Embodied carbon accountability is here, but is the construction sector ready?

Embodied carbon accountability is no longer a concern on the far horizon – it’s a present-day mandate that will reshape how Australia’s construction sector approaches carbon-related decisions.

The launch of the NABERS Embodied Carbon rating tool, which includes a federally endorsed calculator and ruleset, signals a clear shift: the era of vague promises and green commitments is over. In place will come rigorous scrutiny into how embodied carbon is calculated, verified and penalised when measurements are found lacking.

Pressure is indeed mounting from multiple fronts.

To achieve a Green Star Building rating, projects must reduce upfront carbon by at least 10 per cent; for a 6-star rating, reductions must reach 20 per cent – and up to 40 per cent by 2030.

The Australian Securities and Investments Commission (ASIC) is also looking closely into greenwashing risks and misreporting of scope 3 emissions across supply chains. And the evolving Circular Economy Framework, alongside state and federal policies, will further shape how embodied carbon is disclosed, tracked, and managed across a building’s lifecycle.

Is the industry ready?

Based on the observations of our quantity surveyor team – not yet.

Building meaningful accountability and transparency for embodied carbon requires more than token adjustments. It demands a fundamental shift in how construction companies design, procure, and build for a low-emissions future.

Carbon still an afterthought

Despite a growing awareness around its importance in the built environment, embodied carbon remains an afterthought in most construction projects.

It’s not uncommon for teams to engage our quantity surveyors for embodied carbon calculations weeks before pricing a job – often after designs are finalised, materials selected and plans submitted.

At that point, meaningful change is difficult, impractical and costly, if not impossible.

The NABERS Embodied Carbon rating tool is designed to shift this mindset by placing upfront carbon emissions at the heart of the building lifecycle.

At the minimum, the framework requires project teams to report on the embodied emissions for more than 80 per cent of all materials used in construction – from the substructure to the superstructure, to the envelope and even external works. This includes carbon emissions from the extraction, manufacturing, and transportation of materials.

To meet these requirements, evidence must be provided in the form of delivery dockets for key materials, a Bill of Quantities for non-key materials, and additional supporting documentation.

Teams must also supply Environmental Product Declarations (EPDs) for selected materials, or reference NABERS’ national emissions factors database as a standardised benchmark.

What it will mean is that some of the deliverables in the contract will anticipate the administration of EPDs and a final assessment of the carbon to be completed as part of project, no different than “As-built” documentation.

Forward planning and ongoing measurement are critical during the design and concept stage. Deferring embodied carbon assessments until late in the process risks non-compliance that leads to potential rework, costly delays, and compromised project outcomes.

Equally important is how embodied carbon is measured going forward.

With the release of the official NABERS calculator, third-party tools and benchmarks are no longer valid. A national standard has now been set – and companies serious about sustainability would benefit from ensuring current and future projects align with it.

Thinking differently about embodied carbon

It’s clear Australia’s construction sector needs to be proactive in counting the cost of embodied carbon, but how and where should they start?

While developers can undertake the task of measuring carbon emissions themselves, this time-consuming and meticulous exercise is best left to quantity surveyors.

They are specialists that bring the data, tools and expertise needed to assess the quantity of carbon created across the lifecycle of each material, providing teams with valuable insights and accurate measurement of their project’s entire carbon footprint.

However, project teams can streamline the whole process by considering the areas below beforehand:

• Materials: Have materials been chosen based on their true carbon lifecycle cost that’s tested and backed by an independently verified Environmental Product Declaration? 
• Transport: Is the carbon and cost impact of transporting materials assessed, and are local alternatives a better choice?
• Equipment: Can fossil fuel-powered machinery be replaced with electric alternatives to reduce onsite emissions?
• Design specifics: How do decisions like structure design or floor count influence the project’s embodied carbon?
• Project boundary: Will the carbon footprint account for the full lifecycle, including refurbishment, demolition, and disposal?
• Optimisation: Can designs incorporate the reuse or renovation of existing elements to lower embodied carbon?
• Ancillary costs: How will we measure and manage the carbon impact of indirect costs like site offices and support services?
• Waste: What construction methods are in place to reduce onsite waste generation?
• Future focus: Will the building be disassembled at their end of life and can its various elements be recycled and reused?

Integrating these considerations across the entire project lifecycle helps embed embodied carbon with the same priority as project costs, safety and delivery timelines.

In a regulatory environment that’s increasingly tightening around emissions, that’s already half the battle won. But more importantly, an emissions-first mindset doesn’t just facilitate compliance with evolving sustainability standards – it also leads to better-designed, future-ready buildings.

And that’s a win for both Australia and the planet.