The construction sector is undergoing a rapid transformation. From design stage planning to public procurement and project delivery, suppliers are now under mounting obligation to disclose the embodied carbon of their products—particularly the upfront carbon (A1–A3, sometimes A1–A5) emissions associated with raw material extraction, manufacturing, transport, and installation.
At LCMH, we see suppliers across Australia and globally grappling with new reporting frameworks, rating schemes, and procurement rules. This article explores the obligations driving supplier disclosure, what product information designers and contractors now require, and the common challenges suppliers face when providing carbon data.
The Regulatory and Market Forces Driving Supplier Disclosure
1. Corporate Reporting Obligations
EU Corporate Sustainability Reporting Directive (CSRD) and ESRS: Large companies must disclose Scope 3 and value-chain emissions, cascading data demands down to material suppliers.
Corporate Sustainability Due Diligence Directive (CS3D): Requires companies to identify and address environmental impacts in their supply chains, pushing construction materials into scope.
2. Product Passports and Traceability
Ecodesign for Sustainable Products Regulation (ESPR): Introduces Digital Product Passports (DPPs) for construction products by 2027. Suppliers must provide verified product carbon footprints (PCFs) and environmental product declarations (EPDs) in structured, machine-readable formats.
3. Procurement and Buy-Clean Policies
United States: GSA and Buy-Clean programs require low-embodied carbon (LEC) materials with facility-specific EPDs and GWP thresholds for concrete, steel, asphalt, and glass.
California: Mandates EPDs with maximum GWP limits for key materials, such as steel, rebar, glass, and insulation.
UK: Central government tenders (PPN 06/21) demand Carbon Reduction Plans, pushing suppliers to provide data to prime contractors.
4. Building Regulations and Rating Schemes
London Plan Whole-Life Carbon (WLC): Requires upfront carbon disclosure for major developments.
Nordics: Sweden and Denmark mandate climate declarations and embodied-carbon limits for buildings; the EU will extend disclosure to all new buildings ≥1,000 m² by 2028.
Australia:
NABERS Embodied Carbon – prioritises product-specific EPDs over generic factors, creating growing demand for verified A1–A3 (and increasingly A4/A5) data from suppliers.
Green Star Buildings - makes upfront carbon a mandatory credit, requiring designers to demonstrate reductions in A1–A5 emissions against a reference case. The guidance and FAQs emphasise the use of product-specific EPDs as the preferred evidence source.
NSW SEPP (Sustainable Buildings SEPP) – makes upfront carbon reporting a compulsory requirement for Development Applications.
NSW Decarbonising Infrastructure Policy – mandates embodied emission reductions on state level infrastructure projects.
What Information Suppliers Are Expected to Provide
At Design Stage
At the design stage, EPDs aligned to EN 15804+A2 are now standard, providing declared units such as per cubic metre of concrete, per kilogram of rebar, or per square metre of insulation. These declarations must include GWP values for lifecycle modules—at minimum A1–A3, with A4 and A5 data increasingly requested—as well as metadata such as the relevant product category rules, verifier details, validity period, and assumptions like transport distances or energy mix.
At Procurement and Construction Stage
At procurement and construction stages, requirements expand further. Project-specific transport data must be provided, including plant of origin, transport mode, distances, and fuel type. Site-specific impacts such as packaging waste and on-site energy use are often required where available. Suppliers are also asked to demonstrate compliance with Buy-Clean or government GWP thresholds, and in some cases to provide batch or facility IDs to ensure traceability at project level.
The Challenges Suppliers Face
Meeting these expectations is not straightforward. Developing EPDs requires life-cycle assessment modelling, third-party verification, and program fees that can run into tens of thousands of dollars for each product line. Many suppliers struggle to keep pace with rapidly evolving standards: the transition to EN 15804+A2 has already rendered many older EPDs invalid, and regional differences in product category rules add further complexity.
Data gaps remain one of the biggest obstacles. Gathering accurate information on energy, fuels, and material inputs across multiple plants and subcontractors can be resource-intensive. Product variation compounds the challenge, as a single line may include dozens of mixes, coatings, or strength classes, each of which materially affects GWP values. For suppliers that cannot demonstrate compliance, the risk is significant: projects may be delayed, or products substituted at the last minute.
Finally, misalignment between supplier data and the tools used in practice creates frustration. Generic or non-compliant data is often downgraded or rejected by NABERS, Green Star, and international tools, diminishing its usefulness to clients and undermining the supplier’s competitive position.
How Suppliers Can Respond
Remaining competitive in this environment requires suppliers to take a strategic approach to data. Building robust pipelines that integrate plant-level information on energy and materials into enterprise systems can make EPD generation more efficient. Verified EPDs need to be published and maintained in line with EN 15804+A2, refreshed every five years or after significant process changes.
Equally important is the move from static PDF reports toward structured datasets in CSV or JSON formats. These digital-ready outputs will not only meet today’s rating tool requirements but also prepare suppliers for the coming era of Digital Product Passports. Differentiating data by plant or product variant, and flagging which lines comply with procurement thresholds, helps suppliers stand out while ensuring compliance.
Where LCMH Can Help
At LCMH, we specialise in enabling suppliers to meet these obligations through:
Nulla AI
Helps suppliers embed upfront carbon data directly into project workflows, ensuring their products are considered in design, procurement, and verification stages. Nulla also opens new opportunities for suppliers to attach carbon value directly to their invoices, turning carbon performance into a measurable differentiator.Unified Supplier Platform
LCMH provides a central, credible platform where suppliers can showcase their products and environmental impact. This enhances visibility with designers, contractors, and government agencies actively sourcing low-carbon solutions.
By equipping suppliers with credible, structured, and verifiable carbon data, we help them stay compliant, win bids, and differentiate in a carbon-conscious marketplace.
Key Takeaway
Suppliers are no longer optional players in carbon reporting. They are central to project compliance and client decision-making. Those who invest early in producing high-quality, digital-ready carbon data will be best placed to succeed as embodied carbon rules continue to tighten around the globe.