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A Net Zero UK: Ambition vs Reality

In the summer of 2019, the United Kingdom committed to reach net zero by 2050, legally pledging to reduce emissions by 100% compared to 1990 levels. Almost seven years on, how much progress have we really made? The picture was already mixed, but this week it became harder to defend, as the UK confirmed that it is halving its contribution to the UN’s Green Climate Fund by a cut of more than £800 million, leaving it, alongside the US, as the only countries to have rescinded or cancelled a pledge to the world’s largest dedicated climate fund.

Net zero delivery largely depends on two things in parallel: the policy commitments a government makes, and the funding, infrastructure, and regulatory mechanisms that turn those commitments into reality. This article looks at both. It covers the pledges that have shaped UK climate policy since 2024 and the decisions, like the choice to cut climate funding mentioned above, that have determined whether those pledges can actually be delivered.

Domestic climate ambition has held remarkably steady across UK governments since 2019. Net zero by 2050 was legislated under a Conservative government, the 2030 phase-out of internal combustion engine cars was twice committed to and once delayed, and the current Labour government has restored or strengthened most headline pledges. But the financial and infrastructure mechanisms required to deliver that ambition have been moving in the opposite direction. Overseas aid has been cut from 0.7% to 0.5% to 0.3% of gross national income between 2020 and 2027-28. Major delivery vehicles like the Public Sector Decarbonisation Scheme have been defunded. Large-scale renewable infrastructure has been rejected. International climate finance commitments have been halved or withdrawn. This article examines that gap.

Direct Pledges – Environment

Full Fact is a UK-based independent fact-checking charity, whose Government Tracker tool monitors 92 key pledges drawn from the 2024 election manifesto and subsequent announcements, rating each as achieved, appears on track, in progress, appears off track, not kept, unclear or disputed, or wait and see. Several environmental policies have been rated, such as;

AreaPledgeFull Fact Verdict 
Electric vehicles‘Labour will support the transition to electric vehicles … restoring the phase-out date of 2030 for new cars with internal combustion engines’Wait and see
Water pollution‘This Government will cut water companies’ sewage pollution in half by the end of the decade’Wait and see
Environmental prosecution‘We will give regulators new powers to … bring criminal charges against persistent law breakers [water companies]’Achieved

Full Fact, (2026, April 28), Government Tracker, Retrieved from Full Fact: https://fullfact.org/government-tracker/

Although two years into their term, we are still waiting to see if Labour’s efforts to support the uptake of electric cars will result in a complete phase out of new combustion engine cars by 2030, the infrastructure to support this like electric charging points does seem to be becoming a more frequent sight on our roads. Similarly, whilst data for the year 2025-26 has not yet been released, the achievement of handing prosecution power to regulators to bring criminal charges to companies who hinder such investigations will hopefully aid in the reduction of water companies’ pollution into natural bodies of water by 2030.

None of these pledges have been classed as ‘appears off track’, ‘not kept’ or ‘unclear or disputed’ which shows a clear commitment to improving the environmental situation in the UK. The consistency is promising, but these commitments only hold weight if delivery follows.

Direct Pledges – Energy 

Energy policy, however, tells a more encouraging story. These policies seem to be progressing more rapidly than other governmental areas, for example;

AreaPledgeFull Fact Verdict 
Independence‘A new Energy Independence Act will establish the framework for Labour’s energy and climate policies’Wait and see
Oil and Gas‘We will not issue new licences to explore new [oil and gas] fields’Appears on track
Coal‘We will not grant new coal licences’Appears on track

Full Fact, (2026, April 28), Government Tracker, Retrieved from Full Fact: https://fullfact.org/government-tracker/

The creation of the new publicly owned company, Great British Energy has been achieved, providing an early and tangible signal of the government’s intent. The refusal to license new oil, gas, or coal exploration marks a meaningful break from previous energy policy. Both are rated as appearing on track, suggesting the government is actively resisting pressure to reopen fossil fuel development. This is a position that has the potential to become harder to maintain as energy prices fluctuate and supply security debates resurface.

The Energy Independence Act remains a wait-and-see, which is unsurprising given its role as an overarching legislative framework rather than a single deliverable. Its progress will likely determine how cohesively the remaining pledges are delivered.

As with the environmental commitments, none of these energy pledges have been rated as ‘off track’, ‘not kept’, or ‘unclear or disputed’ which is a consistency that, two years into the term, points to a government that is holding its stated course on clean energy transition. Whether this holds up when the government is faced with harder trade-offs remains unknown.

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Grid Reform

Behind the headline energy pledges, the mechanics of actually connecting renewable energy to the grid have been difficult. Until 2025 the connection system operated on a first-come, first-served basis, and by early 2025 the connection queue had reached over 700 GW of generation and storage projects, roughly four times what the country actually needs. Speculative applications were holding firm connection dates that genuine projects could not access, and the previous model was no longer fit for the scale of the energy transition.

So, in June 2025, the Connections Reform led by NESO, the National Energy System Operator, went live. It replaced the queue-based model with a readiness-based system, assessing roughly 3,000 projects and identifying 283 GW to move forward, of which 132 GW are targeted for connection by 2030 in support of the government’s Clean Power target. Because of an oversupply of battery energy storage system (BESS) projects in the queue, only those with ‘protected’ status received firm connection offers. Around 153 GW of BESS projects were not prioritised, with no realistic pathway to grid connection before 2035. Solar Energy UK, the trade body for the sector, described the outcome as “painful but necessary”.

The process also ran into serious execution problems. NESO missed multiple self-imposed deadlines for issuing connection offers, with the operator itself acknowledging “considerable uncertainty” throughout, and conceding that delays were creating uncertainty around resourcing and investment. Gate 2 Phase 1 transmission offers for projects connecting before 2030 are now not expected until mid-2026 at the earliest. This means that developers who had invested years and significant capital into projects expecting a 2028 or 2029 connection have been hit hard. The reforms are a necessary response to the broken system, but the execution has added a further layer of uncertainty to an already strained supply chain.

Also in June 2025, the UK government rejected the Xlinks Morocco-UK Power Project. The project had been designated a Nationally Significant Infrastructure Project by the previous government in 2023 and had progressed through development for over six years.

The project proposed building 11.5 GW of solar and wind generation in Morocco’s Guelmim-Oued Noun region, paired with 22.5 GWh of battery storage, and transmitting the power to Britain via a 4,000 km HVDC subsea cable. The numbers were striking: 8% of UK electricity supply, a projected 10% reduction in power sector CO₂ emissions in its first year, a 9.3% reduction in wholesale electricity prices, £20 billion in socio-economic value, and £5 billion directly into UK green industries.

At the time, Xlinks had secured backing from TotalEnergies, Abu Dhabi National Energy Company, and Octopus Energy, with £5 billion of equity finance lined up and no government investment required. The company was seeking a Contract for Difference, a standard government mechanism guaranteeing a price for the electricity generated, at approximately half the cost of new nuclear energy but the government declined.

The consequences extended beyond the project itself. XLCC, a Scottish company that had planned to manufacture the four giant cables at a new factory at the Port of Hunterston in North Ayrshire, saw its business collapse alongside the decision. Xlinks has since established a German subsidiary, Xlinks Germany GmbH, which is developing a separate Morocco-to-Germany project called Sila Atlantik, backed by E.ON and Uniper and now formally supported by the German federal government.

Public Sector Policies

Beyond direct government pledges, institutional commitments across the public sector are reshaping how organisations operate and what they demand from their suppliers. Several institutions have imposed mandatory net zero targets or are requiring a demonstrable commitment to sustainability:

  • NHS England – commits to net zero direct carbon emissions by 2040, and net zero indirect emissions like those from the supply chain or patient and staff travel by 2045.
  • Local Authorities – many pledge to reach net zero before the national target with a significant number committing to dates as early as 2030, by delivering on the ground impactful projects to mitigate climate change.
  • Educational Institutions – fall into the same national net zero by 2050 target, with new school buildings designed to a zero carbon standard since 2022.

Over the past five years, the NHS and local authorities in England have made measurable progress on estate decarbonisation, tightened supplier requirements through Carbon Reduction Plans and Environmental Product Declarations, and implemented local green plans. A significant proportion of the capital behind this progress, particularly for heat pump installation, fabric upgrades, and solar deployment across hospitals, schools, and council buildings, came through the Public Sector Decarbonisation Scheme administered by Salix Finance.

From 2025, educational settings in the UK are required to have a Sustainability Lead and a Climate Action Plan, CAP, in place. These CAPs ensure that each individual school can progress towards sustainability targets in a bespoke and manageable way. This means that improvements so far have largely been focused on reducing operational carbon of current school buildings, and there are efforts to only continue this progress and work towards reducing embodied carbon emissions in new build schools.

Cancellation of the Public Sector Decarbonisation Scheme

Much of the aforementioned decarbonisation momentum was funded, in part, by the Public Sector Decarbonisation Scheme (PSDS). This is a programme administered by Salix Finance on behalf of the government since 2020, and has awarded over £3.5 billion in grants across nearly 1,400 projects for measures including heat pumps, solar panels, insulation, and glazing upgrades in schools, hospitals, and council buildings.

Following the 2025 Spending Review, the government confirmed it would commit no further investment to the PSDS beyond already-awarded projects. Existing phases (Phase 3c and Phase 4) are due to continue to completion in March 2026 and March 2028 respectively, but there will be no Phase 5 and likewise, no replacement has been announced.

The practical consequences of this are significant. Many local authorities had set 2030 net zero targets for their estates which may become increasingly hard to reach without continued PSDS investment. Similarly, decarbonising complex buildings such as schools, swimming pools, and hospitals takes years of planning, procurement, and delivery. This abrupt end to the funding pipeline disrupts the planning horizon at precisely the point when the market has scaled up to meet it. Contractors, heat pump installers, and sustainability consultancies that built capacity around PSDS delivery now face the loss of their core customer base. The Low Carbon Skills Fund, which helped public sector organisations develop heat decarbonisation plans in the first place, was also cancelled for 2025/26, removing even the advisory layer of the programme. The result is a public sector net zero programme that has, in effect, been defunded mid-journey, with many small scale consultancies and contractors caught in the crossfire.

International Standing

On the global table, the UK’s policy decisions have weakened its position internationally. At COP30 in Belém in November 2025, Brazil launched the Tropical Forests Forever Facility (TFFF), a results-based finance mechanism designed to make standing forests more valuable than cleared ones. The initiative originated in the UK and was shaped in part by the British government and British financial institutions. But when Keir Starmer arrived in Belém, he came with no pledge to invest. Norway committed $3 billion, Germany €1 billion, France €500 million, Brazil and Indonesia $1 billion each. The UK, which hosted COP26 in Glasgow and championed international forest protection, contributed nothing, citing domestic fiscal pressure as the reason. The situation was worsened diplomatically by Prince William having been in Rio de Janeiro the day before, naming the TFFF an Earthshot Prize finalist. At the time, our director, Tom Bradley, was at industry events for COP30 in São Paulo, and the mixed messaging and effective insult to Brazil during COP30 were mentioned by other delegates. The instrument the UK had helped design proceeded without British funding.

That pattern has continued into 2026. This week, the UK notified the Green Climate Fund, GCF, that it is cutting its pledge for the fund’s second replenishment cycle by approximately 50%, reducing it to only £815 million. The move follows Donald Trump’s administration rescinding the US’s $4 billion pledge a year prior, and the UK and US are now the only countries to have cancelled a commitment to the fund. The GCF’s chief executive confirmed the cut is expected to have a material impact on project delivery. The government cited its decision to reduce overseas aid from 0.5% to 0.3% of gross national income and prioritise domestic security spending. Other major economies including Germany and France have also trimmed climate finance budgets, but neither has rescinded a GCF pledge.

The Expert Verdict 

The Climate Change Committee, the independent body which reports to Parliament on emissions reduction progress, advised in 2019 that Scotland could reach net zero by 2045 and Wales could achieve a 95% reduction by 2050. Both nations went on to legislate this. Scotland’s 2045 target is now law under the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, and Wales went further than the original Committee advice, legislating full net zero by 2050 in 2021. However, in April 2024 the Scottish Government scrapped its 2030 interim emissions reduction target after admitting it was no longer achievable.

The Committee also states that “it is achievable with known technologies, alongside improvements in people’s lives, and within the expected economic cost that Parliament accepted”. This indicates that the solutions exist and the costs are understood, but the Committee is equally direct about what is missing, warning that this outcome “is only possible if clear, stable and well-designed policies to reduce emissions further are introduced across the economy without delay” and that “current policy is insufficient for even the existing targets.”

Climate Action Tracker reinforces this, rating the UK’s overall policies and action as ‘insufficient’. The gap between what is technically possible and what policy currently supports is not a minor shortfall. Cancelling the PSDS, rejecting Xlinks, and attending COP30 without financial commitments are examples of the kind of policy choices that are inconsistent with the legislated trajectory.

Are We on Track?

The overall picture is one of genuine but uneven progress. This article covers only part of the landscape, but the decisions discussed are representative of where the UK stands.

Real progress has been made towards a net zero UK by 2050. Great British Energy has been established, new fossil fuel licences have been refused, supply chain requirements have been tightened through Carbon Reduction Plans and Environmental Product Declarations, and schools are now legally required to have Climate Action Plans in place. The decisions described in this article sit alongside those achievements. The PSDS has been defunded, removing the primary capital mechanism for public sector decarbonisation. The Xlinks rejection ended a proposal for privately financed generation that would have supplied 8% of UK electricity. The grid reform was structurally necessary, but its execution caused investment delays and removed significant volumes of consented capacity from the connection pipeline. At COP30, the UK helped design the Tropical Forests Forever Facility but did not commit financial backing at launch. And this week, the UK halved its contribution to the UN’s Green Climate Fund, the primary financial vehicle for the Paris Agreement’s implementation in 134 developing countries.

These decisions are not isolated. The retreat from delivery mechanisms has been running since around 2020 and has continued across two governments. The UK has maintained net zero ambition in legislation while withdrawing the means of delivery for six years across both parties, and 2025-2026 is the most acute phase of that pattern. Domestic ambition has held in law. The funding, infrastructure, and international finance required to deliver that ambition have not.

Progress remains uneven, and the Climate Change Committee is clear that current policy is insufficient to meet existing targets. Closing the gap between ambition and delivery will be the central challenge of the next 24 years.

At Below280, we help organisations move from commitment to measurable action. Whether that means conducting a Life Cycle Assessment (LCA) to understand where emissions occur across a product full lifespan, producing an Environmental Product Declaration (EPD) to meet supply chain requirements like those now demanded by the NHS and local authorities, carrying out a Whole Life Carbon Assessment (WLCA) to quantify embodied and operational carbon in the built environment, or navigating the UK’s incoming Carbon Border Adjustment Mechanism (CBAM)

Frequently Asked Questions

Progress has been made but the Climate Change Committee warns that current policy is insufficient to meet existing targets. Significant steps like the creation of Great British Energy and the refusal of new fossil fuel licences are positive, but delivery across all sectors needs to accelerate.

Great British Energy is a new publicly owned energy company established by the Labour government as part of its clean energy transition. It represents one of the more tangible early signals of the government’s commitment to moving away from fossil fuels.

Carbon Reduction Plans (CRPs) are required for UK businesses bidding on public contracts over £5 million under PPN 06/21. They set out a company’s current carbon footprint and commitment to reaching net zero by 2050.

An EPD is a verified document that communicates the environmental impact of a product across its lifecycle, based on a Life Cycle Assessment. They are increasingly required by public sector procurement, BREEAM, and supply chain requirements like those from the NHS.

The Committee states that net zero is achievable with known technologies and within expected economic costs, but warns that current policy is insufficient and that clear, stable policies must be introduced across the economy without delay.

Ready to turn your net zero commitment into verified action?

We help UK organisations produce the LCAs, EPDs, and carbon data that supply chain and regulatory requirements demand. Talk to our team.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

Sources 

House of Commons Library – Net Zero

Institute for Government – Net Zero

Full Fact – Government Tracker

NHS England – A Net Zero NHS

Local Government Association – Local Net Zero

Forbes Solicitors – Net Zero Education Review

European Commission – CBAM

UK Government – CBAM Policy Summary

Climate Change Committee – Net Zero

Climate Action Tracker – UK

Written by Helen Brown

Insights

How to Calculate Embedded Emissions for UK Aluminium Manufacturers

If you make aluminium products and export to the EU, your customers are already asking for embedded emissions data. From January 2026, EU CBAM (Carbon Border Adjustment Mechanism) entered its definitive phase, which means the carbon content of your products is now a direct cost for whoever imports them. Get the number wrong or leave it blank, and they pay more. Get it right, and you protect the relationship.

This guide explains exactly what embedded emissions are, how to calculate them, and what UK aluminium manufacturers need to do to stay on the right side of their EU customers.

Embedded emissions are the greenhouse gases released during the production of a good, up to the point it leaves your factory gate. For aluminium, this covers:

Direct emissions (Scope 1): the carbon released from your own production processes, such as combustion in furnaces, use of fossil fuels for heating, process emissions from smelting or casting, and the use of chemical reagents in production.

Indirect emissions (Scope 2): the emissions from the electricity you consume in manufacturing. For aluminium, this is significant because electrolytic smelting is energy-intensive, and the carbon intensity of that electricity depends on when and where it was generated. Note that electrolytic smelting is only relevant if you are producing primary aluminium from base ore. Most downstream aluminium manufacturers working with ingot or billet will not have this process in scope.

Precursor emissions: if your aluminium product uses aluminium ingot, billet, or other semi-finished materials as inputs, the embedded emissions from those upstream materials must also be included. These are often the largest share of the total.

The boundary for CBAM is modules A1 to A3 under EN 15804, which maps to cradle-to-gate. You are not required to include transport to the customer or end-of-life, but you do need everything up to the factory gate.

This is where many manufacturers get tripped up. A Life Cycle Assessment (LCA) gives you a comprehensive picture of your product’s environmental impact across multiple categories. An Environmental Product Declaration (EPD) communicates that data in a standardised format.

But CBAM does not simply accept an LCA or EPD as proof of embedded emissions. The EU’s Monitoring and Reporting Regulation (MRR) requires installation-specific, meter-based data. That means:

  • Emissions must be traced to your specific production installation, not an industry average
  • Electricity must be attributed using a time-weighted carbon intensity factor for the grid you actually use
  • Any precursor materials must have their own verified emissions data, not generic database values

If you cannot provide verified actual emissions, your EU customer must use region-specific default values. These are calculated as the average of the 10% worst-emitting production sites in that region, not a single EU-wide figure. For most UK manufacturers, those default values will be higher than your actual emissions, which means your customer overpays on certificates and you look like a high-carbon supplier.

Identify which products are in scope and trace each one back to its production installation. For a UK aluminium extruder, this means the extrusion facility itself, but also the source of the aluminium billet you use as feedstock.

Gather actual metered data from your installation for the reporting period, typically a calendar year. This includes fuel consumption by type, electricity consumption, and production volumes. The data needs to be traceable, ideally from your energy invoices and production records.

Apply the EU-approved emission factors for each fuel type to your fuel consumption data. These are set by the EU MRR and are not the same as DEFRA emission factors, so you need to use the right source.

Multiply your electricity consumption by the carbon intensity of your national grid, using the country-specific electricity emission factor published by the EU for the relevant year. For UK installations, there is a specific factor available.

If you use primary aluminium as an input, you need verified embedded emissions data for that aluminium from the smelter or supplier. This is where the process gets complicated. If your supplier cannot provide verified data, region-specific default values apply for that portion.

Divide total direct and indirect emissions by the quantity of product produced in tonnes. This gives you the embedded emissions intensity figure your EU customer needs.

Embedded emissions intensity formula

Direct emissions
Scope 1 (tCO2e)
+
Indirect emissions
Scope 2 (tCO2e)
+
Precursor emissions
Upstream inputs (tCO2e)
÷
Production volume
Tonnes produced
=
tCO2e/t
Embedded emissions intensity

This is the figure your EU importer needs for their CBAM declaration.

This is the document you provide to your EU importer. It must follow the format specified by the European Commission and include your installation details, the calculation methodology, the emissions intensity figure, and any carbon price already paid in the UK.

Even though an EPD alone does not satisfy CBAM, it significantly reduces the work involved. A well-constructed EPD for an aluminium product contains most of the primary data and calculation logic CBAM requires. The system boundary overlaps almost entirely, and the verification process for an EPD gives you an audit trail that CBAM verifiers will recognise.

If you already have an EPD or are planning to get one, the marginal effort to produce CBAM-ready embedded emissions data is much lower. The datasets, the allocation methodology, and the verification evidence are largely the same.

This matters because CBAM verification is mandatory from 2026. Your embedded emissions data must be independently verified by an accredited third party, including an on-site audit in the first year. Starting with a rigorous LCA and EPD foundation makes that verification faster and less painful.

EU CBAM applies to goods imported into the EU now. UK CBAM is expected to follow a similar structure and is currently scheduled to take effect from January 2027, covering aluminium, cement, fertiliser, hydrogen, and iron and steel.

If you manufacture aluminium products sold in the UK market, the same embedded emissions calculation methodology will apply domestically within the next 12 months. Building the data infrastructure now means you will be ready for both regimes without duplicating the work.

No. An LCA provides valuable primary data, but CBAM requires installation-specific metered data calculated using the EU MRR methodology. An LCA is a strong starting point, not a direct substitute.

If you cannot obtain verified data from your supplier, region-specific default values apply for that precursor. These are based on the average of the 10% worst-emitting production sites in the relevant region. This will likely overstate your actual embedded emissions and increase your customer’s CBAM certificate cost.

From 2026, yes. Supplier-specific emissions data used in CBAM declarations must be verified by an accredited third-party verifier. The first verification includes an on-site audit.

It is the document UK exporters provide to their EU importers summarising embedded emissions per tonne of product, the calculation methodology, and any carbon price already paid. It follows the format set by the European Commission.

UK CBAM is expected to follow a similar structure, with full implementation from January 2027. It will cover the same broad product categories. UK manufacturers exporting to the EU face EU CBAM obligations now; those selling domestically will face UK CBAM obligations from 2027.

Yes. Below280 provides embedded emissions calculations for CBAM compliance, including primary data collection, EU MRR-aligned methodology, and support through the verification process. We also produce EPDs that create a reusable data foundation for ongoing CBAM reporting.

Working through your first CBAM submission?

If your EU customer has started asking for a Communication Summary Sheet, we can help. We calculate your embedded emissions, prepare the documentation, and support you through verification.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

News

Below280 Launches to Help Manufacturers Navigate the New Era of Environmental Compliance

A specialist consultancy focused on LCA, EPD, and CBAM is entering the market at exactly the right moment

[Cramlington, 18th March, 2026] Below280 has officially launched as a dedicated sustainability consultancy built to help manufacturers understand, measure, and communicate the environmental impact of their products.

What Does “Below280” Mean?

The name says it all. 280 parts per million is the pre-industrial CO₂ baseline, the world before significant human induced climate change. Below280 exists to help businesses take the steps that actually move the needle back.

LCA, EPD and CBAM Under One Roof

With growing pressure from the EU and UK Carbon Border Adjustment Mechanism (CBAM) and rising demand for verified Environmental Product Declarations (EPDs) and Life Cycle Assessments (LCA), manufacturers are facing a compliance landscape more complex than ever.

“The regulations and requirements are coming whether businesses are ready or not. Below280 exists to make sure they are. We have a strong history of delivering LCA, starting out as part of Narec, and then Decerna, and now as an independent company. If you want high quality LCA studies that can help you not only fit with regulations, but make active changes to your product, this is what we do,” said Tom Bradley, Director at Below280.

As modern methods of construction and sustainable building claims come under scrutiny, LCA is fast becoming the proof that backs them up.

Unlike generalist sustainability consultancies, Below280 brings deep technical expertise to a focused set of services; meaning clients get specialists, not generalists, working on the issues that matter most to their business right now. Below280 is open for business and working with manufacturers across the globe.

Below280 has a strong history of LCA, existing as part of the sustainability consultancy Decerna since 2012, and prior to that, being the LCA services of Narec since 2010.

For enquiries, visit www.below280.com or contact info@below280.com

About Below280 Below280 is a UK-based sustainability consultancy specialising in Life Cycle Assessment, Environmental Product Declarations, and CBAM compliance.

Insights

Part Z and Embodied Carbon Guide

The UK Government faces an imminent decision on embodied carbon regulation. And the clock is ticking on Net Zero targets. Embodied carbon now threatens to overtake operational energy use. It is becoming the sector’s primary carbon source, leaving the UK’s construction industry no longer wondering whether embodied carbon regulation is necessary, but how long the UK can afford to delay its assessment. This article discusses the differences between operational and embodied carbon, explores the barriers, benefits and support of mandatory reporting and why this matters within the UK construction industry.  


Embodied carbon is defined as the total carbon emissions produced throughout a building’s entire lifecycle, excluding its operational energy use. It contributes to roughly 20% of UK built environment emissions currently, but this is ever rising. Due to buildings increasing in energy-efficiency and grid decarbonisation, operational carbon is falling, meaning that embodied carbon will account for over half of built environment sector’s emissions by 2035. 

Operational Carbon vs Embodied Carbon 

As embodied carbon is released upfront, it cannot be reduced post-build unlike operational carbon which you can improve over time through retrofits or switching renewable energy. Consequently, regulatory targets, and standardisation methods of measurement are likely to help quantify emissions, develop science-based targets and hold building developers accountable. However, embodied carbon remains largely unregulated in the UK, resulting in a fall of only 4% between 2018 and 2022, 13% off the reduction target. Compared to operational carbon, these fell successfully in line with stated targets supported by extensive regulation. 

 Operational Carbon Embodied Carbon 
Definition Carbon emissions arising from the energy used to operate a building during its lifetime Carbon emissions from the materials and construction processes used throughout a building’s lifecycle 
Practical Example Electricity powering office lighting and IT equipment  Air conditioning cooling a commercial building Concrete and steel manufacturing and transport   Demolition waste processing 
Mitigation Strategies Improved insulation and airtightness  Renewable energy generation   Energy-efficient appliances Using less material and low carbon or recycled alternatives  Local material sourcing  Building reuse and retrofit  
Supporting UK Regulation Extensively documented:  Building Regulations Part L (Conservation of Fuel and Power)   Future Homes Standard 2025   Energy Performance Certificate (EPC) requirements Currently unregulated, industry-led initiatives include:   Part Z Building Regulations   RICS Whole Life Carbon Assessment and the   Net Zero Carbon Buildings Standard 

Part Z – Industry-led Change  

Part Z is an industry-proposed amendment to the UK Building Regulations 2010, written to require developers to assess and limit the whole-life carbon emissions of new construction projects. Under Part Z, large projects — over 1,000m² or 10 homes — must first report their carbon emissions. Stricter limits on upfront embodied carbon come next. The goal is to regulate the carbon footprint of the construction industry.

Barriers to Regulation 

This approach is backed by industry leaders such as the Institution of Structural Engineers (IStructE) and UK Green Building Council (UKGBC) and supported by a further 105 company pledges. However, almost 5 years on from its original proposal, it is still yet to become law. This has led to pressing questions arising about the UK Government’s priorities regarding the UK construction industry, and its responsibility within net zero targets. 

In an interview with Will Arnold, of IStructE and an author of Part Z, The Building Cost Information Service suggests that government hesitation comes from concerns about meeting housebuilding targets. This uncertainty stems from the effects that implementing this policy could have on increasing the difficulty of building much needed homes. However, Arnold, explains that the regulation could still be applied to larger developments, to avoid building unnecessary barriers for smaller projects. Increasing project costs by undertaking an embodied carbon assessment is also a key worry, but this fails to recognise the monetary positives in increasing material efficiency, reuse and transport distances, all arising from reducing embodied carbon.  

Looking further afield, the European Union has taken a progressive approach, mandating Member States to report embodied carbon by 2028. The Energy Performance of Buildings Directive (EPBD) requires that all new buildings must calculate and report whole-life carbon emissions, plus member states must establish maximum thresholds for embodied carbon, which will gradually decrease after 2030. Prior to the implementation of the EPBD, several EU countries already had national regulation regarding embodied carbon, showing a clear recognition and commitment to eliminating this major contributor of emissions. 

The Benefits of Lowering Embodied Carbon 

Despite Part Z not becoming regulation, industry continues reducing embodied carbon, and the UK Green Building Council published the Net Zero Carbon Buildings Standard in 2024. This document calls for the assessment of both embodied and operational carbon using a whole life carbon approach. Similarly, developers can elect to assess their embodied carbon emissions on a project-by-project basis. This approach demonstrates environmental leadership for those who choose it, whilst meeting the rising demand from both industry stakeholders and the public. 

  • The Forge, London, United Kingdom, 2023 

The Forge, a collaboration between Landsec, Bryden Wood and Easi Space is a development of two nine-storey commercial office buildings in London. It is the world’s first major commercial building constructed using a platforms approach to Design for Manufacture and Assembly (P-DfMA). It also used a minimised basement size, decarbonised MEP services (using heat pumps instead of gas) and opted for low carbon material specifications resulting in a 39% reduction in upfront embodied carbon. Further calculations tracked changes from the baseline through to completion in 2023 and found that embodied carbon accounts for roughly two-thirds of whole life carbon over 60 years, with operational carbon making up the remaining third. 

Timeline to Implementation 

Embodied carbon is soon to dominate built environment emissions, yet it remains largely unregulated in the UK. Thoughtful design and material choices reduce emissions, but progress depends on voluntary action and industry leadership without regulatory backing. As operational carbon continues to fall and embodied carbon’s share grows, the case for regulation becomes harder to ignore. Seemingly, one question remains; how long will the UK wait to implement embodied carbon regulation? 

Supporting Your Embodied Carbon Reporting 

Decerna helps UK construction organisations navigate new compliance requirements through our comprehensive consultancy and development services. Our extensive experience in Life Cycle Assessment makes us one of the longest-established UK consultancies in this field, offering ISO 14040/44 LCAs and EPDs, along with WLCA and Embodied Carbon Assessments. Our capabilities extend to providing Carbon Border Adjustment Mechanism support, comprehensive carbon reporting covering all Scope 1, 2 and 3 emissions, and developing bespoke carbon reduction and Net-Zero plans

Written by Helen Brown 

Does your product need an embodied carbon declaration?

Part Z is coming. Below280 produces ISO 14040/44 compliant LCAs and EN 15804 verified EPDs for UK construction product manufacturers — the documentation specifiers and procurement teams are already asking for.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

News

EU Publishes Long-Awaited Amending Regulation to Simplify CBAM

The European Union has published Regulation (EU) 2025/2083, amending the Carbon Border Adjustment Mechanism (CBAM) Regulation (EU) 2023/956. These amendments follow extensive data collection and stakeholder feedback during the transitional period.

Adopted on 8 October 2025 and published on 20 October 2025, the regulation introduces substantial simplifications, aimed at reducing administrative burden without compromising environmental integrity.

Key changes include:

  • A new exemption threshold, establishing a 50-tonne threshold per importer annually for certain goods.
  • Declaration deadlines extended from 31 May to 30 September
  • Simplified default emission values based on highest-emitting exporting countries
  • System boundaries aligned with EU Emissions Trading Scheme for certain aluminium and steel products
  • Commission-published default carbon prices for third countries with carbon pricing systems
  • Clarified obligations for indirect customs representatives

The amending regulation demonstrates the EU’s responsiveness to implementation challenges, whilst preserving the CBAM’s environmental objectives.

CBAM is changing. Is your compliance data keeping up?

Regulation changes do not pause your obligations. UK manufacturers exporting steel, aluminium, cement, fertilisers or hydrogen to the EU still need verified embedded carbon data — and your EU importers need it now. Below280 keeps your CBAM documentation current as the rules evolve.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

News

Tees Valley Net Zero and Environmental Product Declarations (EPD) Programmes 

Supporting 670 businesses across the Tees Valley 

Overview 

The Tees Valley is home of many businesses, many of which are central to the UK’s industrial base and net zero ambitions. Funded through the UK Shared Prosperity Fund (UKSPF), the Tees Valley Net Zero (TVNZ) and Environmental Product Declarations (EPD) programmes were designed to help local SMEs decarbonise, improve energy efficiency, and prepare for emerging regulations like the EU Carbon Border Adjustment Mechanism (CBAM) and mandatory carbon reporting

Through tailored support—from carbon reduction planning and Life Cycle Assessments (LCAs) to EPD certification and CBAM readiness—the programme supported 670 businesses across the region. 

Key Findings:  

Category Key Result 
Businesses Supported 670 businesses across the Tees Valley 
Economic Impact 500 businesses provided with grants 
Carbon Savings 250 tonnes CO₂e

Innovation Benefits 

  • 82% of businesses said the benefits wouldn’t have happened in the same way without the support 
  • 97% of firms have, or will, improve energy efficiency 
  • 92% of firms have, or will, reduce their energy costs 
  • 80% of respondents have, will, or may develop a decarbonisation plan or EPD certification 

Commercial Benefits 

The programme also helped businesses overcome key barriers to commercial success: 

  • 49% → 10% reduction in businesses facing lack of market knowledge 
  • 27% → 10% reduction in technological constraints 
  • 29% → 4% reduction in risk of failure 
  • 27% → 6% reduction in firms lacking collaborators 

Quality of Service 

Client feedback showed extremely high satisfaction levels: 

  • 100% of respondents were satisfied with the programme 
  • 100% rated the team’s knowledge/expertise as “Excellent” or “Good” 
  • 97% rated the relevance/quality of advice as “Excellent” or “Good” 
  • 97% rated Net Zero advisor consultations as “Excellent” or “Good” 

Conclusion 

The TVNZ and EPD programmes clearly demonstrated the value of targeted, expert-led sustainability support. By helping businesses reduce emissions, navigate new regulations such as CBAM, and prepare for low-carbon growth, the programme contributed significantly to the Tees Valley’s economic and environmental future. 

Does your combined authority need EPD support for local businesses?

Below280 partners with combined authorities and local enterprise partnerships to deliver EPD and LCA programmes for manufacturers in their region. If you represent a council, LEP, or growth hub looking to support businesses with sustainability compliance, get in touch.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

Insights

UK Sustainability Regulations 2025: What Your Business Needs to Know 

The UK’s regulatory landscape is rapidly transforming sustainability into a fundamental business imperative. Recent updates to environmental legislation and related frameworks create a more demanding compliance environment. Organisations must utilise 2025 as a critical preparation period to address increasingly stringent ESG requirements, enhance supply chain transparency, and develop robust strategies to meet ambitious carbon reduction targets. 

Legislative Updates 

Carbon Border Adjustment Mechanism – CBAM  

For importers and exporters, the EU Carbon Border Adjustment Mechanism (CBAM), a scheme which puts a carbon price on imports of carbon-intensive goods to prevent carbon leakage has undergone significant simplification in early 2025. A new de minimis threshold now exempts importers handling less than 50 tonnes annually. This covers iron, steel, aluminium, cement, and fertiliser sectors. This change affects approximately 90% of importers whilst still capturing over 99% of embedded emissions. Notably, electricity and hydrogen sectors remain exempt from this threshold, with algorithm-based calculations and anti-abuse provisions added, ensuring compliance through customs declarations and monitoring. 

For larger importers, several streamlining measures have been implemented, including a simplified authorisation procedure, reduced verification requirements for emissions calculations, decreased financial liability with certificate holding requirements dropping from 80% to 50%, and extended reporting deadlines from May to August. The implementation timeline has been adjusted, with certificate sales for 2026 emissions beginning in February 2027, further reflecting EU ETS. 

Corporate Sustainability Reporting Directive – CSRD 

The Corporate Sustainability Reporting Directive (CSRD) requires qualifying companies to publish detailed sustainability information in their management reports covering environmental, social and governance impacts. Companies must follow the European Sustainability Reporting Standards (ESRS). This includes a double materiality perspective — reporting both how sustainability issues affect the business and how the business affects people and the environment.

As of February 2025, the scope of the CSRD has been reduced to only companies with over 1,000 employees (and either €50M turnover or €25M balance sheet), exempting approximately 80% of previously in-scope companies. It introduces a two-year postponement for implementation timelines, establishes value chain protections limiting information requests from smaller firms, simplifies the ESRS standards, eliminates sector-specific standards requirements, modifies assurance requirements by removing potential upgrades to reasonable assurance, and creates voluntary reporting options for companies not in scope. These changes aim to reduce administrative costs by an estimated €4.4 billion annually whilst maintaining the core sustainability disclosure principles of the directive. 

Corporate Sustainability Due Diligence Directive – CSDDD 

The Corporate Sustainability Due Diligence Directive is an EU legislation requiring large companies to identify, prevent, mitigate and account for adverse human rights and environmental impacts in their own operations, subsidiaries and value chains. It also obliges companies to adopt transition plans for climate change mitigation on a best effort basis.  

The February 2025 simplification package introduces several key changes, including postponed implementation timelines (delayed to July 2027 and first application to July 2028), streamlined value chain assessment requirements that limit due diligence, and simplified process requirements such as reducing assessment frequency from annual to every five years. The update also removes the EU-wide civil liability regime in favour of national systems and better aligns climate plan requirements with existing Corporate Sustainability Reporting Directive (CSRD) standards. These adjustments aim to reduce compliance costs whilst maintaining core environmental and human rights protections. 

The Built Environment  

National Planning Policy Framework – NPPF  

The December 2024 updated National Planning Policy Framework (NPPF) contains significant amendments concerning climate change, which make explicit that climate adaptation and mitigation are now central to decision-making.  The major update is quoted as “the need to mitigate and adapt to climate change should also be considered in preparing and assessing planning applications, taking into account the full range of potential climate change impacts.”  

Those bringing forward planning applications must now provide information concerning the climate impacts of the proposed development and measures taken to adapt to the new requirements. Evidence of such considerations may include; whole-life carbon assessments and quantification of the projects embodied carbon emissions, which provide information about both operational carbon emissions, along with upstream and downstream Scope 3 emissions of the project. The framework also gives significant weight to renewable and low carbon energy generation. 

Building Regulations 

The Department for Levelling Up, Housing and Communities (DLUHC) has announced significant updates to England’s Building Regulations, effective 15 June 2025. These changes represent an important step towards the Future Homes Standard in 2025 and support the UK’s target of achieving net-zero carbon emissions by 2050. 

More stringent energy efficiency requirements have been introduced, with new build homes required to cut carbon emissions by approximately 30% and new commercial buildings by 27% compared to current standards. Within this, Approved Document O addresses the issue of overheating in new residential buildings and establishes a new ‘Primary Energy’ metric, alongside CO2 measurements, to assess energy efficiency compliance. This now takes into account factors such as heating system efficiency and energy production impacts. These measures aim to increase the proportion of homes rated C or above for energy efficiency, which currently stands at 46% compared to just 14% in 2010. New requirements for offices are also included, detailing standards for the use of recirculating ventilation systems and mandatory CO2 monitors. 

Construction Products Regulation – CPR 

The revised Construction Products Regulation (CPR) of January 2025, modernised the previous 2011 rules to address shortcomings in the single market for construction products. The update tackles inconsistent implementation across Member States, simplifies the complex legal framework, and better supports green and digital transitions whilst ensuring product safety. 

Key updates include the introduction of Digital Product Passports (DPPs) that serve as centralised digital records containing technical specifications and environmental data, improving product traceability throughout the EU market. The CE marking has been expanded beyond technical performance to incorporate environmental impact assessments, and manufacturers must now report on climate-related factors such as CO2 emissions and energy consumption for key construction products. These changes align with broader EU sustainability initiatives like the Energy Performance of Buildings Directive, integrating product-level data into building-level assessments. The regulation represents a significant shift for the construction sector’s digitalisation and sustainability efforts, to enable more informed choices based on both performance and environmental impact. 

Reports and Disclosures 

UK Sustainability Reporting Standards – UK SRS 

The International Sustainability Standards Board (ISSB) was established at COP26 in 2021 as part of the IFRS Foundation to create a global baseline for sustainability reporting. The UK government, a strong supporter of the ISSB, has established a framework to assess these standards for endorsement in the UK. If approved, this would become the first UK Sustainability Reporting Standards. The government plans to consult on exposure drafts of UK SRS in Quarter 1 2025, as part of a wider Sustainability Disclosure Reporting framework led by HM Treasury. 

Following the creation of the standards and subject to endorsement, the Financial Conduct Authority will be able to introduce requirements for UK-listed companies to report sustainability-related information to investors. The government has also committed to consulting on requirements for economically significant companies to disclose information using future UK SRS. 

Streamlined Energy and Carbon Reporting – SECR 

The UK’s Streamlined Energy and Carbon Reporting (SECR) policy, introduced in 2019, establishes mandatory carbon and energy reporting requirements for a wide range of organisations. The policy applies to quoted companies (those listed on major exchanges including the London Stock Exchange, EEA markets, NYSE or NASDAQ), large unquoted companies, LLPs, and academy trusts. For unquoted companies and LLPs, the qualification criteria include meeting at least two of the following thresholds: turnover of £36 million or more, balance sheet assets of £18 million or more, or 250 or more employees. 

Companies that consume less than 40,000 kWh of energy in a reporting period qualify as low energy users and are exempt from SECR requirements. Whilst quoted companies must report global data, large unquoted companies, LLPs and academy trusts are only required to report UK energy usage. The policy also includes a ‘comply or explain’ provision allowing organisations to omit data if collection is not possible, provided they explain what has been excluded and why. This provision gives organisations in earlier stages of their ESG reporting journey time to develop more comprehensive reporting capabilities for future years. 

Your Responsibilities 

Next Steps with Below280 

The regulatory landscape is shifting. Below280 specialises in exactly the services organisations need right now — LCA, EPD certification, and CBAM compliance. Our extensive experience in Life Cycle Assessments makes us one of the longest-established UK consultancies in this field, offering ISO 14040/44 compliant assessments and Environmental Product Declarations, along with carbon capture due diligence. This expertise is particularly valuable for businesses needing to address specific now mandated climate impact assessment requirements. 

Our capabilities extend to providing Carbon Border Adjustment Mechanism support, comprehensive carbon reporting covering all Scope 1, 2 and 3 emissions, and developing bespoke carbon reduction and Net-Zero plans that align with the UK Government’s procurement policy. By leveraging our multidisciplinary expertise, we support clients throughout their sustainability journey, from initial concept through to the implementation of low carbon systems and infrastructure. 

Conclusion 

In summary, key EU mechanisms have been modified with higher thresholds and streamlined requirements for corporations and international traders, whilst updated regulations now explicitly incorporate climate considerations into planning and construction. Simultaneously, new reporting frameworks are being developed continue to provide structure for carbon and energy reporting. 

These developments signal the UK’s commitment to balancing ambitious sustainability goals with practical implementation challenges. For businesses, 2025 represents a critical preparation period to adapt to these evolving requirements, with particular focus needed on supply chain transparency, carbon reduction strategies, and comprehensive ESG reporting capabilities. 

Not sure which regulations apply to your business?

CBAM, EPD, Part Z, CSRD — the regulatory landscape is moving fast. Below280 helps UK manufacturers understand exactly what applies to them and what they need to do about it.


Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.

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