Growing the market for low carbon industrial products: policy framework

Closes 15 Sep 2025

Chapter 2: The Embodied Emissions Reporting Framework: overview and cross-cutting considerations

This chapter seeks views on the purpose of the EERF, including which features would most benefit the producers and buyers of steel, cement, and concrete. It proposes guidance on embodied emissions reporting as the first phase of the EERF, while also developing an IT system to simplify and reduce the costs of reporting, ensuring the data is more accessible and easier to compare. 

2.1. Do you agree or disagree that producers and buyers of in-scope products are the main intended end users of the EERF? Are there any additional end users that should be considered? Please explain your reasoning.
2.2. What do you consider are the benefits of measuring and reporting embodied emissions?
2.3 . Do you believe that there are barriers to measuring and reporting embodied emissions?
2.4. If you are a producer or practitioner, do you currently measure embodied emissions? If so, please provide details of the processes, methodologies and standards that you follow, as well as any secondary data that you may use.
2.5. If you currently measure embodied emissions, what are the costs of this activity? Please provide context.
2.6. Do you agree or disagree with the government’s proposal to initially introduce the EERF on a voluntary basis? Please explain your reasoning.
2.7. Do you agree or disagree that a potential transition to a mandatory approach to reporting embodied emissions of products in the longer-term could be beneficial? Please explain your reasoning and whether you see any risks or opportunities.
2.8. Should there be a common methodology and standard for EERF guidance and should this represent best practice or minimum requirement? Explain your reasoning.
2.9. Do you agree or disagree that the initial EERF guidance should focus on life cycle assessment (LCA) based approaches to reporting? Please explain your reasoning.
2.10. Is there anything else that the government should consider regarding maximising use of existing data?