BEAMA publishes new evidence to help shape UK’s proposed Embodied Emissions Reporting Framework

UK trade association BEAMA has published new industry research and a five-point policy position to help shape the UK Government’s proposed Embodied Emissions Reporting Framework (EERF). 

BEAMA welcomes the Government’s ambition to improve the consistency and comparability of product environmental data. However, it warns that requiring full Environmental Product Declarations (EPDs) as the default reporting route for individual products could add an estimated £1.58 million in costs for electrotechnical manufacturers. 

The estimate is based on survey findings showing that moving from a self-certified assessment to a full EPD adds an average £3,240 per product, double the average reported cost of self-certification (£3,200). Applied across the average manufacturer portfolio of 490 product lines, this would add an estimated £1.58 million in additional costs. This would be an ongoing cost, given EPDs should be renewed after five years or whenever a change is made to a product or its supply chain.  More than 38% of respondents reported portfolios exceeding 1,000 active product lines, meaning the costs could be significantly higher for some businesses.

The research shows manufacturers are not questioning the need for robust product environmental data. Eighty-eight per cent of manufacturers already provide environmental data to the market. Of these, 80% can provide it through a self-certified declaration or format. Only 20% can provide the data as a form of EPD. The findings reinforce the need for future reporting requirements to improve consistency and comparability without creating disproportionate costs, duplication or barriers to innovation.

BEAMA says there is currently no standalone methodology for embodied emissions assessments, meaning the proposed framework will need to be underpinned by broader lifecycle assessment (LCA) standards and supporting Product Category Rules. The decisions made now will shape wider product environmental data policy and market expectations well beyond the framework’s initial scope.

BEAMA is calling on Government to ensure the framework delivers:

1. Alignment with existing, internationally recognised LCA methodology (ISO 14040/14044)
2. Proportionate implementation and assurance requirements that build on existing conformity assessment systems
3. Methodologies and Product Category Rules appropriate to complex electrical products and systems
4. A structure that avoids duplication across existing and emerging regulatory frameworks
5. Support for multiple compliant reporting routes, including EPDs, PEPs and TM65 assessments.

Amy Collins, Head of Net Zero and Clean Tech at BEAMA, said: 

“The UK has a real opportunity to set the standard for trusted product environmental data, but only if we build a framework that works in practice for both Government and industry.

“Manufacturers are already providing environmental data and want to see that work recognised through a framework that builds on existing international standards and reflects the complexity of electrical products and supply chains. It also needs to avoid creating multiple reporting requirements for the same information.

“The decisions made now will shape how product environmental data is used for years to come. Getting the framework right from the outset will help deliver consistent, comparable information while supporting UK manufacturing and the transition to a low carbon economy. Existing conformity assessment processes already provide trusted assurance for electrical product safety. Building on these established processes for Product Environmental Data is a practical way to deliver confidence without creating unnecessary additional burdens.”

Ayah Alfawaris, BEAMA Technical Sustainability Committee Chair and Head of Group Marketing & Sustainability at Wilson Power Solutions, said: 

“BEAMA is uniquely positioned at the centre of this conversation. We believe this framework, together with other related Government initiatives, should be brought under a coherent, coordinated umbrella. Working in partnership with trade associations will help avoid inconsistencies, duplication and unnecessary burdens on manufacturers, while ensuring industry can focus on delivering the UK’s Clean Power 2030 ambitions.” 

The position forms part of BEAMA’s wider Getting Product Environmental Data Right campaign, which sets out practical policy proposals and industry evidence to support the development of a credible, proportionate and internationally aligned framework for product environmental data.

beama.org.uk