IStructE has written to Michael Gove, secretary of state at the Department for Levelling Up, Housing & Communities (DLUHC), to query the omission of any regulation of embodied carbon the Future Homes Standard and Future Buildings Standard consultation.
Consultation on the proposals closed at the end of last month.
The institution described the omission as “a missed opportunity to regulate embodied carbon to meet the UK’s net zero legal commitments”.
IStructE said that previous commitments from DLUHC to consult on embodied carbon regulation would have made this consultation the perfect occasion to gain feedback from industry.

In its response, IStructE also raised concerns about the phrase “net zero ready” being used in the consultation to refer only to operational carbon emissions. This is despite that half the lifetime emissions of a new home being due to embodied carbon, which accounts for 10% of UK emissions and is a figure that continues to rise as the national grid decarbonises. IStructE suggests that this could leave the UK open to legal challenge on whether the legislation met net zero commitments.
Will Arnold, head of climate action, at the Institution of Structural Engineers, said: “It's disappointing that embodied carbon was excluded from the consultation. Our letter urges DLUHC to consider consistent regulation, aligning the UK with global standards. Our view is that a building is only net zero if its whole life carbon emissions are considered.”
Technical director Patrick Hayes added: “Introducing embodied carbon regulation provides certainty, consistency and efficiency for all parties on how to meet our legal obligations. It ultimately reduces the burden on business and reduces costs of transitioning to net zero by introducing a level playing field.”
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