Preparing for the Construction Products Regulation and other directives in UK construction manufacturing

"There’s no doubt about it, the government is looking at regulating for embodied carbon. We’ve got a new government, there’s quite a lot for them to work through, but it is going to come. We look across the channel and there are so many countries that have introduced it, and Europe is basically mandating EPDs. We will just have to follow." — Simon Corbey, CEO at the Alliance for Sustainable Building Products

Why addressing embodied carbon should be a critical priority

Embodied carbon — the emissions associated with the production, transportation, and installation of building materials — accounts for a significant portion of the UK’s total greenhouse gas emissions. According to the WGBC, buildings are currently responsible for 39% of global energy related carbon emissions. Furthermore, in the UK, the UKGBC suggests that around 20% of the emissions from the built environment are embodied carbon emissions.

This figure underscores the urgent need for systemic change in construction manufacturing. The UK has committed to achieving net-zero carbon emissions by 2050, a goal that cannot be met without addressing embodied carbon in construction projects. The urgency of this task has been reinforced by global initiatives, such as the COP climate conferences and the EU Green Deal, which call for substantial reductions in carbon emissions across all sectors.

The regulatory landscape: Key developments to acknowledge

Several significant regulatory changes are shaping the construction manufacturing industry, both in the UK and across Europe. Understanding these developments is crucial for manufacturers who want to prepare effectively.

UK CBAM and its impact on manufacturers

A pivotal regulatory development on the horizon is the UK Carbon Border Adjustment Mechanism (CBAM). Set to align closely with the EU’s CBAM, the UK version aims to impose a carbon price on imported goods, including construction materials like steel, cement, aluminum, ceramics, and glass. This mechanism ensures that imports face the same carbon costs as domestically produced goods, preventing “carbon leakage” and leveling the playing field for UK manufacturers who adhere to strict sustainability regulations. For manufacturers, the UK CBAM means that accurate reporting of embodied carbon — and the use of environmental product declarations (EPDs) — will be essential not just for regulatory compliance, but also for maintaining competitiveness against international suppliers. Companies that fail to measure and manage their embodied carbon could face higher costs and reduced market access.

EU Ecodesign for Sustainable Products Regulation (ESPR)

Set to come into force in 2025, the ESPR will mandate stricter sustainability criteria for products sold within the European Union. This regulation will likely affect UK manufacturers, especially those who export to the EU.

The ESPR aims to ensure that products are more energy-efficient, durable, and recyclable, with clear documentation of their environmental impacts through Digital Product Passports (DPPs).

Net Zero Carbon Building Standard (NZCBS)

Launched in 2023, this standard provides a comprehensive framework for achieving net-zero carbon in building design, construction, and operation.

The NZCBS requires life-cycle assessments (LCAs) and emphasizes the use of EPDs to verify embodied carbon reductions through product-specific carbon data. Large contractors, developers, and real estate firms are increasingly adopting this standard, making it essential for manufacturers to align with its requirements to be considered.

Part Z proposal

The Part Z initiative advocates for the inclusion of mandatory embodied carbon assessments within UK building regulations. This proposal has received widespread support from industry bodies, including the Royal Institute of British Architects (RIBA) and the Alliance for Sustainable Building Products (ASBP).

If adopted, Part Z would require all new construction projects to quantify and report embodied carbon, driving even more demand for sustainability reporting credentials such as EPDs. While no specific timeline has been set, industry experts suggest that regulations could be implemented by 2026-2028.

International mandates

Countries like France, the Netherlands, and Sweden have already mandated embodied carbon reporting for new buildings. For example, in France, according to the new RE2020 (Réglementation Environnementale 2020) every building project must include a life-cycle assessment (LCA) and an EPD for each material used.

These international regulations create a ripple effect, influencing UK manufacturers who aim to remain competitive in the global market.

Bottom-up pressures: Market demand for transparency

In addition to regulatory pressures, the demand for transparency is growing among clients, specifiers, and contractors. This “bottom-up” pressure is driven by a shift in market expectations and procurement practices.

• Architects and specifiers are increasingly requiring EPDs for tender submissions. Without EPDs, manufacturers risk being excluded from high-value projects.
• Clients and developers are setting ambitious sustainability targets. For example, British Land and other major developers now conduct embodied carbon assessments for every project, making EPDs a prerequisite for product selection.
• Contractors are prioritizing low-carbon materials to meet project goals for BREEAM, LEED, and other certification schemes.

“We’re seeing more and more requests every day. When companies come to us, they often need EPDs urgently to avoid losing out on tenders or projects. The demand isn’t going away — if anything, it’s increasing.” - Thomas Mattinzioli, One Click LCA

The role of EPDs in regulatory compliance and market readiness

Environmental product declarations (EPDs) are a key tool for manufacturers to demonstrate compliance with regulations and meet market demands. An EPD is a third-party-verified document that provides detailed information about the environmental impacts of a product throughout its life-cycle.

"Changing nothing but simply using verified EPDs, we went from 628 to 507 kilograms of CO₂ per square metre. This shows the significant impact that verified EPDs can have." — Mark Walsh, Product Management and Development Engineer at Unilin

How EPDs help construction manufacturers

1. Regulatory compliance: Simply put, EPDs provide the transparency required by upcoming regulations like the ESPR, the revised EU CPR, and potential UK Part Z mandates. They ensure manufacturers are prepared for mandatory embodied carbon reporting.
2. Market access: Many large projects and public procurements now require EPDs. In countries like Norway and France, EPDs are already mandatory for public projects.
3. Credibility and transparency: EPDs combat greenwashing by providing verifiable claims of environmental performance. This builds trust with clients, specifiers, and end-users.
4. Operational insights: Conducting an LCA to produce an EPD helps manufacturers identify carbon hotspots and opportunities for improvement in their supply chain and production processes.

“Investing in EPDs shows that you believe in sustainability and transparency. It’s not just about compliance — it’s about positioning your company for the future.” - Simon Corbey, CEO at the Alliance for Sustainable Building Products

Practical strategies for manufacturers to prepare

To stay ahead of upcoming regulations and market demands, manufacturers should take the following steps:

1. Start your EPD journey
   • Adopt platforms like One Click LCA to streamline the process of creating EPDs. Access 250,000+ data points to drive sustainability projects and simplify the complexity of life-cycle assessments.
   • Conduct LCAs for key products to understand their environmental impacts and identify areas for improvement.
2. Upskill your workforce
   • Provide training for teams on EPD creation, life-cycle assessments, and sustainable manufacturing practices. One Click LCA Academy offers comprehensive courses to help manufacturers build in-house expertise.
3. Engage with industry initiatives
   • Participate in industry events and workshops hosted by organizations like the ASBP and RIBA to stay informed about regulatory developments and best practices.
4. Monitor the regulatory landscape
   • Track developments related to Part Z, the Net Zero Carbon Building Standard, and the ESPR. Engage with industry bodies and government consultations to stay ahead of changes.

Conclusion

The drive to reduce embodied carbon in construction manufacturing is no longer optional. With regulations on the horizon and market demand growing, EPDs are becoming essential for manufacturers who want to remain competitive and compliant. By investing in EPDs, upskilling your workforce, and staying engaged with industry developments, you can ensure your business is ready for the low-carbon future that lies ahead.

Now is the time to act — because the future of sustainable construction is already taking shape.

How One Click LCA can support your EPD journey

Navigating the complexities of embodied carbon regulations and market expectations can be challenging, but One Click LCA offers the tools and expertise to streamline your EPD journey. As the market-leading sustainability platform for the construction industry, One Click LCA provides a comprehensive suite of tools for conducting LCAs, generating EPDs, and ensuring compliance with evolving regulations. With the largest construction materials database available, manufacturers can quickly access accurate data, reducing the time and effort required for EPD creation. By leveraging One Click LCA’s tools, manufacturers can not only prepare for regulatory changes but also gain a competitive edge by demonstrating a commitment to transparency, sustainability, and innovation.

Find out more:

• How Sculptform uses product LCAs and EPDs to identify high carbon materials in their products
• How EPDs are shaping Saint-Gobain's strategy to reach carbon neutrality by 2050
• How EPDs help Ibstock understand embodied carbon of their products