Trend analysis: Embodied carbon measurement and reduction — regulatory momentum and market signals

Why It Matters

Embodied carbon from construction materials and processes accounts for approximately 11 percent of global greenhouse gas emissions, yet until recently it has received a fraction of the policy attention directed at operational energy (UNEP, 2024). As buildings become more energy efficient, the relative share of embodied carbon in whole-life emissions grows. In a typical new net-zero operational building, embodied carbon can represent 50 to 70 percent of total lifecycle emissions over a 60-year lifespan (World Green Building Council, 2025). This shift in proportional impact has triggered a wave of regulatory and market activity that sustainability professionals can no longer afford to treat as a secondary concern.

The numbers are stark. The global construction sector consumes approximately 40 billion tonnes of raw materials each year, and producing cement alone accounts for roughly 8 percent of worldwide CO₂ emissions (Global Alliance for Buildings and Construction, 2024). Against this backdrop, regulators in the EU, North America, and parts of Asia are introducing mandatory whole-life carbon assessments, procurement limits, and disclosure requirements. The EU Level(s) framework, originally voluntary, is now referenced in binding legislation including the recast EPBD and the proposed Construction Products Regulation revision. In the United States, Buy Clean policies have expanded from California to 12 states by early 2026, with the federal Buy Clean Task Force setting Global Warming Potential (GWP) limits for steel, concrete, flat glass, and asphalt used in federally funded projects (White House, 2025).

For developers, material suppliers, contractors, and investors, understanding where embodied carbon regulation is heading is essential for strategic positioning. Those who invest early in measurement capabilities, low-carbon material sourcing, and supply chain transparency will capture value; those who wait risk stranded assets, cost penalties, and loss of market access.

Key Concepts

Embodied carbon encompasses all greenhouse gas emissions associated with a building's materials and construction, from raw material extraction and manufacturing through transportation, on-site construction, maintenance, and end-of-life demolition or recycling. It is typically expressed in kilograms of CO₂ equivalent per square meter (kgCO₂e/m²) and assessed across lifecycle stages A1 through A5 (product and construction), B (use-stage replacements), and C (end-of-life) as defined by EN 15978 and ISO 21930.

Whole-life carbon assessment (WLCA) evaluates both operational and embodied carbon over the full building lifespan. RICS published its updated Professional Standard on WLCA in 2023, establishing a consistent methodology now adopted by over 30 national green building councils. The standard requires practitioners to report lifecycle stages separately and disclose data quality scores, improving comparability across projects (RICS, 2023).

Environmental Product Declarations (EPDs) are standardized, third-party-verified documents that report the environmental impact of a specific construction product. EPD availability has expanded dramatically: the EC3 database maintained by Building Transparency contained over 180,000 EPDs by late 2025, covering concrete, steel, insulation, timber, and dozens of other material categories (Building Transparency, 2025). EPD availability is a prerequisite for meaningful embodied carbon benchmarking and procurement.

The EU Level(s) framework provides a common language for assessing building sustainability across six macro-objectives, with Indicator 1.2 specifically addressing life cycle GWP. Originally published as a voluntary reporting tool in 2020, Level(s) is now embedded in the recast EPBD, which requires member states to introduce whole-life carbon reporting for new buildings above a certain size threshold from 2028 and to set national limits from 2030 (European Commission, 2024).

Buy Clean policies set maximum allowable GWP values for specified construction materials used in public procurement. California's Buy Clean California Act, the first in the US, was enacted in 2017 and has since been expanded. The federal Buy Clean initiative, launched in 2022, covers four material categories in federally funded infrastructure and buildings. By February 2026, 12 US states have enacted or proposed similar legislation (Carbon Leadership Forum, 2026).

What's Working

EPD infrastructure has reached critical mass. Five years ago, finding product-specific EPDs for common construction materials was difficult. Today, the global EPD ecosystem includes over a dozen program operators and platforms such as EC3, EPD International, and IBU. In the concrete sector, over 60 percent of ready-mix producers in Western Europe and North America now publish product-specific EPDs, enabling apples-to-apples comparisons at the procurement stage (Building Transparency, 2025). This data infrastructure is foundational: without it, regulations and procurement requirements lack the measurement backbone to function.

Regulatory convergence is reducing fragmentation. The alignment between the EU Level(s) framework, EN 15978, ISO 21930, and national standards such as France's RE2020 is creating a more coherent global landscape. France's RE2020, which set the world's first mandatory embodied carbon limits for new residential buildings in 2022, has generated two years of compliance data that is informing other jurisdictions. The limit tightens progressively: from 640 kgCO₂e/m² in 2022 to 530 kgCO₂e/m² by 2025 for single-family homes (Ministry of Ecological Transition, France, 2024). Denmark and the Netherlands have introduced comparable requirements, and Sweden's mandatory climate declarations for new buildings took effect in 2022 with limits expected by 2027.

Developer-led procurement is accelerating supply chain response. Major developers and institutional owners are not waiting for regulation. Landsec in the UK requires all new developments to achieve embodied carbon intensity below 600 kgCO₂e/m² and targets 50 percent reduction from a 2020 baseline. Hines, a global real estate firm, has adopted embodied carbon budgets across its development pipeline and requires EPDs for all structural and envelope materials. Skanska has published internal carbon budgets for projects since 2015, driving innovation in low-carbon concrete mixes and timber-hybrid structures (Skanska, 2025). These demand signals create market pull for material producers to invest in decarbonization.

Low-carbon material alternatives are scaling. Supplementary cementitious materials (SCite such as ground granulated blast furnace slag and calcined clay) can reduce concrete embodied carbon by 30 to 50 percent without compromising structural performance. Mass timber construction, using cross-laminated timber (CLT) and glulam, has expanded from niche applications to mid-rise and tall buildings, with over 1,700 mass timber projects completed or under construction globally by 2025 (WoodWorks, 2025). Green steel produced via hydrogen direct reduction is reaching commercial scale, with SSAB, H2 Green Steel, and ArcelorMittal planning facilities with combined capacity exceeding 10 million tonnes per year by 2030.

Digital tools are reducing measurement friction. Software platforms including One Click LCA, Tally, and the open-source EC3 tool have lowered the skill and time barriers to conducting whole-life carbon assessments. One Click LCA reports that its platform was used on over 40,000 building projects globally in 2025, up from 25,000 in 2023 (One Click LCA, 2025). Integration with BIM workflows allows designers to evaluate material substitution scenarios in real time, shifting embodied carbon from a compliance exercise to a design optimization parameter.

What's Not Working

Data gaps persist outside Western Europe and North America. EPD coverage in emerging markets remains sparse. In regions where most new construction is occurring, including South and Southeast Asia, Sub-Saharan Africa, and Latin America, product-specific EPDs are rare, and generic data often overstates or understates actual impacts by 30 percent or more (WGBC, 2025). Without representative data, regulations and benchmarks developed in Europe risk being irrelevant or counterproductive in high-growth markets.

Scope 3 complexity hampers supply chain transparency. For material manufacturers, Scope 3 emissions from upstream raw material extraction, transportation, and energy inputs are often the largest share of embodied carbon but the hardest to measure accurately. Many EPDs rely on industry-average background data for upstream inputs, masking the performance difference between a cement plant powered by renewable energy and one burning petroleum coke.

Cost premiums for low-carbon materials remain a barrier. While green premiums for low-carbon concrete have narrowed to 5 to 15 percent in many markets, green steel carries premiums of 20 to 40 percent over conventional production (McKinsey, 2025). Mass timber is cost-competitive in some building typologies but faces supply constraints and regulatory barriers in markets where timber high-rise codes are still evolving. Without demand aggregation or policy incentives, project-level decisions often default to conventional materials.

Fragmented regulatory timelines create uncertainty. Although the direction of travel is clear, the specific timeline, threshold, and enforcement mechanisms for embodied carbon regulation vary widely across jurisdictions. EU member states have until 2028 to introduce reporting requirements under the recast EPBD, but limit-setting is not mandatory until 2030 at the earliest. This multi-year runway allows laggards to defer action and reduces the urgency signal for supply chains.

Professional capacity lags market need. Conducting a credible whole-life carbon assessment requires skills in lifecycle assessment methodology, material science, and software tools that many design and construction firms do not yet possess. Training programs are expanding but remain concentrated in the UK, Scandinavia, and North America. In many markets, WLCA is still outsourced to specialist consultants, adding cost and disconnecting the assessment from design decision-making.

Key Players

Established Leaders

• One Click LCA — Helsinki-based lifecycle assessment platform used on 40,000+ projects globally. Integrates with major BIM software.
• Skanska — Swedish multinational contractor with internal embodied carbon budgets and a portfolio of low-carbon concrete and mass timber projects.
• Holcim — Global cement and building materials producer investing heavily in supplementary cementitious materials, carbon capture, and circular construction.
• Saint-Gobain — Major building materials supplier publishing EPDs across its full product range and investing in low-carbon manufacturing processes.
• ArcelorMittal — Largest global steel producer, operating XCarb recycled and renewable steel program and planning hydrogen DRI facilities.

Emerging Startups

• Building Transparency — Non-profit operating the EC3 (Embodied Carbon in Construction Calculator) open-access database with 180,000+ EPDs.
• Brimstone — California startup producing carbon-negative Portland cement from calcium silicate rock instead of limestone.
• CarbonCure Technologies — Canadian company injecting captured CO₂ into ready-mix concrete during production, reducing embodied carbon by 5 to 8 percent per batch.
• Material Mapper — UK startup providing real-time material tracking and embodied carbon reporting for construction sites.

Key Investors/Funders

• Breakthrough Energy Ventures — Investing in low-carbon cement, steel, and construction material startups including Brimstone and CarbonCure.
• IKEA Foundation — Funding embodied carbon research and sustainable construction in emerging markets.
• Laudes Foundation — Supporting the Carbon Leadership Forum and industry-wide embodied carbon advocacy and standard-setting.
• European Investment Bank (EIB) — Financing green building and low-carbon material manufacturing projects across Europe.

Examples

France's RE2020 in practice. France became the first country to set mandatory embodied carbon limits for new residential construction in January 2022. Two years of compliance data show that the policy has driven measurable changes in material selection. The share of new residential projects using low-carbon concrete mixes (incorporating slag, fly ash, or calcined clay) increased from 18 percent in 2021 to 47 percent in 2024. Mass timber framing in multi-family housing grew from 3 percent to 11 percent of new starts over the same period (Ministry of Ecological Transition, France, 2024). The progressive tightening schedule gives industry a clear trajectory while allowing time for supply chain adaptation.

Landsec's Forge development, London. British Land and Landsec's Forge project in Southwark achieved embodied carbon of 505 kgCO₂e/m², approximately 25 percent below the RIBA 2030 Climate Challenge target. The project used a kit-of-parts structural system with standardized steel connections, enabling 95 percent of the steel structure to be fabricated off-site and assembled without wet trades. The design team used One Click LCA throughout the design process, running over 200 material substitution scenarios to optimize the structural and facade carbon footprint (Landsec, 2025).

Federal Buy Clean in the United States. The GSA (General Services Administration) began enforcing maximum GWP limits for structural steel, concrete, flat glass, and asphalt in federally funded projects from October 2024. Early implementation data shows that 78 percent of compliant bids in the first six months were submitted using EPDs already within the required thresholds, indicating that the supply chain was better prepared than critics anticipated (GSA, 2025). The policy covers approximately $45 billion in annual federal construction spending and is expected to drive EPD adoption among smaller producers who previously lacked incentive to measure and disclose.

Skanska's timber-hybrid projects in Scandinavia. Skanska has completed multiple timber-hybrid commercial buildings in Sweden and Norway, including the Sara Cultural Centre in Skellefteå, one of the tallest timber buildings in the world at 75 meters. The project used CLT and glulam for the primary structure, reducing embodied carbon by approximately 40 percent compared with a conventional concrete and steel alternative. Skanska reports that lessons from its timber portfolio are being applied to projects across its European and US operations (Skanska, 2025).

Action Checklist

• Establish your embodied carbon baseline. Conduct whole-life carbon assessments for current and pipeline projects using standardized methodologies (EN 15978/ISO 21930) and credible tools. Without a baseline, target-setting and progress tracking are impossible.
• Require EPDs in procurement. Specify product-specific or manufacturer-specific EPDs for all major structural and envelope materials. Use the EC3 database or equivalent platforms to compare products and set maximum GWP thresholds.
• Set progressive reduction targets. Adopt internal embodied carbon budgets that tighten over time, aligned with frameworks such as the RIBA 2030 Climate Challenge, LETI targets, or the Carbon Leadership Forum's policy recommendations.
• Explore low-carbon material substitution. Evaluate supplementary cementitious materials, mass timber, recycled steel, and carbon-injected concrete for each project. Engage suppliers early in the design process to identify available low-carbon options.
• Track regulatory developments. Monitor Level(s) transposition timelines, Buy Clean expansion, and national embodied carbon limit announcements. Build compliance scenarios into project risk assessments.
• Invest in team capability. Train design, engineering, and procurement staff in lifecycle assessment methods and tools. Embed WLCA into standard design workflows rather than treating it as a compliance afterthought.
• Engage the supply chain. Communicate your embodied carbon expectations to material suppliers, contractors, and subcontractors. Provide clear timelines and support smaller suppliers in developing EPDs and measurement capabilities.

FAQ

What is the difference between embodied and operational carbon? Operational carbon refers to emissions from energy used to heat, cool, light, and power a building during its use phase. Embodied carbon covers all emissions from material extraction, manufacturing, transportation, construction, maintenance, and end-of-life processes. As operational carbon declines through efficiency measures and grid decarbonization, embodied carbon becomes the dominant share of whole-life emissions, sometimes exceeding 50 percent for high-performance new buildings.

How reliable are current embodied carbon measurements? Measurement reliability depends heavily on data quality. Product-specific EPDs based on factory-level data are highly reliable for the manufacturing stage (A1-A3). However, emissions from transportation (A4), construction processes (A5), and end-of-life (C1-C4) often rely on assumptions and generic data, introducing uncertainty of 10 to 30 percent. The industry is improving through better data infrastructure, standardized calculation methods, and digital tools that link design models to EPD databases.

Which materials offer the largest embodied carbon reduction opportunities? Concrete and steel together account for the majority of embodied carbon in most building types. For concrete, using supplementary cementitious materials like slag, fly ash, or calcined clay can reduce embodied carbon by 30 to 50 percent. For steel, specifying high-recycled-content electric arc furnace (EAF) steel rather than primary blast furnace steel can cut embodied carbon by 50 to 75 percent. Substituting mass timber for concrete or steel in appropriate structural applications can deliver reductions of 30 to 60 percent while also sequestering biogenic carbon.

Are Buy Clean policies spreading beyond the US and EU? Yes. Canada introduced federal green procurement criteria for construction materials in 2024, and Japan and South Korea have incorporated embodied carbon considerations into public procurement guidelines. Australia's National Construction Code has added optional pathways for whole-life carbon reporting, with mandatory requirements expected by 2028. The direction of travel is global, driven by Paris Agreement commitments and the growing recognition that materials sector emissions cannot be ignored.

How do embodied carbon requirements affect project costs? The cost impact varies by project type, location, and ambition level. Studies in the UK and Scandinavia suggest that achieving 20 to 30 percent embodied carbon reductions adds 0 to 2 percent to total construction costs when optimized during early design stages (LETI, 2024). Deeper reductions of 40 percent or more may require premium materials or structural redesign, adding 2 to 5 percent. However, these costs are falling as low-carbon material markets mature and will decline further as regulations scale demand.

Sources

• UNEP. (2024). 2024 Global Status Report for Buildings and Construction. United Nations Environment Programme.
• Global Alliance for Buildings and Construction. (2024). Global Construction Materials Consumption and Emissions Report. GlobalABC.
• World Green Building Council. (2025). Bringing Embodied Carbon Upfront: Advancing Net Zero Whole Life Carbon. WGBC.
• European Commission. (2024). Recast Energy Performance of Buildings Directive (EPBD): Whole-Life Carbon Provisions. Official Journal of the European Union.
• RICS. (2023). Whole Life Carbon Assessment for the Built Environment: Professional Standard (2nd Edition). Royal Institution of Chartered Surveyors.
• Building Transparency. (2025). EC3 Database Annual Report: EPD Coverage and User Growth. Building Transparency.
• Ministry of Ecological Transition, France. (2024). RE2020 Implementation Review: Two-Year Compliance Data and Material Trends. République Française.
• Carbon Leadership Forum. (2026). Buy Clean State Policy Tracker: February 2026 Update. University of Washington.
• White House. (2025). Federal Buy Clean Initiative: Progress Report and Material Category Expansion. Executive Office of the President.
• One Click LCA. (2025). Annual Impact Report: Platform Adoption and Project Coverage. One Click LCA.
• WoodWorks. (2025). Mass Timber Project Database: Global Inventory Update. WoodWorks.
• McKinsey. (2025). The Green Premium Tracker: Construction Materials Edition. McKinsey & Company.
• Skanska. (2025). Climate Action Report: Embodied Carbon Reduction Across Operations. Skanska AB.
• Landsec. (2025). Forge Project: Embodied Carbon Case Study. Landsec.
• GSA. (2025). Buy Clean Implementation: Six-Month Compliance Review. U.S. General Services Administration.
• LETI. (2024). Embodied Carbon Target Guidance for New Buildings. London Energy Transformation Initiative.