CARBON MEASUREMENT
B
ack in 2022, when Citigroup launched a transformation project for
its EMEA headquarters shaped by the bank’s ambitious net- zero commitments, embodied carbon became big news for anyone involved in the built environment. Te project is no mere facelift, but a major upgrade to maximize the reuse potential of materials and the specification of equipment to reduce embodied carbon. Te foodservice industry
took its time to catch up. Embodied carbon was a fringe issue even one year ago, but somehow a fuse was lit and it is now firmly in the spotlight. “So much has changed,” says
FCSI Senior Associate Lauren Hunter, sustainability director of Invito Design in the UK. “People wanted a signal from the industry that this was not a niche issue and that it was not going away. Initially, it was seen as just another trend, but Te Palace Framework provided the first rumble that something was coming.”
Hunter has been a driving
force in drawing attention to embodied carbon, and she played a central role in creating Te Palace Framework, specifically acting as the chair of the working group focused on adapting the Chartered Institution of Building Services Engineers (CISBE) TM65 methodology for commercial catering equipment. TM65 provides a
standardized method to
calculate the embodied carbon of mechanical, electrical, and plumbing (MEP) products in the absence of Environmental Product Declarations (EPDs) – verified, transparent documentation based on life cycle assessment data that reports the environmental impact of a product from manufacture, through installation, to disposal. TM65 is seen as a critical,
internationally applicable first step to evaluating carbon emissions when manufacturers have no detailed EPDs, but it has its shortcomings when applied to foodservice. Te criteria used for general building services are a poor fit for complex commercial kitchen environments, and it gives manufacturers a heavy compliance burden. Te Palace Framework
provides a new, specialized benchmark for embodied carbon specifically within the hospitality and catering equipment sector and is a
big step towards increasing carbon transparency.
CATCHING THE REGULATORY TIDE
Te emergence of the new framework is timely, given that UK and EU legislation is embracing embodied carbon. Te UK government is prioritizing the reduction of embodied carbon with a focus on measuring, reporting, and setting voluntary standards. Its efforts will include a national embodied emissions reporting framework and partnering with industry to introduce product standards and improve data gathering. Te EU’s requirements
for Digital Product Passports (DPPs) – digital records of data on sustainability, circularity, and supply chain issues from manufacturing to recycling – under the Ecodesign for Sustainable Products Regulation (ESPR) are accelerating, with a major focus on appliances, including dishwashers and laundry equipment.
“This is now a real thing. Now, 49% of manufacturers are measuring embodied carbon, which is a big step up from just 10% a year ago”
BREEAM 7, which went
live in late 2025, now requires comprehensive reporting and benchmarking of embodied carbon across the building life cycle as a key component for high-level ratings. “Tis is now a real thing.
Now, 40% of manufacturers are measuring embodied carbon, which is a big step up from just 10% a year ago. Cost and carbon are the same thing, so looking at the whole life of equipment is what gives you a good view of what to specify,” says Hunter.
“Cheap equipment will not
last, but we are seeing a long- term perspective emerge,” she adds. “People are questioning the marketing speak, energy monitoring equipment is everywhere and is exposing differences in performance, and there is now a real conversation around cost. “People are realizing
that capex and opex are the same – they are costs, the only difference being that one is
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