Dr Lee Jones, Head of Sustainability at Hubexo NBS, looks at what whole-life reporting means for product manufacturers and suppliers.
Over the last decade, construction has made real progress on mitigating operational carbon. And it's true, today's buildings are better insulated and heat pumps are regularly specified, while clients are asking much tougher questions about in-use performance than they were five years ago. This is welcome progress, but expectations are now going further, heading towards the reporting of whole-life carbon emissions. This is something altogether more demanding. Whole-life carbon reporting looks past how a building performs during its occupation and asks what it cost the environment to construct it in the first place. Some of the answers to these questions can be found in the data that product manufacturers hold.
The numbers behind the product spec are vital
Upfront embodied carbon refers to the emissions generated through the manufacture, transport and installation of materials used in a construction of a building. Often, upfront embodied carbon is the largest single element of a building's whole-life carbon footprint. For example, in a typical UK office, over a 60-year lifespan, it accounts for around 35% of whole-life carbon¹. In highly efficient buildings, where operational emissions have already been driven down, that figure can reach as high as 75%². With new regulations looming, the carbon number sitting behind a product matter almost as much as how the product performs.
Measurement has improved, consistency hasn't
For suppliers, this is where the picture gets awkward. Measurement has advanced, as around three in five construction professionals now use digital technology to assess embodied carbon, up from two in five doing so in 2023, according to the NBS Digital Construction Report 2025³. On the surface, that sounds like good news, but inconsistency is a major issue. Research by AECOM found up to 70% variation in embodied carbon calculations for identical designs, depending on the methodology⁴. That's a huge discrepancy, with probable repercussions. Whilst the methodological approach at a project level its self may be in question, similarly, if the figure behind a manufacturer's product cannot be reliably compared with a competitor's, why should a specifier go to the trouble to make a case for it?
Verified data is becoming a condition of specification
In the search for certainty, verified Environmental Product Declarations (EPDs) are fast becoming a cornerstone commercial requirement. An EPD calculated to a recognised standard, such as BS EN 15804, gives a specifier a figure they can trust and confidently compare against an alternative. For example, NBS's own Lifecyle Assessment (LCA) tool now draws on more than 12,500 specification-ready products with EPDs from NBS Source and ECO Portal: it's a cloud-based platform that gives design teams the ability to pull that data straight into live project assessments⁵. Manufacturers who supply carbon data that is verified and structured to widely recognised standards are therefore producing products that are straightforward to specify.
Placing the data where the decisions are made
EPDs and other manufacturer literature are typically found in PDF documents. However, recent research from NBS’s 'Closing the Specification Gap' found that for many manufacturers, the specifiers they are selling to would rather receive structured digital product information⁶. This tells us that product information, including carbon data, needs to be available where design decisions actually get made; that is, inside the tools specifiers already use. It should not be stuck in a PDF brochure that can’t be linked to the specification tool, 3D model, or carbon assessment tools. The transition to digital product passports over the next few years also supports this.
Looking to the very near future
The timing around all this matters because the regulatory direction of travel is clear. The UK government's Carbon Budget 5, which take effect from 2028, notes that carbon assessments will be fundamental in helping to achieve the country’s Net Zero⁷ goals. The EU has already moved further, with mandates now locked in. Once whole-life carbon reporting becomes standard practice, a building will be judged on its upfront embodied carbon figures, as well as its operational performance. No doubt, specifier requests from manufacturers for verified carbon information will soon become routine.
The built environment accounts for two-fifths of global carbon emissions⁸, and in the UK construction generates around three-fifths of all waste⁹. In that context, clients, regulators and investors will no longer accept figures that cannot be adequately explained or compared. Those manufacturers who get their product data verified and published in a form specifiers can use, ahead of the deadlines, will be the ones still sitting on the specification when embodied carbon reporting becomes mandatory. The tools to do this are already here. The task now is to position the data where it can do the most good.
Notes:
- Investing in Heritage to Avoid Embodied Carbon Emissions, Historic England: https://historicengland.org.uk/research/heritage-counts/heritage-and-environment/avoiding-embodied-carbon-production/
- Embodied Carbon Report, Architects Climate Action Network: https://architectscan.org/resource/embodied-carbon-report/
- NBS Digital Construction Report 2025, NBS (powered by Hubexo): https://www.thenbs.com/digital-construction-report-2025
- The Practical, Technical and Economic Impacts of Measuring and Reducing Embodied Carbon in New Buildings, AECOM for MHCLG: https://www.gov.uk/government/publications/consideration-of-embodied-carbon-in-new-buildings
- NBS LCA, NBS (powered by Hubexo): https://www.thenbs.com/nbs-lca
- Closing the Specification Gap, NBS (powered by Hubexo), NBS for Manufacturers: https://manufacturers.thenbs.com/resources
- Carbon Budget and Growth Delivery Plan, Department for Energy Security and Net Zero: https://assets.publishing.service.gov.uk/media/6901d0c2a6048928d3fc2b55/carbon-budget-and-growth-delivery-plan-report.pdf
- Global Status Report for Buildings and Construction 2024/2025, GlobalABC/UNEP/IEA: https://globalabc.org/sites/default/files/2025-03/Global-Status-Report-2024_2025.pdf
- UK Statistics on Waste, Department for Environment, Food and Rural Affairs: https://www.gov.uk/government/statistics/uk-waste-data/uk-statistics-on-waste