Whole Life Carbon

What’s happening in the EU?

The EU is moving fast. New provisions in the recast Energy Performance of Buildings Directive (EPBD), backed by initiatives like the BuildingLife Roadmap, are pushing Member States toward mandatory WLC assessments and establishing lifecycle Global Warming Potential (GWP) measurement frameworks by 2028, with a roadmap to set limit values by end of 2027 (BPIE). Meanwhile, frontrunners like France, Denmark, and the Netherlands are already enforcing binding WLC limits (2050-materials.com).

At Sustainabuild Ltd, we’re closely monitoring emerging regulations. Recently, we have been focusing on Whole-Life Carbon (WLC) - the concept of accounting for emissions from embodied, operational, and end-of-life stages in the built environment. As the industry shifts from focusing only on operational energy use to considering the full cradle-to-grave impact of buildings, WLC is becoming the gold standard.

What about our neighbour Spain?

Spain is also taking significant steps. Through the INDICATE project and related national initiatives, Spain has been developing data-driven benchmarks for embodied carbon in buildings. These benchmarks are shaping early WLC policies and helping to define practical pathways for lifecycle assessment across the construction sector (BPIE, GBCe). This positions Spain as a regional leader in applying WLC approaches and offers Gibraltar valuable insights on how benchmarks can be rolled out in practice.

How is the UK responding?

The UK is aligning through industry-led programs and standards. Most notably, the RICS Whole Life Carbon Assessment (WLCA) 2nd Edition became effective on 1 July 2024, offering a coherent methodology that spans embodied and operational emissions (rics.org). A proposed update to UK Building Regulations “Part Z”would soon require mandatory WLC reporting and potentially carbon limits for new developments (OneClick LCA). Public procurement rules already incentivise WLC transparency through requirements for Scope 3 (embodied) emissions in Carbon Reduction Plans (One Click LCA)

What about Gibraltar?

Though not an EU Member State, Gibraltar has ambitious net-zero goals, targeting carbon neutrality by 2030and a 50% emissions reduction by 2035, under its 25-Year Environmental Plan (25 Year Env Plan). The Climate Change Act 2019 also commits Gibraltar to robust GHG inventory reporting and a net-zero emissions target by 2045 (Gibraltar Laws).

The recently introduced Environmental Governance (Targets) Regulations 2025 mark a significant step in setting statutory long-term targets for air quality, water, biodiversity, and waste reduction. However, a gap remains in Gibraltar when it comes to addressing the substantial carbon and material impacts of the building sector, making whole life carbon (WLC) methodologies particularly relevant.

While formal WLC regulations are not yet in place, Gibraltar's commitments and close alignment with UK and international standards suggest it will likely follow suit, integrating WLC assessments in building policy and procurement over time.

Why this matters:

WLC ensures decisions reduce total carbon impact, not just operational energy.
Early adoption ensures compliance with upcoming standards in the EU, UK, and beyond.
Gibraltar can lead by integrating WLC practices ahead of regulation to build resilience and credibility.

At Sustainabuild Ltd, we help clients navigate WLC methodologies, embed best practices, and prepare for evolving regulatory landscapes. If you’re planning a project or want to explore how Whole-Life Carbon assessments can be adopted for your developments, let’s connect!