CBAM serves multiple objectives, each supporting the broader EU climate strategy:

Preventing carbon leakages: Discouraging industries from��relocating��their manufacturing operations abroad to avoid .

Levelling the competitive playing field:�� CBAM��ensures��that importers of carbon-intensive��products are subject to��a��comparable��carbon cost to the EU’s Emissions Trading System.

Encouraging global emissions reduction:��International producers have incentives to decarbonise their processes, extending EU’s climate influence globally.

Strengthening transparency and accountability:��CBAM mandates the detailed reporting of embedded emissions, making sure that carbon footprints throughout global supply chains are accurately measured, verified and shared.

UK’s��adoption��of CBAM

The UK is due to introduce its own version of CBAM on 1 January 2027, following the EU’s implementation in January 2026. While the systems are similar,��there are a few key differences. The UK CBAM��will be a tax-based mechanism��based on the quarterly UK Emissions Trading Scheme (ETS) price in the prior quarter. The UK will also only cover direct emissions when it launches in 2027,��with the inclusion of indirect emissions being delayed until 2029 at the earliest.

Impact on bidding

Imported materials will cost more, impacting bids and project tender prices. To secure work, suppliers must demonstrate emissions transparency in their supply chains, as this is likely to become a procurement requirement written into contracts. While this could create financial and legal risks and costs for companies unprepared for carbon accounting, those with well-established procurement routes with transparent reporting will be less affected and maintain a competitive advantage.

The need to meet CBAM requirements will��likely be��included��in contracts. It represents a risk, and developers and contractors must agree on who is liable for the fluctuation in cost. The appetite for risk along with the market conditions and existing supply chains will inform different approaches and attract differing levels of cost.

Data verification as new standard

If UK emissions trading data cannot be verified or actual emissions data cannot be obtained, importers must show evidence of the efforts they have made to try to��acquire��it��from their suppliers – including outreach, documentation requests and��attempts��to validate information.

This adds administrative work, but prevents companies from simply defaulting to non-specific data, and aligns��with the��EU’s approach��which��limits��default values for reporting, moving toward country-specific defaults and prioritising actual emissions data.

As CBAM rules tighten, real��emissions��data from suppliers will become��essential��and standard. Navigating this complexity can be minimised by setting clear expectations from the start so that neither time��nor cost is wasted by either side.

In 2022, UKGBC launched the System Enablers for a Circular Economy report, which highlighted secondary materials markets as one of the eight key enablers to the circular economy. A secondary materials market was defined as a marketplace for materials and construction products that had a previous life and are easy to procure from. These marketplaces help overcome these barriers to material reuse:

• Limited availability of secondary materials
• Limitations on storage of secondary materials
• Difficulties in the procurement of secondary materials
• Risk being pushed onto contractors

Secondary materials marketplaces seem to fall into either physical or digital marketplaces. Physical reuse hubs provide storage, spaces for materials to be tested, certified and physically inspected, enabling wider use of reclaimed materials.�� Equally, digital platforms can provide key documentation or materials passports , and allow materials to be uploaded and collection time-matched between projects.

The lack of storage for secondary materials has also been a barrier to scaling material reuse. There are a few reuse hubs across the UK, such as in Carlisle, and more are opening across the country. The is trialling a circular construction hub in the Scottish Central Lowlands region, aiming to cover several cities and rural areas. The has piloted a reuse hub specifically focused on suspended ceilings and luminaries. In London, , who use circular practices as a materials-first approach to designing and building, have been founders alongside and to open in Newham. This meanwhile-use site is planning to expand to cover more of the site over the next five years, looking at the testing and refurbishing of materials to enable them to be reused. They are looking at materials which do not already have a defined route and experimenting with packaging up materials to enable design within constraints.

Collaboration and engagement with the supply chain have consistently appeared as key enablers for delivery material reuse and trialling innovative approaches. Engagement with the design team and supply chain to communicate why this matters for the project can help ensure the material reuse is achieved. Equally, having conversations early allows for identification and mitigation of risks, enabling stakeholders to be bought into the approach. Anecdotally, talking to people to understand why processes are done one way and if they can be approached differently can lead to positive results. Engagement across the sectors is also important to enable marketplaces to scale and create space for collaboration, as demonstrated through a recent

Why this report matters

Despite rapid innovation across materials, digital technologies, construction systems and business models, many solutions��remain��underutilised. Fragmented decision-making, risk-averse cultures, misaligned procurement��models��and limited access to scale-up finance continue to hold back progress.��

Without faster adoption, the industry risks higher long-term costs, missed opportunities, and slower progress towards net zero and more resilient places.��This report focuses on what needs to change to move from isolated innovation to system-wide implementation.��

Drawing on insights from a broad range of stakeholders, built environment practitioners and industry experts, the report identifies seven key themes that influence whether solutions scale: organisational readiness; adopter needs and solution; finance and business models; certification and verification; risk, insurance and warranties; delivery and implementation; outcomes and knowledge sharing.

Across these themes, the report sets out 77 actionable enablers to support organisations in accelerating adoption.��