Review Finds No Common Mandatory Carbon Reporting Framework

A structured narrative review published in Architectural Research examines how building-level calculation methods, product data, and assessment results are connected within embodied-carbon certification and regulation systems. The study, authored by Jin Chul Park and colleagues, analyzes domestic and international standards to determine whether existing instruments establish a common mandatory building-level embodied-carbon reporting and limit-value framework. The authors conclude that while various jurisdictions have adopted different policy measures, no single unified mandatory framework currently exists to standardize reporting and limit values across the building sector.

The review defines upfront embodied carbon as greenhouse gas emissions released during the product stage, specifically modules A1 through A3, and the construction stage, modules A4 through A5, before a building enters use. This definition follows the life-cycle module framework established by EN 15,978. The study distinguishes this upfront carbon from whole-life embodied carbon, which includes material-related impacts from production through use-stage maintenance, repair, replacement, and refurbishment to end of life. As operational energy demand is reduced through insulation and efficient equipment, embodied carbon can represent a larger share of whole-life greenhouse gas emissions, making its assessment increasingly critical for climate mitigation.

The buildings and construction sector consumes 32% of global energy and contributes 34% of global CO2 emissions, according to the Global Status Report for Buildings and Construction 2024/2025. These shares underline the sector’s importance for climate mitigation. Building policy has widely addressed operational energy, but embodied-carbon assessment extends this focus to materials and construction. Upfront emissions occur before occupation and cannot be avoided through later improvements in operational energy efficiency, requiring attention to material selection, structural design, and construction planning before construction begins.

The study identifies three main streams in recent international trends regarding embodied carbon. The first development is mandatory calculation and disclosure, exemplified by the recast Energy Performance of Buildings Directive, which requires life-cycle global warming potential calculation and disclosure on Energy Performance Certificates from 2028 for new buildings larger than 1,000 square meters and from 2030 for all new buildings within its scope. Sweden’s climate declaration has required A1–A5 reporting since 2022, marking an early adoption of mandatory disclosure in the region.

A second development is the adoption of statutory limits. France introduced RE2020 for housing in 2022, and Denmark introduced BR18 climate requirements in 2023, followed by tightening in 2025. Under the Energy Performance of Buildings Directive, Member States must publish national limit-value roadmaps by 2027. These legal commitments and future implementation dates are distinguished from requirements already in operation, highlighting the phased nature of regulatory adoption across different jurisdictions.

The third development involves assessment through voluntary certification and professional standards. LEED v5 BD + C includes the required item to quantify and assess embodied carbon, and BREEAM V7 sets whole-life carbon assessment requirements under Mat 01. In the UK, the Net Zero Carbon Buildings Standard remains a voluntary framework. These voluntary frameworks are distinct from national statutory limits, and product-focused instruments such as the Carbon Border Adjustment Mechanism address emissions through different legal mechanisms, illustrating the diversity of policy options available to regulators.

The review compares institutional arrangements rather than ranking national emission values, noting that values in the analyzed tables are not numerically ranked. Denmark’s principal 2025 cap applies to specific modules over 50 years, with a separate cap for A4–A5, while France’s Ic construction uses a 50-year dynamic assessment that excludes operational energy. The Netherlands’ MPG limit applies to a weighted environmental-cost indicator rather than to carbon alone. Sweden’s declaration covers A1–A5 without an adopted numerical limit in the reviewed sources, demonstrating the variability in how different countries define and apply their carbon metrics.

In Korea, the Framework Act on Carbon Neutrality and Green Growth was enacted in 2021, but the reviewed instruments do not establish a common mandatory building-level embodied-carbon method and reporting framework linked to national limit values. Existing domestic guidance and international-standard references are available, but they are not linked through such a framework. The G-SEED certification system, introduced in 2002 and reorganized in 2013, is the most widely used certification system in the domestic building sector, with approximately 23,000 cumulative certifications reported. It includes a voluntary building life-cycle assessment item under Innovative Design, awarding points for full and streamlined LCA with third-party verification.

The G-SEED rules cover production, construction, use, and end of life, requiring a maintenance-stage scenario based on a 50-year building life. Supporting references include ISO 21931-1:2010 and EN 15804:2012, but a supporting-reference list does not by itself demonstrate mandatory conformity to every provision of those standards. ZEB certification, introduced in 2017, evaluates annual primary energy demand per unit area and energy self-sufficiency, but no embodied-carbon or building-LCA item was identified in the Korea Energy Agency’s published certification criteria reviewed in the study. This is recorded as an assessment-scope limitation rather than as a self-defined embodied-carbon method.

The comparison reveals that certification schemes and building-level standards did not emerge in a uniform order. BREEAM, LEED, and the Korean green building certification scheme predate EN 15978:2011. International frameworks combine these connections differently, with LEED and BREEAM using building-LCA standards or tool-conformity rules alongside their own scoring. National regulations prescribe reporting boundaries and compliance metrics, sometimes through adapted methods. The policy issue for Korea is how to align existing methods, product information, and certification with a common reporting framework, a challenge that requires structural coupling of calculation standards and certification systems.

Four policy measures follow from the comparison: coordinate building-level methods, integrate assessment with certification, assess and improve product data, and establish disclosure and benchmark processes before limits. The responsible bodies and timeframes are proposals based on institutional functions, not an agreed implementation plan. Standards coordination and data improvement can begin in parallel, but mandatory reporting and limits require progressively stronger evidence. Developing a common national building-level calculation method involves aligning existing domestic guidance and international standards around agreed modules, physical scope, biogenic-carbon rules, area definitions, and reporting templates.

Strengthening certification links to the common method requires aligning G-SEED’s existing voluntary full and streamlined LCA routes with consistent reporting requirements before any increase in mandatory coverage is considered. ZEB would require a distinct embodied-carbon item if its remit were expanded. Certification points and statutory carbon limits should remain explicitly distinguished to avoid confusion in policy implementation. Auditing and improving product data in parallel with method development involves mapping the availability, age, representativeness, and verification status of data for major construction materials, a task that does not establish the extent of any national coverage shortfall but should identify priorities before expansion.

Introducing disclosure and developing benchmarks before limits requires using explicit transition conditions. A registry could be coordinated with pilots in public building projects once the reporting method, minimum physical scope, and data-quality rules have been agreed. Disclosure for large new buildings would follow in the medium term, only after these pilots demonstrate reproducible calculation and verification. Several reporting cycles should then be used to examine distributions by building type, physical scope, and structural system. Limits should be considered in the longer term only when the coverage, representativeness, and independent verification of these data are adequate, ensuring that any limit specifies whether it covers A1–A5, material-related whole-life impacts, or operational emissions as well.

The narrative review does not provide harmonized building calculations, an exhaustive database-search record, or a quantitative audit of Korean EPD/LCI coverage. Its findings are limited to the cited instruments and versions, and future work should test reporting consistency on Korean residential projects and assess the data quality, verification effort, and sample representativeness needed for national benchmarks. The study emphasizes that the comparison is structural, showing when instruments were introduced, not whether instruments of the same kind impose equivalent requirements, as legal status, covered buildings, module coverage, and reference periods all differ across jurisdictions.

Subject of Research: Analysis of domestic and international standards and certification systems for upfront embodied carbon in carbon-neutral buildings

Article Title: Upfront Embodied Carbon for Carbon-Neutral Buildings: Trends and Analysis of Domestic and International Standards and Certification Systems

Article References: Park, J. C., Song, Y. W., Kim, S. E., & Hwang, S. W. (2026). Upfront Embodied Carbon for Carbon-Neutral Buildings: Trends and Analysis of Domestic and International Standards and Certification Systems. Architectural Research, 28(1), Article 32. https://doi.org/10.1007/s44515-026-00036-8

Image Credits: AI Generated

DOI: 10.1007/s44515-026-00036-8

Keywords: embodied carbon, building standards, carbon neutrality, life-cycle assessment, green building certification, environmental policy, construction emissions, regulatory frameworks, sustainable architecture, climate mitigation, Upfront, Embodied