IN Brief:
- BEAMA estimates an EPD-only route could add £1.58 million across an average manufacturer’s portfolio.
- Eighty-eight per cent of surveyed manufacturers already provide some form of product environmental data.
- The association wants EPDs, PEPs, TM65 assessments, and recognised lifecycle methods retained as compliant options.
BEAMA has published industry research and a five-point policy position intended to influence the UK government’s proposed Embodied Emissions Reporting Framework for industrial products.
The association supports the development of more consistent and comparable environmental data but has warned against making a full Environmental Product Declaration the default route for every individual electrical product.
Its survey estimates that moving from an existing self-certified assessment to a full EPD would add an average £3,240 per product. Applied to an average portfolio containing 490 active product lines, BEAMA calculates an additional cost of approximately £1.58 million for one manufacturer.
More than 38% of respondents reported portfolios exceeding 1,000 active product lines, increasing the potential cost where declarations must be prepared separately. EPDs also require periodic renewal and may need revision whenever a product or its supply chain changes materially.
The research found that 88% of participating manufacturers already provide environmental information to the market. Among those businesses, 80% can supply data through self-certified declarations or other formats, while 20% can provide a form of EPD.
BEAMA is seeking alignment with recognised lifecycle-assessment methods, including ISO 14040 and ISO 14044, together with Product Category Rules that reflect the design, material composition, manufacturing routes, and supply chains of complex electrical equipment.
Its policy position supports proportionate assurance built on existing conformity-assessment systems, avoidance of duplicated obligations, and recognition of several compliant routes, including EPDs, Product Environmental Profiles, and TM65 assessments.
The proposed UK framework is intended to improve the consistency of information used to compare embodied emissions across industrial products. Decisions on methodology, verification, system boundaries, and accepted reporting formats will determine whether the resulting figures can be used reliably in procurement and design.
Electrical portfolios resist simple comparison
Electrotechnical manufacturers commonly maintain hundreds of related products differentiated by current rating, breaking capacity, enclosure, pole configuration, accessories, controls, installation environment, and regional approval. Treating every catalogue item as a separate assessment can multiply cost without producing a corresponding increase in useful information.
Grouping related products may reduce duplication where their designs, materials, and manufacturing routes are sufficiently similar. Those grouping rules need to remain transparent, however, because excessive aggregation could conceal meaningful differences between products.
Complex electrical equipment also contains components and materials sourced through several supply-chain tiers. Manufacturers may not possess primary emissions data for every upstream process, requiring recognised databases, assumptions, allocation methods, and documented estimates.
Comparability depends on more than the headline carbon value. Functional unit, declared lifetime, maintenance, losses during use, manufacturing location, electricity mix, transport, repair, replacement, recycling, and end-of-life assumptions can all alter the final result.
Operational losses are particularly significant for many electrical products. A transformer, cable, power supply, motor-control product, or switchboard may create relatively limited manufacturing emissions compared with the energy lost during decades of operation. Procurement based only on embodied carbon could therefore favour equipment with poorer whole-life performance.
Product Category Rules define how those factors are treated within a specific class of equipment. Poorly aligned rules can leave two formally compliant declarations difficult to compare, while separate national methods create additional work for manufacturers selling across several markets.
The policy debate is developing as European electrical manufacturing expands to support grid reinforcement and electrification. ABB is increasing medium-voltage production capacity in Europe, illustrating the volume of equipment required as networks expand and replace ageing assets.
Environmental information will increasingly form part of procurement alongside safety, reliability, losses, service life, maintainability, repairability, delivery time, and technical compatibility. A reporting system that considers only one measure risks shifting impacts elsewhere within the product lifecycle.
Independent verification can improve confidence but adds cost and lead time. Existing conformity-assessment systems may offer part of the governance structure, although environmental calculations require different evidence and expertise from electrical safety testing.
Digital product data could reduce repeated manual reporting where common definitions, stable identifiers, controlled revisions, and machine-readable formats are adopted. Compatibility is required across manufacturer, distributor, designer, contractor, specifier, and asset-owner systems before those efficiencies can be realised.
A practical transition period will also be necessary. Smaller manufacturers and low-volume products may find full declaration costs harder to absorb, while abrupt requirements could reduce product availability, discourage design changes, or delay market entry.
BEAMA’s proposal retains EPDs within the framework but argues that they should sit alongside other recognised methods rather than becoming the only accepted route regardless of portfolio scale or product complexity.
The Getting Product Environmental Data Right programme contains the association’s policy position and supporting evidence. The final framework will need to improve consistency without requiring repeated assessments that add cost while contributing little additional technical value.
