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Are you ready for ‘Approved Document Z’?

Posted on: August 19, 2025

Embodied carbon in building products is new build’s next big challenge. We find out how the Commercial Window Group is helping house builders to lower emissions in manufacture, supply – and through life.

Do you remember ‘Approved Document Z’?

It’s now four years since an industry coalition under the lead of Architect Simon Sturgis developed the draft proposal ‘Approved Document Z’. Supported by hundreds of businesses, including some of the largest UK housebuilders, developers, contractors and financial institutions, it argued that a whole life assessment and embodied carbon limits should be enshrined in UK building regulations.

According to the 2021 campaign around 1 in 10 tonnes of the UK’s total greenhouse gas emissions are so-called ‘embodied carbon’ emissions, related to the production and use of construction materials.

They total 64 million tonnes of CO2e per year, more than the country’s aviation and shipping emissions combined.

“Despite their magnitude, embodied carbon emissions are unregulated in the UK,” the proposed document’s authors wrote. “Similar legislation has already been implemented in several European Countries, the state of California, and is in the latter stages of debate for cross-EU introduction – all demonstrating the feasibility for the UK to do the same.”

Four years on and while the Government is ripping up the planning system and injecting new life into the house building sector, regulatory progress on embodied carbon has been minimal. 

The 2021 London Plan, the spatial strategy for Greater London, puts focus on embodied carbon in the built environment as part of its goal to make London a zero-carbon city by 2050.

This includes placing a requirement on developers to submit a Whole Life-Cycle Carbon Assessment (WLCA), including product stage emissions (A1-A3); construction stage emissions (A4-A5); use stage emissions (B1-B7); end of life emissions (C1-C4); and optional module D (re-use and recycling benefits).

“Embodied carbon is on the agenda but outside of the capital, the requirements for construction are pretty vague”, says Jody Vincent, Commercial Window Group.

“While the Government has acknowledged the need to regulate embodied carbon, especially against the backdrop of the Future Homes Building Standard (still expected later this year), the ‘regulatory stick’ remains missing. 

“Instead, the initiative has again been taken by industry, with developers voluntarily taking up Whole Life Carbon Assessments (WLCAs).”

Jody argues that the new build supply chain is also doing its part.

Following targeted investment to shrink its reliance on fossil fuels through renewable energy, windows and doors supplied by the Commercial Window Group use less carbon in manufacture, than any other window frame in the UK.

“In terms of embodied carbon attributable to the manufacturing process, we’re making the lowest carbon window in the UK”, Jody explains.

“This is around just 3.73kg of C02 generated on average per unit. Alongside our systems partner, Profile 22, we’re also working to recover more end of life material, and bring higher quantities of recycled PVC-U into our products.”

The Commercial Window Group specialises in the manufacture, supply and installation of windows and doors into the new build and social housing sectors. It offers national coverage through a network of regional fully accredited new build specialist window and door installers.

Windows and doors are manufactured in ultra-energy efficient systems from Profile 22 by the Commercial Window Group’s manufacturing operation Emplas, one of the UK’s largest and longest established window and door manufacturers.

The installation of 1558 new solar panels means that we’re now generating an additional 534,000kWh of clean energy a year, lowering its C02 emissions by up to 135,000kg per annum.

Low-energy LED lighting; a new climate control system and new inverter-driven compressors have also contributed to reducing CO2 emissions throughout its production facilities, while Raspberry Pi consoles have seen energy consumption fall by 80% when compared to standard computers.

“We’re not perfect but we are doing what we can to lower our environmental impact, and that includes reducing the embodied carbon generated by our manufacturing process”, he says.

“As for the PVC-U itself, yes it comes from oil and sodium but actually once it’s been extracted, is hugely recyclable low-maintenance through life and energy efficient.

“The contribution the building fabric and materials can have in lowering carbon emissions in the built environment through life is enormous.

“We offer for example, an extensive range of windows and doors which achieve ultra-low u-values of as low as 0.8W/m2K.” 

In addition to substantial savings on energy usage, Commercial Window Group products are supplied by an upgraded delivery fleet with low emission Euro 6 engines, translating to a 15% reduction in fuel. New route planning software has saved a further 10% on pre-existing fuel usage – the equivalent of taking two vehicles a day off the road.

“It’s very clear that the next generation of homeowners place a value on sustainability.

“Being able to evidence the sustainability of your supply chain and through-life contribution that those products make to lowering the carbon footprint of their home is a great way to communicate your commitment as a developer to sustainability.

“That’s important because with or without it Approved Document Z, Generation Z, expects It.”

For more information on the Commercial Window Group’s next generation high performance window and door ranges and our regional delivery partners call 01234 567890 or email [email protected]

Posted on: August 19, 2025
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