Embodied carbon - The time for action is now

The rules have changed – and the writing’s on the wall

When it comes to embodied carbon, the age of voluntary virtue-signalling and vague commitments is ending. Carbon accountability is here – and it’s being hardwired into the system. Consider:

• Targets with teeth – Australia must submit a new 2035 emissions target and Nationally Determined Contribution to climate action under the Paris Agreement by year’s end.

• Financial disclosures – As of 1 January 2025, mandatory climate-related financial disclosures have landed. Scope 3 emissions reporting is required from Year 2. ASIC, the Australian Securities and Investments Commission, will be on the hunt for greenwashing.

• Policy with purpose – Policies and government guidance shaping the market. New requirements are emerging at federal and state levels, influencing how materials are measured, disclosed and managed.

• Green Star goes harder – Projects chasing a Green Star Building rating must cut upfront carbon by at least 10%. Six Star seekers? They’re looking at 20% today, rising to 40% over time.

• Circular is the new straight – The federal Circular Economy Strategy wants to double Australia’s material circularity by 2035, with embodied carbon in the mix.

These are meaningful changes. But for the built environment, the loudest knock on the industry’s door is the release of the NABERS Embodied Carbon rating tool.

Australia now has a government-backed, audit-ready framework to measure emissions embedded in materials and construction.

And yet, on the ground, only a handful of players have read the writing on the wall.

The gap between promise and practice

For those close to the day-to-day realities of construction, the gap between industry narrative and actual behaviour is stark.

Embodied carbon is being talked about everywhere – in design journals, construction conferences, government strategies and sustainability reports. But the conversations are not yet translating into rigorous measurement on the ground.

Altus Group has been thinking about embodied carbon for some time. (You can explore our previous insights on why embodied carbon is so critical in construction, and why a standard method of measurement matters.)

Too often, teams come to quantity surveyors asking for embodied carbon assessments without fully understanding what they’re asking for. Design decisions are made on shaky assumptions. Materials are compared without lifecycle context. Most measurement happens far too late to change anything.

We see it every day.

Shared standard, real results

The NABERS Embodied Carbon rating tool doesn’t just measure embodied carbon emissions. It also eliminates ambiguity and excuses.

For too long, we have seen a multitude of embodied carbon calculators applied, relying on third party benchmarks where the data accuracy was questionable at best. Sometimes, this wasn’t much better than Googling a number.

The evidence required to achieve a NABERS Embodied Carbon rating is extensive – and includes onsite delivery dockets for key materials, a Bill of Quantities as a minimum for non-key materials, along with a raft of other documents. NABERS also offers a new national emissions factors database as a trusted baseline in the absence of Environmental Product Declarations (EPDs).

The only variable is the data project teams input. And even that is scrutinised by a NABERS Accredited Assessor to ensure it complies with strict quality standards for data gathering, interpretation and application.

No more back-of-the-envelope assumptions. Shared standards are how we shift behaviour, build trust in processes and enable meaningful action at scale.

Form follows footprint

The baselines are set. Now it’s about when, not whether.

Too many still leave embodied carbon calculations until it’s too late – in some instances at the tender stage when builders have just weeks to price a job. By then, the most carbon-intensive decisions – structure, materials, form — are already cast in concrete, figuratively and literally.

It’s like value management: the design and cost opportunities on Day 1 is vastly greater than Day 300.

Designing for lower embodied carbon isn’t just about choosing greener products. It’s about using fewer materials. Planning for long life, loose fit. Designing for disassembly. Sometimes, not building at all. These decisions are made when embodied carbon is part of the design brief, not an afterthought.

Where are we heading?

When it comes to embodied carbon, Australia’s construction industry is in what the Gartner Hype Cycle calls the “trough of disillusionment”. Overenthusiasm has waned. The hard work has begun, and the plateau of productivity seems a long way off.

But it’s coming. ASIC will expect companies to prove what they report. Green Star rating requirements will ratchet up. More governments will mandate embodied carbon assessments for major developments. International policy will push capital towards low-carbon projects.

Meanwhile, NABERS has handed the industry a ready-to-use tool – one that is backed by government, industry associations and an extensive database of emissions factors. Most importantly, it is updated regularly to keep pace with industry leadership and our understanding of embodied carbon.

Now, we must align design, delivery and data. To embed upfront carbon thinking from the outset. And to shift from box-ticking to bottom-line outcomes.

How can Altus Group help?

At Altus Group, we are proud to be NABERS Accredited Embodied Carbon Assessors, bringing our expert knowledge in sustainability to help drive meaningful environmental outcomes in the built environment.

Our team operates independently and strives to deliver accurate, transparent and consistent NABERS ratings. By evaluating the embodied carbon in construction materials and processes, we empower our clients to make informed decisions that reduce carbon impacts and support Australia’s transition to a low-carbon future.

With Altus, you gain a trusted partner committed to advancing sustainability through industry-leading assessment and insight. Learn more about our Development Advisory services.

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