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Embodied emissions of building materials

Regulation of embodied carbon in the built environment is gaining momentum. Embodied carbon assessments are being incorporated into planning, building and procurement requirements in a growing number of countries around the world.

HIA’s Position Statement

  1. The selection and use of low embodied carbon materials should be the choice of customer
    and/or driven through government incentives, as opposed to a mandatory requirement that
    would regulate a maximum target or cap on the embodied (carbon) emission of building
    materials for all homes and apartments.
  2. Any future regulation on embodied carbon of materials needs to apply in a holistic manner,
    considering the whole life cycle of the product any regulation on this issue, must not conflict with
    or compromise other energy efficiency, building or related policies.
  3. Where governments are seeking to introduce mandatory embodied (carbon) emission of
    building materials, the scheme should:
    • be designed by industry and led by HIA
    • be applied at a national level, as opposed to it being introduced by an individual state or
    • territory government or with varying approaches across states
    • establish a national industry-agreed methodology and framework for measuring and reporting embodied carbon
    • have the thresholds or caps set based on industry benchmarking data as opposed to theoretical or academic studies
    • follow the preparation of a regulatory impact assessment that can clearly demonstrate a net benefits to society
    • support locally made and manufactured products over imported products
    • recognise and support innovation in products and materials and investments made in producing alternate or lower carbon materials
    • be introduced over a staged approach over multiple years with initial focus on industrial buildings followed by commercial buildings, multi-residential and lastly on houses
    • only apply to the core elements of the building fabric
    • have rating tools and/or calculators as part of measuring embodied emissions that are simple to use and provide consistent outcomes
    • be implemented and enforced as point of sale obligation, as opposed to it being applied through building certification or planning approvals at a building by building level; and
    • have its introduction supported by a comprehensive industry and home owner education program.


Government regulations over the past two decades have focused on policies to reduce the operational carbon emissions through energy efficiency regulations. This has focused on the building fabric and services to reduce energy use, and in turn emissions, from the operational use.

Globally a number of countries are shifting gears and looking at regulating the embodied emissions of the materials going into buildings, as part of their sustainability commitments.

Regulation of embodied carbon in the built environment is gaining momentum. Embodied carbon assessments are being incorporated into planning, building and procurement requirements in a growing number of countries around the world.

Australia does not currently regulate for embodied carbon measurement for building materials, though it is expected that regulation and potential caps or targets will be considered in future regulations as part of broader discussions as Government look to measures as part of their net zero emission commitments.

Policy endorsed by HIA National Policy Congress: May 2023

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