USGBC-CA Editor’s Note: Welcome to 2026 and to our blog! We are eager to hear your insights and thought leadership that will inspire our collective audience, our community. And please read and engage with our authors! So let’s kick it off with this contribution from BREEAM, and email julie@usgbc-ca.org if you have a proposed post!
The real estate industry is entering a new chapter in sustainability defined not only by how efficiently buildings operate, but by the hidden carbon within their very structure. For years, progress was measured primarily in energy efficiency and water use, focusing on how buildings performed once construction was complete. But as California again raises the bar on environmental performance, this focus is widening to include the carbon locked inside a building’s walls, floors, and foundations.
With the 2026 updates to the California Green Building Standards Code (CALGreen), California will become the first U.S. state to introduce mandatory embodied-carbon limits for new construction. This marks a watershed moment for the industry, one that acknowledges that 50% or more of a building’s total lifecycle emissions can occur before a tenant even enters the property. In doing so, the state is broadening the definition of green buildings and signaling a shift toward whole-life carbon accountability.
California’s leadership will almost certainly influence regional and local policy discussions across the country. Just as the state’s energy and vehicle standards shaped national trends in past decades, its embodied-carbon requirements are poised to catalyze a new era of design, procurement, and material innovation. The question now is how project teams can turn policy into measurable performance.
What CALGreen Means for the Market
For teams navigating this new landscape, embodied carbon will need to be measured and documented as part of a broader strategy linking building design to meaningful sustainability outcomes for large-scale commercial projects across the state. This introduces a new layer of accountability far earlier in the design process than many developers are accustomed to. Decisions about structural systems and foundational design, often made before full design development, will now directly influence whether a building complies with new regulations.
This policy shift also puts a spotlight on transparency. Tools like Environmental Product Declarations (EPDs) are becoming essential for substantiating material impacts. Manufacturers will face growing pressure to provide verified emissions data, while procurement teams will increasingly weigh carbon intensity alongside cost, schedule, and durability.
While this may feel like a significant change, it actually reflects a broader industry realignment. Lenders, insurers, and investors are beginning to integrate embodied carbon into due-diligence frameworks, and CALGreen accelerates a shift the market was already underway.
Why Lifecycle Thinking Matters More than Ever
As these regulations take effect, it’s important for project teams to acknowledge that embodied carbon is not an isolated design choice. Instead, it is the cumulative impact of decisions made across an entire building lifecycle — from how raw materials are extracted and transported, to the longevity of building components, to end-of-life outcomes. Lifecycle thinking is becoming essential not just for compliance, but for strategic, climate-aligned development.
Early design decisions carry disproportionate weight, and often the most significant carbon reductions are unlocked during concept and schematic design when foundational choices are still flexible. As more manufacturers release verified product data and tools like the Embodied Carbon in Construction Calculator (EC3) become more prominent, the industry is entering an era where embodied carbon analysis is accessible enough to be integrated from day one.
This shift is also tied to a larger transformation in how we assess building performance. As it becomes easier to reduce operational emissions through electrification and grid decarbonization, embodied carbon becomes a dominant part of a building’s climate footprint. In that context, CALGreen’s new measures go beyond regulatory requirements to prepare projects for a future where whole-life carbon is a core metric of sustainable design.
Circular Design as the Next Frontier
While embodied carbon policy focuses on how materials are produced, the next horizon also lies in how they are used, and reused, over time. Circular economy principles offer a pathway to comply with carbon limits in a way that reimagines materials stewardship in the built environment.
Adaptive reuse is perhaps the clearest example. Preserving and transforming existing structures avoids the substantial emissions associated with new construction and extends the life of materials already in circulation. With office-to-residential conversions gaining momentum in many California cities, the intersection of carbon savings and community revitalization is becoming increasingly evident.
Designing new buildings for flexibility, long-term adaptability, and eventual disassembly also plays a critical role. When components can be reconfigured or reclaimed rather than demolished, the carbon value of materials stretches across multiple building cycles.
Ultimately, circularity reframes material efficiency from being solely a climate strategy to being an economic one as well. Minimizing waste, reducing over-specification, and choosing modular systems should be viewed as cost-saving measures that also help create durable, adaptable assets capable of meeting future needs without starting from scratch. This is perhaps where California’s leadership could have its most far-reaching impact — by pushing the market towards buildings that are not only lower carbon at completion, but inherently more resilient and reusable over time.
The Importance of Certification Frameworks
In this evolving landscape, certification frameworks serve as practical tools for navigating complexity. Standards such as BREEAM offer structured methodologies for conducting lifecycle assessments, using verified product data, benchmarking performance, and documenting outcomes in a way that aligns with regulatory expectations.
It’s of importance to note that the value of frameworks like BREEAM is not certification alone. Crucially, they provide familiar, globally tested processes that help teams integrate lifecycle analysis early, manage data consistently, and communicate performance credibly to regulators, investors, and insurers. As CALGreen raises the bar, these frameworks can offer a stable foundation to base strategy and decision-making from, particularly for teams operating across multiple regions or working with global capital partners who expect transparent, third-party-verified performance.
A Collective Opportunity
California’s embodied-carbon requirements mark a milestone not just for the state, but for the broader North American market. They show how policy, when paired with industry innovation, can accelerate meaningful progress toward a net-zero built environment.
Yet the opportunity is even larger than that. By integrating lifecycle assessment with adaptive reuse and circular design, the industry can begin to close the loop on carbon, turning buildings into dynamic resources for future development. BREEAM offers the structure and verification needed to make that shift credible and scalable. Its holistic approach brings together data, design, and delivery in a way that supports California’s leadership today and prepares the market for what comes next.
About the Author
Alejandro Romero is a sustainability leader specialising in embodied carbon, resource efficiency, and the technical development of BREEAM. He has led major research and innovation initiatives that strengthen scientific rigor across the built environment, shaping strategy and aligning technical standards with evolving industry needs. Alejandro works at the intersection of policy, carbon science, and practical application, helping project teams, standards bodies, and certification programs deliver meaningful, measurable sustainability outcomes.
