SUSTAINABILITY
Cement
As mentioned in our construction section, we previously mentioned that public bodies would receive new guidance relating to the design of projects and procurement of cement and concrete products, with the intent of achieving a consistent approach to reducing embedded carbon in construction.
Taking account of actions in the Climate Action Plan, the inter-departmental Cement and Construction Sector Decarbonisation Working Group considers that projects commencing design from 1 September 2024 are required, at a minimum, to follow certain standards and practices, described here. Extracts are set out below:
- Public bodies should be guided by best-practice carbon management design approaches, including avoidance of over-specification of materials, when undertaking or procuring construction projects.
- Concrete products procured by public bodies, or used in publicly produced construction projects, including poured or pre-cast products, should in general specify a minimum of 30% clinker replacement, consistent with IS EN 206 ....
- High-carbon CEM I cement products should not be procured by public bodies, or used in publicly produced construction projects...
- Public bodies should seek an Environmental Product Declaration, to an EN 15804 standard, or equivalent when directly procuring cement or concrete products. Confirmation of a similar disclosure should be sought by public bodies, where a contracted party is managing materials procurement. When available, public bodies should require a Declaration of Performance and Compliance under the Construction Product Regulation.
- From 1 September 2025, public bodies that are commencing design for new buildings for projects in receipt of exchequer funding in excess of €10 million in the case of non-residential buildings, or in excess of €60 million in the case of residential buildings, should produce or procure a Whole Life-Cycle Greenhouse Gas Emissions assessment in accordance technical guidance to be provided by SEAI in 2025, consistent with the Energy Performance of Buildings Directive. Subject to a review of the first step, from 1 June 2026, projects in receipt of exchequer funding in excess of €5 million in the case of non-residential buildings, or in excess of €30 million in the case of residential buildings, should produce such an assessment. Projects below this scale should also consider implementing this assessment.
- Public bodies procuring infrastructure projects (construction other than buildings) in receipt of exchequer funding in excess of €60 million, should produce or procure a Whole Life-Cycle Greenhouse Gas Emissions assessment for their project. From 1 January 2026, projects in receipt of exchequer funding in excess of €10 million should produce such an assessment. Public bodies should identify the most appropriate, available methodology to ensure that the project's embodied carbon is suitably interrogated, and applicable to the infrastructure or project-type. Projects below this scale should also consider implementing this assessment. Data produced for Building Information Modelling (BIM), introduced under the Capital Works Management Framework can, in most cases, also be used to produce this assessment.
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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.