National law
None in England; the Future Homes Standard covers operational carbon only.
Part Z is a proposal, not law.Construction · whole life carbon
Embodied carbon
Embodied carbon is the greenhouse gas from making, transporting, installing, maintaining and finally demolishing a building’s or structure’s materials.
No national law in England requires anyone to measure it.
London planning, National Highways, the water and energy regulators and central government contracts ask for it instead.
Definition
What is embodied carbon?
Every material-related emission across the life of an asset: modules A0–A5, B1–B5 and C1–C4 in the RICS standard.
The life-cycle modules come from the European standards and are grouped by RICS into five boundaries (RICS §2.1).
| Boundary | Modules | What it covers |
|---|---|---|
| Upfront carbon | A0–A5 | Pre-construction work, products, transport and construction, up to practical completion |
| Embodied carbon | A0–A5, B1–B5, C1–C4 | All material-related impacts: upfront, plus maintenance, repair, replacement, refurbishment and end of life |
| Operational carbon | B6–B7 | Energy and water used to run the asset |
| User carbon | B8 | User activities not counted elsewhere |
| Whole life carbon | A, B and C | All of the above over the reference study period, 60 years for a building; module D is reported separately |
“Embodied carbon equals A1–A3” is a common error: under RICS, A1–A3 is only the product stage.
Name the source whenever you give a boundary, because a water company’s “embodied carbon” commitment may mean A1–A5 alone (Ofwat).
Status
Is measuring embodied carbon a legal requirement in the UK?
Not nationally in England: the requirements come from planning in London and from clients’ contracts.
On 3 March 2026 the Government told MPs it does “not agree with mandating whole life carbon assessments at this time” (HC 1785 ¶82).
The national foreword to BS EN 15978:2026 says the same: the UK has no mandatory national regulations or methodologies for whole life carbon assessment of buildings (BSI).
The Future Homes and Buildings Standard cuts operational carbon by 75% against 2013 standards, from 24 March 2027; it does not regulate embodied carbon (SI 2026/335).
Part Z, an industry-drafted amendment to the Building Regulations, would mandate assessment and later set limits, but it has not been adopted (Part Z).
One project
What does this mean for one London office?
A scheme referable to the Mayor must submit a whole life-cycle carbon assessment twice, at application and before occupation.
It is an illustration, not a real scheme.
The same building outside London, for a private client, would owe no assessment unless the contract asked for one.
London’s requirement is planning policy, applied by the planning authority to the application, not a duty on the company (London Plan SI 2 F).
- 1
Is there a national legal duty?
No: nothing in English law requires the assessment (HC 1785 ¶82).
- 2
Does planning ask for it?
Yes: a scheme referable to the Mayor submits a whole life-cycle carbon assessment at application and again before occupation (GLA guidance).
- 3
Which method?
The GLA’s own guidance and template, which rest on the RICS first edition, even though RICS members otherwise use the second (GLA).
- 4
Does the Future Homes Standard help?
Not with this: it regulates operational carbon only (HCWS1445).
- 5
What is reported?
Modules A to C over 60 years, with module D separate (RICS §2.1, §4.2).
Who asks
Who asks for embodied carbon figures?
Six bodies, none of them through national law.
The Construction Playbook applies to central government on a comply-or-explain basis, and its guidance warns that making a particular standard a tender condition “is likely not to be justifiable” (Guidance Note ¶3.6.3).
National Highways’ deadline has passed; its follow-up after 2025 is not recorded here.
How a contractor meets those clients’ process requirements is on PAS 2080.
Who asksExplore
Who asks
Greater London Authority
Referable schemes submit a whole life-cycle carbon assessment.
Who asks
National Highways
Large and medium suppliers: a PAS 2080-verified carbon management system by the end of 2025.
Who asks
Ofwat
Expects frameworks such as PAS 2080; named companies report capital carbon on A1–A5.
Who asks
Ofgem
Networks report embodied carbon in line with industry standards, PAS 2080 the example.
Who asks
Cabinet Office
Bids come with a whole life carbon assessment where proportionate.
The methods
Which standard measures embodied carbon?
BS EN 15978:2026 for buildings, BS EN 17472 for civil works, EN 15804+A2 for the products, and RICS for its members.
| Standard | What it is for | Status |
|---|---|---|
| BS EN 15978:2026 | Life-cycle assessment of a building | Current since 31 July 2026; the 2011 edition is withdrawn (BSI) |
| BS EN 17472:2022 | Sustainability assessment of civil engineering works; not for buildings | Published 31 March 2022 (BSI) |
| EN 15804+A2 | Environmental product declarations for construction products | The version in force is +A2/AC:2021 (BSI) |
| RICS whole life carbon, 2nd edition | How a RICS member carries out and reports an assessment | Binding on members since 1 July 2024 (RICS) |
| PAS 2080:2023 | Managing whole life carbon through a project; not a calculation method | Voluntary; points to the standards above (Clause 7.1.3) |
Much guidance in circulation, including PAS 2080’s bibliography, was written against the 2011 edition of EN 15978: it is behind, not wrong.
Product data usually comes from environmental product declarations, which stay voluntary under the Government’s construction products proposals (White Paper ¶10.3.6).
The product-level standards are compared on life-cycle assessment and product standards.
A voluntary limit
What is the UK Net Zero Carbon Buildings Standard?
A voluntary, industry-led standard that sets pass-or-fail limits on upfront carbon and energy use, published in March 2026.
It was led by eight founding organisations, BBP, BRE, CIBSE, IStructE, LETI, RIBA, RICS and UKGBC, and follows the RICS whole life carbon method (NZCBS).
Its limits depend on sector, works type and the year work starts, so there is no single “UK NZCBS limit”, and offsets cannot be used to meet them.
It is not law: the Department for Education recommends certification to it on its own framework, which is a client’s choice, not a national rule (DfE).
DfE measures on gross internal floor area (GIFA) and the Standard on GIA, so the two limits are not like for like.
UK NZCBSExplore
UK NZCBS
Version 1
Published March 2026; the current text is Version 1, Rev 1 (April 2026).
UK NZCBS
Verification
Launched July 2026 with Bureau Veritas; only verified buildings may say “Net Zero Carbon Aligned”.
UK NZCBS
Upfront carbon, offices
Whole office building, new works starting in 2026: 765 kgCO2e/m² GIA.
UK NZCBS
DfE schools
DfE’s own CF25 limit: 550 kgCO2e/m² GIFA for modules A1–A5, a contract term.
Your project
What applies to your project, and what do your figures add up to?
Choose where and for whom; then enter your module totals to see them in RICS’s boundaries.
The check applies no benchmark, because none is set in law.
Enter whatever modules your assessment covers; a blank module counts as not assessed, not as zero carbon.
The share of upfront carbon in the embodied total shows how much is fixed before the building opens.
Embodied carbon · your project
Choose where the project is and who it is for.
Your figures, in RICS boundaries (kgCO2e)
Enter the module totals from your assessment; leave a module blank if you have not assessed it.
Boundaries: RICS Whole life carbon assessment, 2nd edition, §2.1 (A0, B8 and module D are left out here; RICS reports D separately). Rules: London Plan 2021 SI 2 F; National Highways net zero plan, 2025 update; Ofwat Final Climate Change Principles; Ofgem RIIO-3; the Construction Playbook.
No benchmark is applied: none is set in law. Nothing you enter leaves your browser.
What is changing
Will embodied carbon become mandatory?
Not on any published timetable: the 2023 consultation was never held, and the 2026 answer was no.
- 26 May 202201
MPs recommend mandatory assessments
The Environmental Audit Committee asked for regulations by December 2023 for buildings over 1,000 m² or more than 10 dwellings. - 30 September 202202
- 3 March 202603
Government keeps a voluntary approach
And is not considering adopting the RICS method as the UK standard. - 20 May 202604
Construction products consultation closes
The White Paper keeps EPDs voluntary for products outside designated standards. - 31 July 202605
- 24 March 202706
- Early 202807
The Government says it is still assessing the evidence on measuring and reducing embodied carbon in new buildings (HC 1785 ¶84).
This page covers England; building rules are devolved, and the Scottish, Welsh and Northern Irish positions are not recorded here.
Order of work
Where should a project start?
Find who is asking, fix the method and boundary, then collect product data early.
The earliest decisions carry the most carbon, which is why PAS 2080 puts “avoid” first in its hierarchy (Clause 4.3).
A company reporting its own footprint counts purchased construction in Scope 3; see Scope 3 emissions.
- 1
List who is asking
Planning authority, client and any regulator, and what each wants.
- 2
Fix the method and boundary
BS EN 15978:2026 or EN 17472, and which modules: upfront or whole life.
- 3
Choose the assessor
A RICS member is bound by the 2nd edition standard.
- 4
Collect product data
EPDs under EN 15804+A2 where suppliers have them.
- 5
Assess at each stage
Design options first, as-built last, on the same method.
BS EN 15978:2026 · RICS · GLA
Embodied carbon is unregulated in English law but not unasked for, so the work starts with who is asking and what boundary they mean.
- A0–A5, B1–B5, C1–C4
Embodied carbon is materials across the whole life, not just construction
Upfront carbon is only A0–A5. - No UK law
England does not require embodied carbon to be measured
The Government confirmed it on 3 March 2026. - London Plan SI 2 F
Referable London schemes must assess it at planning
And again before occupation. - 31 July 2026
BS EN 15978:2026 is the current building method
The 2011 edition is withdrawn. - End of 2025
National Highways asks its larger suppliers for PAS 2080
A contract condition, not a statute.
How do PAS 2080, RICS and EN 15978 fit together?
One manages the process, one sets the professional rules, one is the calculation method.
RICS’s own module figure is adapted from EN 15978, EN 17472 and EN 15643 (RICS Figure 2).
PAS 2080 has no normative references: it requires a recognised method and names these standards as examples.
The three documentsExplore
Frequently asked
What else do people ask about embodied carbon?
What is embodied carbon?
Embodied carbon is the greenhouse gas emitted in making, transporting and installing a building’s or structure’s materials, maintaining and replacing them, and demolishing and disposing of them at the end.
The RICS standard defines it as life-cycle modules A0 to A5, B1 to B5 and C1 to C4.
It excludes the energy and water used to run the building, which is operational carbon.
What is the difference between embodied and upfront carbon?
Upfront carbon stops at practical completion: modules A0 to A5.
Embodied carbon adds the maintenance, replacement and refurbishment of materials over the building’s life (B1 to B5) and the end of life (C1 to C4).
Upfront carbon is part of embodied carbon, not another name for it.
Is embodied carbon regulated in the UK?
Not by national law in England.
The Building Regulations, including the Future Homes and Buildings Standard from 24 March 2027, regulate operational carbon only.
On 3 March 2026 the Government told MPs it does not agree with mandating whole life carbon assessments at this time.
Part Z is an industry proposal, not law.
Who asks for an embodied carbon assessment?
In London, schemes referable to the Mayor must submit a whole life-cycle carbon assessment with the planning application.
National Highways asks its large and medium suppliers for a PAS 2080-verified carbon management system.
Ofwat and Ofgem expect recognised standards, and central government’s Construction Playbook asks for a whole life carbon assessment with bids where proportionate.
How is embodied carbon calculated?
Quantities of each material are multiplied by emission factors, usually from environmental product declarations made under EN 15804+A2, and grouped into life-cycle modules.
For buildings the method is BS EN 15978:2026 and, for RICS members, the RICS whole life carbon standard; for civil engineering works it is BS EN 17472.
Is BS EN 15978:2011 still current?
No. BSI withdrew it on 31 July 2026 and published BS EN 15978:2026, which adds a pre-construction module A0, a user-activity module B8 and splits module D in two.
Its UK foreword says there are no mandatory UK regulations or methods for whole life carbon assessment of buildings.
What is PAS 2080?
PAS 2080:2023 is BSI’s free, voluntary specification for managing whole life carbon in buildings and infrastructure.
It is a management process, not a calculation method, and it uses the term “capital carbon”.
The detail is on the PAS 2080 page.
Is there a legal embodied carbon limit for buildings?
No. No limit is set in UK law.
Part Z proposes future limits on upfront carbon, but its thresholds are placeholders and it has not been adopted.
Sources
Where does each figure come from?
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 24 sources fromRICSHouse of Commons Environmental Audit CommitteeBSIMinistry of Housing, Communities and Local Governmentlegislation.gov.ukUK Parliament
- RICSWhole life carbon assessment for the built environment, 2nd edition, Version 3, §2.1 and §4.2
Upfront, embodied, operational, user and whole life carbon defined by module; a 60-year reference study period.
- RICSWLCA standard 2nd edition now in full effect
Binding on RICS members from 1 July 2024.
- House of Commons Environmental Audit CommitteeEnvironmental sustainability and housing growth: Government Response (HC 1785), ¶¶72–73, 82–84
Received 3 March 2026: no mandate for whole life carbon assessment “at this time”.
- House of Commons Environmental Audit CommitteeBuilding to net zero: Government Response (HC 643)
The 2022 promise to consult in 2023, which was not kept.
- BSIBS EN 15978:2026, Sustainability of construction works: assessment of environmental performance of buildings
Published 31 July 2026; adds modules A0 and B8 and splits D into D1 and D2.
- BSIBS EN 15978:2011 (withdrawn)
“Effective July 31, 2026, this standard has been withdrawn.”
- BSIBS EN 17472:2022, sustainability assessment of civil engineering works
The method for infrastructure; not for buildings.
- BSIBS EN 15804:2012+A2:2019 (identical to EN 15804+A2/AC:2021)
The core rules for construction product environmental product declarations.
- Ministry of Housing, Communities and Local GovernmentConstruction Products Reform White Paper, Chapter 10
Producing an EPD stays voluntary; a proposal, consultation closed 20 May 2026.
- legislation.gov.ukThe Building Regulations etc. (Amendment) (England) Regulations 2026 (SI 2026/335)
The Future Homes and Buildings Standard, in force 24 March 2027.
- UK ParliamentWritten ministerial statement HCWS1445 (24 March 2026)
“Zero carbon ready” homes: an operational carbon standard.
- Part ZThe Part Z proposal
An industry-drafted amendment to the Building Regulations; not law.
- Greater London AuthorityLondon Plan 2021, Chapter 9, Policy SI 2
SI 2 F: referable development calculates whole life-cycle carbon emissions.
- Greater London AuthorityWhole Life-Cycle Carbon Assessments guidance
Required for referable applications; encouraged for other major development.
- Greater London AuthorityThe next London Plan
Draft plan consulted on from 16 July to 15 October 2026; adoption expected early 2028.
- National HighwaysNet zero highways plan: 2025 update
Large and medium suppliers to implement a PAS 2080-verified carbon management system by the end of 2025.
- OfwatFinal Climate Change Principles (February 2026)
Expects frameworks such as PAS 2080; three named companies have capital or embodied carbon commitments.
- OfgemRIIO-3 guidance: Environmental Reporting Guidance
Embodied carbon reported in line with industry standards, PAS 2080 given as an example.
- Cabinet OfficeThe Construction Playbook (September 2022)
Whole life carbon assessment with bids where proportionate; comply or explain.
- Cabinet OfficePromoting Net Zero Carbon and Sustainability in Construction: Guidance Note
¶3.6.3: requiring bidders to hold a particular standard is likely not justifiable.
- BSIPAS 2080:2023, Clauses 3.8 and 7.1.3
PAS 2080 says “capital carbon” and points to existing life-cycle standards.
- Net Zero Carbon Buildings Standard LtdUK Net Zero Carbon Buildings Standard, Version 1 Rev 1 (April 2026), Table 2 and Annex A
Voluntary limits on upfront carbon and energy use intensity by sector and year.
- Net Zero Carbon Buildings Standard LtdUK NZCBS FAQs
Verification with Bureau Veritas; “Net Zero Carbon Aligned” only after verification.
- Department for EducationCF25 Technical Manual, §0.1.10 (January 2026)
A1–A5 embodied-carbon limit of 550 kgCO2e/m² GIFA.
Continue reading
Where to go next
Guide
PAS 2080
The carbon management specification National Highways, Ofwat and Ofgem point to.
Guide
Future Homes Standard
The operational carbon rules for new homes from 24 March 2027.
Guide
Life-cycle assessment standards
ISO 14040, ISO 14044, EN 15804 and EPDs.
Guide
Scope 3 emissions
Where purchased construction sits in a company footprint.
See also: BREEAM certification · LEED certification · NABERS UK.