, and large city-level requirements for public projects.

Extending Beyond Buildings: Embodied Carbon in Everyday Products

The principle of embodied carbon isn’t just relevant to buildings. It applies to everything humans manufacture, buy, and throw away:

Consumer electronics: Smartphones, laptops, televisions—energy use in manufacturing can be several times greater than what devices use over their lifetimes.
Appliances: Refrigerators, washing machines, and air conditioners are energy-intensive to produce.
Automobiles: Battery and chassis manufacturing account for a major slice of total emissions, especially for electric vehicles.
Clothing and Textiles: From cotton farming to dyeing, the clothing industry’s life cycle emissions are vast and largely “invisible” to end users.
Packaging and disposables: Plastic, paper, metals—single-use items generate carbon “up front,” regardless of what happens after use.

As efficiency standards slash the amount of energy products use in daily life, embodied carbon is on track to dominate the carbon impact of what we buy.

Why Regulate Embodied Carbon Across All Sectors?

Without broad standards or limits, high-carbon products can undercut progress made via energy efficiency.
Manufacturers often lack incentive to innovate in low-carbon processes if regulation applies only to one sector.
Public disclosure and benchmarks build consumer and industry awareness, improving accountability.

Moving Forward: Pathways and Policy Solutions

Reducing and eventually eliminating embodied carbon will require effort from government, industry, and consumers alike. Promising strategies and next steps include:

Update procurement rules to favor low-carbon materials and products, especially in public projects.
Expand mandatory reporting, requiring EPDs or whole-life carbon assessment for new buildings and major products.
Set measurable carbon intensity limits for carbon-intensive materials (concrete, steel, aluminum, etc.).
Support research and adoption of low-carbon manufacturing techniques (e.g., carbon-cured concrete, recycled metals).
Encourage reuse and recycling to reduce the need for virgin materials.
Educate companies and consumers about embodied carbon, empowering low-carbon purchasing choices.

Collaborative Standards

Developing and enforcing robust measurement and reporting standards—international, national, and industrial—is essential. Projects like the World Green Building Council, Carbon Leadership Forum, and Buy Clean are working to harmonize definitions and methodologies for maximum impact.

Frequently Asked Questions (FAQ)

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

A: Operational carbon refers to emissions from energy used in operating buildings or products (such as heating, lighting, or charging), while embodied carbon is the emissions created during the extraction, production, and delivery of materials, as well as during their construction and disposal phases.

Q: Why does embodied carbon matter if operational emissions are larger?

A: Embodied carbon is increasingly important as grids decarbonize and efficiency improves. In new construction and many products, it can now equal or exceed operational emissions—so tackling it is vital for deep carbon reductions.

Q: How can embodied carbon be measured?

A: Through life cycle assessment (LCA), which quantifies emissions across extraction, production, shipping, use, and end-of-life stages. Results are often published in Environmental Product Declarations (EPDs) for comparison and accountability.

Q: What are examples of policies to reduce embodied carbon?

A: Examples include mandatory reporting for new buildings, “Buy Clean” programs that specify maximum emissions for public procurement, and tax credits or incentives for verified low-carbon materials.

Q: Is consumer action important?

A: Consumer demand for low-carbon products drives corporate investment in cleaner manufacturing and helps reinforce policy efforts—making everyday choices an important part of the solution.

The Road Ahead: Embracing Systemic Change

Regulating embodied carbon across every product and building type is one of the most powerful—and necessary—steps for meaningful climate action. Comprehensive standards, increased transparency, and coordinated public policies are needed to steer markets and innovation. By recognizing that carbon is embedded in everything we make, use, and discard, policymakers, industry, and individuals can collaborate to push for effective, enforceable limits and accountability at every phase.

The clock is ticking. Tackling embodied carbon is not just about better buildings or greener gadgets; it’s about reshaping the global economy to work with the Earth’s climate limits—and securing a stable future for generations to come.

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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