Energy and Climate Change CommitteeMemorandum submitted by the Construction Products Association

Who We Are

The Construction Products Association is the umbrella body for manufacturers and suppliers of construction products in the UK and our membership consists of the 24 major companies in the industry as well as 43 sector trade associations and collectively these represent 85% by value of the industry. The products sector has an annual turnover of more than £50 billion, accounts for 40% of total UK construction output and is 4% of GDP.

The sector is a crucial component of the coalition government’s strategy for manufacturing to spearhead the growth so desperately needed in the economy.

More than 80% of construction products used in the UK are still manufactured in the UK.

How We Contribute to the Climate Change Debate

Our members are at the forefront of manufacturing and supplying the products and materials that will improve the energy efficiency of our homes, offices, schools and hospitals, capture renewable energy, build new power stations and deliver the low carbon built environment that we all seek. As well as supporting the need for these measures to help reduce carbon emissions, we also believe this represents a great business opportunity. Our members are therefore not adverse to the need to measure and report on their greenhouse gas emissions.

The Case for Consumption-based Greenhouse Gas Emissions’ Reporting

The Association supports strongly the need for government to measure and report greenhouse gas emissions based on consumption of goods in the UK and not just those emissions emitted during production, only then will we have an accurate picture of the contribution of the UK to global greenhouse gas emissions.

Currently the greenhouse gas content of products that are imported is not measured. This gives not only a skewed picture of progress in decarbonising our economy but may perversely result in efficient low carbon manufacturing in the UK being forced overseas as its higher price cannot compete with cheaper, probably less efficient and more carbon intensive imports entering the UK “carbon–free”.

In construction, the government is giving strong policy direction to the need to decarbonise manufacturing and to provide the products that will deliver low carbon buildings and infrastructure, but until procurement is based on carbon intensity rather than lowest costs, this will not happen. Whilst procurement remains based on lowest cost then cheaper imports manufactured in less efficient and more carbon intensive ways will outcompete UK-base manufacturing industries. This will not deliver the manufacturing jobs that are needed to grow the economy.

We believe that measuring greenhouse gas consumption in the UK will therefore contribute to the much-needed level-playing field for UK based industries to compete.

If our manufacturing sector departs overseas then the result is that we will have simply outsourced our carbon emissions, along with the jobs and prosperity of many, which is neither good for our society, economy, nor the global environment. Driving production overseas, only to import the needed products back into the UK free from carbon measurement, is a perversity that must be overcome. With a growing population in the UK, plus the need to refurbish the 26 million existing homes to a high standard of energy efficiency, will require many more construction products to be used in the years ahead.

We note, in addition, that according to a September 2011 response by DFID to the Environmental Audit Committee* (Page 12, report citation below), the UK already accounts for carbon dioxide emissions associated with UK consumption of all goods and services, whether or not the emissions are generated within the UK. They include emissions from international travel and the production and transportation of imported goods, but not emissions from production of goods for UK export. These were reported in the 2010 Sustainable Development Indicators. The graph of UK consumption is given in

   If this is indeed the case then the question must be how robust is this data and can it be expanded beyond carbon to greenhouse gas emissions.

We are very keen to have the opportunity, with the major companies in our sector, to present to the Committee on the points raised above. These are absolutely critical to the security of a manufacturing base in this country which will help deliver the built environment in a sustainable way.

*The impact of UK overseas aid on environmental protection and climate change adaptation and mitigation: Government Response to the Committee's Fifth Report of Session 2010–12

Ordered by the House of Commons to be printed 14 September 2011

October 2011

Prepared 17th April 2012