Consultation response:

We asked the UK Government to introduce mandatory embodied carbon reporting for the construction sector, such as the EU are introducing. This would support the UK’s cement sectors investments in expanding low-carbon cement production and capitalise on the expected demand from the EU, helping safeguard the UK’s cement sector’s future. The advantages of mandatory rather than voluntary reporting include a creating a level playing field, standardised reporting methodology (which would aid benchmarking and clarity), and that it would give the construction sector a clear signal the UK Government treats embodied carbon as a serious climate priority, thereby encouraging firms to embed low-carbon choices early in the design process and contribute to the UK’s Net Zero agenda. Strategic policy is needed as the construction and the built environment is responsible for at least 25% of UK emissions. This is why UK industry is also calling on the Government to introduce mandatory reporting standards.

Our analysis of the UK Government outcome:

It is disappointing that the UK Government has decided to proceed with a voluntary embodied emissions reporting framework (EERF), and only committed to further consultation on making the EERF mandatory at a later stage. Reasons for proceeding on a voluntary basis may include that it avoids the need to agree the EERF with devolved governments of Scotland, Wales, and Northern Ireland. The UK Government also claims an initially voluntary introduction of EERF aims to encourage the immediate reporting of embodied emissions data and improve product comparisons, while minimising risks such as potential unintended consequences and costs to taxpayers and producers. The risk and unintended consequences are not explained. With this phased approach, producers able to meet reporting requirements could provide embodied emissions data as soon as available, while others would have time to prepare for the possibility of mandatory reporting in the future. It is not clear what incentive the voluntary approach gives to ‘first movers’ to take on the additional burden of EERF. We predict low industry uptake and very limited effectiveness in leveraging industrial decarbonisation markets.

The UK Government proposes guidance on the method of embodied emissions reporting as the first phase of the EERF, while also developing an IT system to simplify and reduce the costs of reporting, ensuring the embodied emissions data is more accessible and easier to compare. We are supportive of this, in principle, but believe the voluntary nature of the guidance means various methods to calculate embodied emissions will continue to be used and that, therefore, comparability will be constrained by limited uptake of voluntary reporting. We maintain that this range of methods will become embedded in the industry, which will create resistance to later measures by the Government to make one reporting method the mandatory one.

We are pleased to see the UK Government recommend the existing European standard EN 15804 for embodied lifecycle carbon reporting, which would ease trade with the rest of Europe and reduce duplication of competing standards.

In cement works, alternative fuels are increasingly used to replace traditional fossil fuels such as gas, oil, and coal burned to generate the 1,450c needed to generate clinker, a key part of cement. Alternative fuels are generally from waste products that would otherwise end up in landfill, but when burned sometimes generate more CO2 than traditional fossil fuels. This can disincentivise cement works switching to alternative fuels, even though it diverts waste products from landfill and reduces the localised environmental harms associated with fossil fuel extraction. The UK Government has rightly decided that embodied emissions reporting for products, including cement, should be gross CO2e emissions, but that producers can optionally also include net CO2e which deducts emissions from burning alternative, waste-derived fuels. In this way, producers can promote the benefits of making their products using alternative fuels, whilst also providing a transparent account of the gross emissions involved.

Consultation response:

Along with other consultees, CAN called on the UK Government to develop a definition of low carbon steel, cement, and concrete for the UK industry. This should be coupled with a clear banding system such as A-G scale of low to high carbon industrial products. This would help construction companies compare, for example, cement products to more easily select lower-carbon products with the confidence of a Government-endorsed standard.

Our analysis of the UK Government outcome:

Unfortunately, the UK Government has ignored the consultation majority by stating that it will not introduce a single cross-sector standard, instead relying on the existing patchwork of classifications by industry and international organisations. This was apparently prompted by some industry responders claiming a comparable rating system could obscure nuances. Furthermore, the Government inexplicably will not develop any carbon footprint classification for cement products, which are responsible for 9% of the UK’s emissions.

This response shows a disappointing adherence to consultees’ feedback, as well as a distinct lack of ambition towards supporting low-carbon markets within key carbon-intensive industries. Relying on the existing patchwork of standards will prevent carbon comparison between construction projects, reducing incentives for companies to select lower-carbon products. This is because existing standards vary in how they classify low carbon products and encourage organisations to set procurement commitments e.g. SteelZero, ConcreteZero, the First Movers Coalition, and the Construction Leadership Council (CLC). In 2023, gross construction new work output totalled £139 billion, with the private sector share over 2.5x the size of the public sector.

Consultation response:

Along with other consultees, CAN agreed with the UK Government that green public procurement can create the confidence of demand for low-carbon products that can incentivise industry to invest in decarbonisation technologies. Overall responders focused emphasised the need for both practical and clear guidance on how to go about procurement low-carbon products, as many in procurement teams lack the technical expertise to scrutinise the range of industry product classifications.

Our analysis of the UK Government outcome:

Rather than inventing an entirely new framework from scratch, the Government decided that new procurement guidance will directly endorse and integrate existing, industry-led standard models for material classification (such as the Low Emission Steel Standard (LESS) for steel, and benchmarks from the Lower Carbon Concrete Group for concrete). We are concerned that these material classifications for industry, by industry, and may therefore not have the same rigour as a classification designed by a government body – its more industry self-regulation that we’ve seen fail before. Furthermore, these industry standards will be embedded in the Ministry of Housing, Communities and Local Government’s (MHCLG) Construction Products Regulation, which sets whether a construction product can legally be sold or used on a UK building site. Given the overriding consultation response requesting clarity for non-technical staff, we are concerned that the decision to rely on the multiple existing industry classification would require training on multiple classification standards and that these are primarily made for technical construction consultants rather than public procurement staff.

We applaud the UK Government for its commitment to meeting level 3 of the Industrial Deep Decarbonisation Initiative (IDDI) Green Procurement Pledge, which it signed at COP28. This means the government will require the public procurement of low-carbon cement, concrete, and steel in public construction projects starting from 2030 onwards.

We support the UK Government’s effort to ensure inter-departmental alignment, otherwise known as the right hand talking to the left hand. The Department for Energy Security and Net Zero is mandating that these procurement rules directly complement the Ministry of Housing, Communities and Local Government’s Construction Products Regulation reforms and the upcoming Steel Strategy, ensuring public sector buyers have a single, unified standard for what constitutes a compliant "low-carbon" purchase

Consultation response:

Encouraging multiple approaches to decarbonisation, particularly in combination where compatible, is likely to drive the rapid and deep decarbonisation of industry being sought by the UK Government. However, not all pathways are equal and it is counter-productive not to encourage those most effective at reducing environmental harms. To do so would also create inconsistency between criterion 1 point 3 and 4. Technologies that drive greater efficiencies, using fewer materials through product design and waste reduction should be rewarded over abatement technologies such as carbon capture, utilisation, and storage (CCUS).

Our analysis of the UK Government outcome:

The UK Government has stuck to encouraging a broad range of decarbonisation approaches, including energy efficiency, resource efficiency, renewable energy, fuel switching, and CCUS, without favouring any specific production pathway. We hope that the high energy inputs and embodied emissions required to operate some decarbonisation technologies such as CCUS, is calculated into any corresponding reduction in site emissions. We also trust that the Government will be more nuanced than their statement suggests in supporting a hierarchy of abatement approaches and technologies that favours those that are proven, lowest impact, and reduce resource consumption.