Embodied Emissions Report for Commercial Developments in NSW
A technical overview of regulatory requirements, assessment processes and material disclosure obligations for commercial projects
The embodied emissions report has emerged as a primary analytical requirement in the regulatory landscape of commercial development in New South Wales. It reflects a shift toward recognising the carbon effects of materials, processes and construction practices before a building enters its operational phase. This page presents a detailed explanation of the embodied emissions report for commercial buildings, the legislative basis for its application, and the technical expectations that accompany its preparation. The content is intended for architects, engineers, developers, contract administrators and building owners who require a precise and evidence grounded understanding of the embodied emissions report as part of project approvals.
Regulatory Context for the Embodied Emissions Report in NSW
An embodied emissions report is required for all new commercial developments in NSW from 1 October 2023 under the Sustainable Buildings SEPP. This mandate establishes a structured method for identifying the carbon implications of material selection and construction planning at the earliest formal stages of a project. Since the embodied emissions associated with material extraction, refining, transportation, fabrication and installation account for a major proportion of life cycle carbon, regulators determined that a consistent approach to quantifying these impacts was essential. Over recent years the lack of uniform reporting made it difficult for authorities to compare outcomes, so this requirement was developed to standardise evaluation across the state.
The embodied emissions report for commercial developments focuses solely on non residential building types. It does not include the BASIX pathway, which is reserved for residential projects. The embodied emissions report follows a separate and more detailed methodology suited to the complexity and scale of commercial facilities. This separation is important because the quantity of materials, structural systems, mechanical systems and facade elements differ greatly between commercial and residential construction. Without a clear distinction, the accuracy of assessment outcomes would be reduced significantly.
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Purpose and Analytical Function of the Embodied Emissions Report
The embodied emissions report serves as an evidence driven tool for identifying the carbon load of construction materials before a project proceeds to the building phase. It aims to quantify the impacts of structure, envelope, permanent internal elements, external works and building services. Through this quantification process, the embodied emissions report provides a baseline from which comparative performance can be understood. In large building programs across NSW, this baseline gradually forms a data set that enables benchmarking, policy refinement and long term modelling of carbon reduction strategies.
The embodied emissions report also establishes accountability between the applicant and the approval authority. By requiring the disclosure of material quantities at both the development application and construction certificate stages, the regulatory system ensures that carbon impacts are not overlooked or deferred until later phases. The dual stage reporting process prevents the common issue where design intentions shift during procurement. The embodied emissions report therefore acts as a stabilising mechanism for carbon related decisions within the design and construction continuum.
Scope and Boundaries of the Embodied Emissions Report
The embodied emissions report targets upfront embodied carbon only, which includes the manufacturing stages of materials known as A1 to A3 in life cycle terminology. These stages cover raw material extraction, transportation to the manufacturing site and the manufacturing processes themselves. Although later stages such as installation, replacement or demolition contribute to full life cycle carbon, they fall outside the scope of the embodied emissions report in NSW. This narrow boundary ensures that the data reflects processes that are consistent across projects and easier to quantify without requiring assumptions that introduce uncertainty.
Within these boundaries, the embodied emissions report must address at least eighty percent of the total bill of materials. This threshold is designed to prevent incomplete or selective reporting that excludes high carbon materials. If a building incorporates concrete, steel, facade systems, roofing systems, internal walls and major services, the embodied emissions report must quantify the majority of these materials.
Occasionally a project team may find difficulties sourcing verified data for some specialised components, and while the report allows some flexibility, the eighty percent minimum still applies to uphold integrity. This requirement is very strict but needed.
Material Categories in the Embodied Emissions Report
The structure category covers columns, beams, floor plates, suspended slabs, load bearing walls and similar elements. These are often the most carbon intensive materials in a project, especially where conventional concrete or steel systems are used. The embodied emissions report therefore allocates significant attention to structural quantities, and inaccurate reporting here would impact the overall carbon calculation.
The envelope category includes external walls, facade assemblies, glazing systems, cladding, roofing panels and weatherproofing layers. Because envelope systems are exposed to performance standards like thermal efficiency, fire resistance and weather durability, their material complexity is high. The embodied emissions report must quantify these materials precisely, and designers are encouraged to consider how envelope specification influences embodied carbon outcomes. Some projects mistakenly assume that envelope materials contribute less to carbon, but the report consistently demonstrates otherwise due to the extensive use of aluminium and composite products.
Permanent internal walls and doors sit within a separate category. Although these elements do not typically involve complex manufacturing compared to facade systems, they appear in substantial quantities within large commercial buildings. Their cumulative carbon burden becomes relevant when summed across multiple levels and zones. The embodied emissions report ensures these materials are not disregarded because they do not form part of the building’s structural system. This is one of the areas where early design decisions can produce meaningful reductions.
Services represent another major component of the embodied emissions report. Mechanical, electrical and hydraulic systems contain metals, plastics and manufactured parts that carry embodied carbon from fabrication. The assessment of services is sometimes overlooked by project teams due to perceived complexity, but the regulatory approach requires them to be included. It is important to note that labour or equipment are not counted; the embodied emissions report only quantifies materials.
External works include pavements, hard landscaping, external retaining structures and trafficable surfaces. Their inclusion ensures that carbon associated with site level construction is not separated from the main building, because in many commercial facilities external works represent a major volume of concrete and aggregate. A common mistake in early development applications is to under document these works, but the embodied emissions report corrects that gap.
Methodology and Data Capture Requirements
The embodied emissions report relies on an itemised list of building materials extracted from architectural and engineering documentation. Quantities may come from architectural schedules, structural drawings or civil documentation. The accuracy of measurements is essential because the embodied emissions report forms part of a regulatory submission. For this reason quantities must be certified by a quantity surveyor, designer, engineer or an accredited assessor. This certification ensures that material estimates are consistent with the construction documentation and not produced in an informal manner.
At the development application stage, the embodied emissions report focuses on quantity disclosure. At the construction certificate stage, additional detail regarding emissions conversion factors may be required, particularly when the NABERS embodied assessment tool is used. This staged process ensures that as a design progresses, its carbon information becomes increasingly refined. There are sometimes minor discrepancies between design intentions and final material procurement, but these do not undermine the purpose of the embodied emissions report as long as the disclosure remains accurate at each stage.
Broader Significance of the Embodied Emissions Report
The embodied emissions report supports the long term decarbonisation goals for NSW, especially as operational carbon continues to decrease through renewable energy adoption. As the grid becomes cleaner and buildings become more energy efficient, embodied carbon increasingly forms a larger proportion of total building emissions. Research across Australia indicates that embodied emissions already represent a substantial share of built environment emissions, and this proportion is projected to rise without intervention. The embodied emissions report therefore functions as an essential policy mechanism to address this shift.
Material efficiency plays a major role in reducing embodied carbon. When the embodied emissions report identifies high carbon materials, project teams gain insight into where reductions may be achieved through alternative specification. For example, certain concrete mixes allow supplementary cementitious materials that reduce carbon intensity, while some structural systems can be optimised to use less material. While the embodied emissions report itself does not prescribe solutions, it generates visibility that enables rational decision making. It is sometimes misunderstood as a compliance only document, but its analytical function extends beyond minimum submission requirements.
Recording Low Emission Construction Technologies
The embodied emissions report also requires applicants to disclose whether low emission construction technologies have been incorporated. This includes modern fabrication methods, recycled inputs, material systems with reduced carbon footprints and modular design approaches.
The purpose of this disclosure is not to rank projects but to collect information on emerging construction practices. With time this data contributes to state wide understanding of decarbonisation trends. Some project teams assume that this disclosure is optional, but it is a required component when submitting the embodied emissions report for commercial developments.
Contribution to National Consistency
Although the embodied emissions report is a NSW requirement, its methodology aligns with national efforts to create consistent reporting frameworks. The focus on A1 to A3 life cycle stages, the emphasis on material quantities and the use of emissions factors derived from verified declarations are compatible with national research and industry guidelines. This consistency enhances the reliability of the embodied emissions report and allows NSW projects to contribute data that supports national planning models. In the long term this improves the ability of Australia to track carbon reductions across building lifecycles and across regions.
Practical Considerations When Preparing the Embodied Emissions Report
Professionals preparing an embodied emissions report must ensure that documentation is complete and that all major material categories are captured accurately. Inadequate drawings or incomplete schedules can lead to under reporting, which may cause delays in assessment. Effective coordination between architects, engineers and quantity surveyors becomes essential. A common issue that occasionally appears is inconsistent nomenclature between documents, which can result in materials being double counted or omitted unintentionally. Although this does not change the integrity of the embodied emissions report, it introduces avoidable complications.
When working with large commercial buildings, project teams must also consider how the embodied emissions report interacts with procurement timelines. Early quantity information may not incorporate final material suppliers or precise product selections. While this is acceptable at the development application stage, the construction certificate stage requires more definitive quantities. The embodied emissions report therefore becomes part of the design development process, encouraging teams to finalise material decisions earlier than they normally would. Some practitioners feel this is challenging, but it helps in creating a more transparent carbon profile.
Ensuring Accuracy and Continuous Improvement
The embodied emissions report demonstrates the importance of accurate measurement as a foundation for emissions reduction. It provides a structured method for producing verifiable data that informs broader policy directions. As more commercial developments submit an embodied emissions report, the body of data available to regulators and industry grows, enabling more refined future controls. In addition, repeated use of the embodied emissions report builds familiarity across design and construction practitioners, gradually improving reporting quality and analytical competence.
The embodied emissions report will continue to evolve as more data becomes available and assessment tools are expanded. While the current approach emphasises upfront carbon, future policy directions may consider broader life cycle stages. For the immediate future, the embodied emissions report remains a critical requirement that supports NSW’s transition toward lower carbon commercial development. With ongoing attention to accuracy, transparency and professional diligence, the embodied emissions report will play a significant role in shaping the built environment’s carbon trajectory.