Understanding the 2025 Mandatory Carbon Counting Change

New Zealand's 2025 mandatory carbon counting requirements will impact architects and builders, making Engineered Product Declarations (EPDs) crucial for compliance and reducing construction-related emissions.

Buildings contribute around 12 per cent of domestic greenhouse gas emissions so reducing building-related emissions is key to achieving New Zealand’s net-zero emissions target. The Government’s second emissions reduction plan, released in December 2024, takes in feedback from relevant industries following the release of the initial emissions reduction plan, and sets out the key areas we need to address in 2025 to remain on track to achieve targets. 

Central to achieving these targets is industry collaboration on improving emissions data for products, materials and buildings, says the Minister of Climate Change, Hon Simon Watts in the report. 

“New Zealand stands at a critical point in preparing for a net zero future. Achieving our goals will require collaboration across all groups to reduce emissions, unlock renewable energy, foster innovation, and leverage nature-based solutions.”

Limited availability of data on products used in construction can make understanding, comparing and reducing embodied emissions challenging, and the implementation of 2025 mandatory reporting of Environmental Product Declarations (EPDs) addresses this issue.

What are EPDs?

An EPD is a product declaration certificate that lists each component or material within a product (whether it is flooring, cladding or decking) and reports the exact amount of kilograms of CO2 embodied in each product, and can be compared to a nutrition label for food.  

“[They] are valuable tools for architects and specifiers as they support more sustainable design practices and help meet evolving regulations, certification requirements and client expectations,” shares Barbara Nebel from Thinkstep, an environmental sustainability agency. 

“An EPD tells the environmental story of a product over its life cycle in a clear, transparent way. It is science-based, complies with standards, is independently verified and publicly available.”

Mandatory embodied carbon reporting in 2025 means EPDs are now required for all new building products specified and if a product doesn’t have an EPD available, the architect or specifier will have to procure the information from the manufacturer.

It means that without the certificate you have to record a wider margin for the amount of CO2 in the product, which could increase the embodied carbon overall in the project. Increasing the amount of carbon dioxide embodied in your building design could put you over the threshold for embodied carbon and prevent you from getting a building consent. 

Starting in 2026, building designs will need to align with a 'reference' building—essentially the same design but with predefined carbon limits. The new building's total embodied carbon must be measured and kept below these established thresholds.

Are EPDs available for engineered timber flooring?

For flooring, EPDs can give you a clear idea of engineered flooring sustainability, which is not only beneficial for complying with carbon counting regulations, but will also give you key information about the quality of the materials used within the product. 

Not all building products will automatically come with an EPD, so it’s important to ask your supplier whether or not the product you want to specify has one.

Explore engineered wood flooring available with EPDs