Members of the FIS sustainability group have come together to respond to the Government consultation on addressing carbon leakage risk to support decarbonisation – see: Addressing carbon leakage risk to support decarbonisation

As part of its plan to measure and reduce carbon emissions, the Government is considering a range of potential policy measures which include a carbon border adjustment mechanism (CBAM), mandatory product standards (MPS) amongst other policy measures to help grow the market for low carbon products. They are also considering emissions reporting.

The main points raised by the FIS group is that the construction industry has been measuring embodied carbon emissions from products for decades. EPD are well established and recognised as a mean to measure the environmental impact of construction products. In addition, the industry has recognised for a long time that measuring the environmental impact of products should not be done on a per tonne basis, first because it is not an appropriate measure for all construction products, but also because construction products are part of a larger system to fulfil a performance, eg: strength, acoustic or thermal. Comparison of the impact of products should be done in the context of their use, at building or product system, and could be done against a functional unit.

The other aspect that has been covered in the consultation is that the system the Government puts in place should be in line with the EU approach since most products imported come from the EU and the EU is a major market for the export of construction products.

To find out more details of the FIS response to the consultation, contact Flavie Lowres at