Insight

By Joanna Whitear and Rachael Entwistle, ESG directors at Black Cat Building Consultancy

The Energy Performance of Buildings Directive (EPBD) underwent a major update in 2024, with the revision going beyond energy efficiency – aiming for comprehensive decarbonisation across the entire building lifecycle. But what are the directive’s implications and why should all European businesses – including those in the UK – be treating carbon as a cost factor?

Transitioning to a low carbon future is essential in the attempt to address climate change. The construction and infrastructure sectors are responsible for 57% of global annual carbon emissions. Sustainability in the built environment encompasses all stages of a building’s lifecycle, from raw material extraction, manufacturing products, operation, right through to ‘end of life’ disposal. 

Environmental Product Declarations (EPDs) provide vital data on the whole life carbon of a product and quantifiably demonstrate the environmental impact of a product. EPDs are recognised within sustainability certification schemes including BREEAM, LEED, DGNB and Green Star. They are an important component of calculating the whole life carbon of built assets, which are being increasingly required by some clients and authorities, keen to drive down the carbon footprint of projects and developments.

Decarbonising buildings and infrastructure, with particular focus on whole life carbon emissions, presents a significant challenge. It requires collaboration, innovation and informed decision making based on accurate, shared data. With this in mind, the focus on embodied and lifecycle carbon emissions has intensified and EPDs have emerged as an essential tool for providing transparency and quantification of impacts. Standardising EPD carbon assessments will be key to driving collective decarbonisation.

The EPBD revision upgraded the existing regulatory framework, initially agreed in 2018, to reflect higher climate ambition, coupled with social action, providing the Member States with the flexibility needed to take into account the differences in the building stock across Europe. The revision goes beyond energy efficiency, aiming for comprehensive decarbonisation across the entire building lifecycle. It now requires
whole lifecycle assessments for large buildings, such as those larger than 1,000m² by 2028, with the mandate extending to all commercial buildings by 2030.

However, despite the UK’s exit from the European Union meaning it is no longer bound by the requirements of EU law, the UK government generally tends to align with the direction of travel. There is an industry proposed amendment to the UK Building Regulations 2010 via ‘Part Z’ that would require mandatory whole life carbon assessments to be completed by 2026 – for assets of more than 1,000m² or where more than ten dwellings are constructed. As well as this, by 2028 there will be the introduction of legal limits on upfront embodied carbon emissions with a view for these to tighten in the future. While this is currently only an industry proposal, there is already evidence of the growing acceptance of the need to undertake whole lifecycle assessments through local planning requirements.

The updated EPBD and proposed UK Building Regulations changes will facilitate the demand for transparent product data required for whole lifecycle assessments. A significant challenge faced by whole lifecycle assessment professionals is the lack of reliable data from suppliers, as well as the absence of mandatory standardised methodology and an effective centralised national database. 

Currently, assessors use diverse methodologies, timeframes and scopes, often relying on inconsistent data. This makes it difficult to compare assessments across projects and complicates the process of making meaningful environmental evaluations. This issue is compounded by a lack of rigour in how developers approach whole lifecycle assessments. Many developers simply request a simplified carbon footprint figure, often expressed per square metre, without fully accounting for the complex factors behind that number.

However, the 2024 update to the RICS ‘Whole Life Carbon Assessment for the Built Environment’ has significantly expanded on the level of detail provided. It now includes new data capture templates and incorporates infrastructure which was a significant omission from the initial version. While there is no current lever to enforce the use of this assessment standard, it is a step in the right direction. Combined with the recent launch of the UK Net Zero Carbon Buildings Standard, which itself references the RICS whole lifecycle assessment, there is a distinct push within the UK towards whole lifecycle assessment and net zero buildings, even in the absence of specific legislation. 

While EPDs are considered the gold standard for product transparency in compiling a whole lifecycle assessment, several key barriers limit their broader adoption, including time and budget constraints. Developing an EPD requires both significant time and financial investment. The process can take up to a year to complete which, combined with the associated costs and resource requirements, can deter smaller companies from initiating the process. Given the significant social benefits smaller enterprises provide, this barrier to undertaking EPDs in such companies is itself against the principles of sustainability.

In addition there is also a shortage of qualified Life Cycle Assessments (LCA) experts, consultants and verifiers with the necessary skills to analyse environmental data in-line with standards such as EN 15804. This shortage leads to long waiting times for EPD development. For smaller organisations, the complexity of data collection and the EPD development process can be overwhelming, further hindering adoption.

Furthermore, organisations with large or varied product lines face additional challenges in producing and updating EPDs. Frequent changes in product mixes require ongoing updates to EPDs, making the process time-consuming and resource intensive. These challenges must be addressed to improve the adoption and effectiveness of EPDs, allowing for more accurate and consistent carbon footprint reporting across the industry.

Many may dismiss whole lifecycle assessments and EPDs as ‘another green thing a client has asked for’ but this is not going to go away. While legislation may lag behind currently – it will ultimately catch up and the earlier adopters will no doubt reap the rewards versus those who will need to play catch up. 

Practical solutions to address these challenges

Current methods for carbon footprint disclosure are proving too slow and cumbersome to keep up with the pace of change needed for decarbonising the built environment. To meet these decarbonisation goals, we must streamline our approach to carbon reporting.

One key solution being advocated by industry professionals is the introduction of national default carbon values. These values would establish a baseline carbon footprint for products, unless developers can prove their product emissions are lower. Implementing these defaults would simplify whole lifecycle assessments, especially during the early design phase when changes can have the most significant positive impact, making the process faster, more efficient and effective. 

Manufacturers need to understand the benefits in developing EPDs for their products – it could be a unique selling point to distinguish from a crowd of competitors. Developers and designers should also be proactive in requesting EPDs from suppliers – if the demand for EPDs grows and developers and designers begin to shun manufacturers who cannot meet their EPD needs, the suppliers will be forced to react to avoid becoming obsolete. This would allow products with lower carbon impacts, as evidenced by their EPDs, to stand out against industry defaults or competitors, enhancing their marketability. 

It is becoming increasingly clear that while upfront material and product capital costs for ‘environmentally friendly’ options may be higher than their ‘standard’ counterparts, the use of whole lifecycle assessment calculations helps to highlight the cost impacts over the broader asset lifespan. This can often result in reduced operational costs, maintenance and replacement costs, as well as ‘end of life’ disposal, or reuse/recycling, which ultimately makes them more financially attractive than the ‘standard’ options. There needs to be a marked change in emphasis on the upfront capital costs versus whole life costs and carbon. Having the ability to present these options to a client is a clear distinguishable skill that should not be overlooked. As the demand for this grows, it will strengthen the case even further for expansion beyond EPDs.  

While EPDs offer comprehensive environmental data, they often exceed the immediate needs of many users, who typically seek reliable and comparable carbon information. The process of over producing data can discourage organisations from starting, as it involves significant time, financial and resource investments. 

To overcome this, we need to remove the perceived barriers for smaller organisations to enter the carbon transparency space, allowing them to begin the process without waiting for full EPD certification – focusing on improvement over time. This could start with a company adapting generic LCA data to estimate its products’ carbon impacts, guided by accessible training and free tools. This will provide a high-level of understanding about a company’s impact and establish the context for more detailed assessments. Over time, this could evolve to full product carbon footprint and eventually eco-label certification, whilst demonstrating and reporting  year-on-year product level carbon reduction. 

Furthermore, incentivising and expanding access to EPD services and promoting government funding and industry programmes would help accelerate the process while maintaining data integrity.