We responded to the consultation on growing the market for low carbon industrial products, highlighting the importance of adopting a whole-life cycle approach to carbon assessment, aligned with existing standards such as EN 15804. While embodied carbon is central, we stressed that other environmental impacts such as resource depletion, water use, and health considerations should also be included to avoid unintended consequences.
We supported the voluntary introduction of the Embodied Emissions Reporting Framework (EERF) in the short term, with a transition to mandatory reporting in the longer term to ensure a level playing field. We noted the benefits of Environmental Product Declarations (EPDs), while identifying barriers such as cost, data gaps for SMEs and reused products, and verifier shortages. A consistent methodology, based on existing European standards, was strongly endorsed.
We expressed caution about benchmarking tools and product classification systems, emphasising the difficulty of making direct product comparisons across materials. We recommended alignment with whole life carbon assessments and endorsed circular economy principles, particularly reuse and reclaimed materials.
Finally, we welcomed government leadership through procurement policies, supporting voluntary guidance evolving into mandatory standards within the Government Buying Standards. We also highlighted opportunities for expansion to other construction-related sectors and alignment with EU initiatives, such as Digital Product Passports, to avoid regulatory divergence.