ESG Journal

Low Embodied Carbon Materials as EU Product Rules Take Effect

Close view of a wall of pale rough-faced stone bricks with dark mortar joints

Low embodied carbon materials are building products whose extraction, manufacture, transport and installation release less greenhouse gas than conventional options that do the same job. They matter more every year because a building’s embodied carbon is spent before the doors open, and two European rules that began in January 2026, the Carbon Border Adjustment Mechanism and the new Construction Products Regulation, make that carbon easier to see and to price.

Key takeaways

  • Embodied carbon is the greenhouse gas released in making, moving, building, maintaining and demolishing a building, as opposed to the operational carbon from running it.
  • Cement and steel alone are responsible for around 18 per cent of global emissions, according to the UN Environment Programme’s 2024/2025 buildings report.
  • The EU’s Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026, covering imports of iron and steel, aluminium and cement, among other goods.
  • The revised EU Construction Products Regulation began to apply on 8 January 2026, with a duty to declare the carbon footprint of products as harmonised standards are updated and a legal basis for digital product passports.
  • The largest savings usually come from reuse, from structure and from lower-carbon concrete and steel.

What are low embodied carbon materials?

Embodied carbon covers every stage before and after use: raw material extraction, manufacturing, transport, construction, maintenance, replacement and end of life. Practitioners often focus on “upfront” carbon, the share released before a building is occupied, because it cannot be reduced later. Low embodied carbon materials are those that cut this figure by using less material, using recycled or reclaimed content, using cleaner production or storing carbon in the product.

Operational carbon, from heating, cooling and lighting, falls as grids decarbonise and buildings become more efficient. Embodied carbon does not fall by itself, so its share of a building’s lifetime emissions grows. The UK Green Building Council explains the difference in its guide to embodied carbon in construction.

Which low embodied carbon materials work best?

Reused components

Keeping an existing structure, or reusing beams, bricks, façade elements and fittings, avoids the manufacturing emissions of new material almost entirely. It requires early surveys and flexible design.

Recycled steel and aluminium

Steel made from scrap in electric arc furnaces generally has far lower emissions than steel made from iron ore, and recycled aluminium needs only a fraction of the energy of primary metal. Ask suppliers for the recycled share and the production route.

Lower-carbon cement and concrete

Cement production is a major source of emissions. Blended mixes that replace part of the cement with by-products such as ground granulated blast-furnace slag or fly ash, and designs that use less concrete in the first place, can lower the figure considerably. Always compare options on the same declared basis.

Timber and other bio-based materials

Responsibly sourced timber, bamboo, hemp and straw store carbon taken from the air while they grow. They need careful detailing for moisture and fire, and sourcing evidence matters. Our article on sustainable materials explains how to compare them with other choices.

Earth and lightly processed materials

Rammed earth, compressed earth blocks and lime-based products need little energy to make and suit some climates and building types well.

What changed in January 2026?

The Carbon Border Adjustment Mechanism

The European Commission’s CBAM page explains that the mechanism moved from its reporting-only transitional phase to its definitive phase on 1 January 2026. Importers bringing in more than 50 tonnes a year of covered goods must hold authorised declarant status and, from 2027, buy certificates that reflect the emissions embedded in imports. Covered goods include iron and steel, aluminium and cement, three of the most carbon-intensive building inputs. The effect is to put a price on embodied carbon at the border and to reward producers that can document lower emissions.

The Construction Products Regulation

Regulation (EU) 2024/3110, which entered into force on 7 January 2025, began to apply on 8 January 2026. According to industry guidance, manufacturers must declare the global warming potential of their products as the relevant harmonised standards are revised, with cement and steel among the first families, and the regulation creates the legal basis for a digital product passport for construction products. Read the regulation on EUR-Lex for the exact wording. It sets declaration duties rather than limits, so designers still need their own targets.

How can designers specify low embodied carbon materials?

  1. Set a carbon target per square metre early, and test the structure first, because it usually carries the largest share.
  2. Compare products using environmental product declarations prepared to the same standard and covering the same stages.
  3. Survey the site for reusable material before ordering anything new.
  4. Ask suppliers for the recycled content, the production route and the transport distance.
  5. Check delivered products against the specification, and record the results for the next project.

Our guide to what a net zero building is shows how embodied carbon fits into whole-life targets.

Frequently asked questions

What is the difference between embodied carbon and operational carbon?

Embodied carbon is released by making, transporting, building, maintaining and demolishing a building. Operational carbon is released by running it, for example by heating, cooling, lighting and equipment. A whole-life assessment adds the two.

What are examples of low embodied carbon materials?

Reused structural elements, scrap-based steel, recycled aluminium, concrete with a high share of cement replacements, responsibly sourced timber, bamboo, earth and lime-based products are common examples. The right choice depends on the structure, climate and local supply, so compare declared data.

Does the Construction Products Regulation set embodied carbon limits for buildings?

No. It concerns declarations about products and the infrastructure for product data. Limits and reporting duties for buildings come from other rules, such as national codes and the whole-life carbon requirements in the Energy Performance of Buildings Directive.