Back in 2022, when Citigroup launched a transformation project for its EMEA headquarters shaped by the bank’s ambitious net-zero commitments, embodied carbon became big news for anyone involved in the built environment. The project is no mere facelift, but a major upgrade to maximize the reuse potential of materials and the specification of equipment to reduce embodied carbon.
The foodservice industry took its time to catch up. Embodied carbon was a fringe issue even one year ago, but somehow a fuse was lit and it is now firmly in the spotlight.
“So much has changed,” says FCSI Senior Associate Lauren Hunter, sustainability director of Invito Design in the UK. “People wanted a signal from the industry that this was not a niche issue and that it was not going away. Initially, it was seen as just another trend, but The Palace Framework provided the first rumble that something was coming.”
Hunter has been a driving force in drawing attention to embodied carbon, and she played a central role in creating The Palace Framework, specifically acting as the chair of the working group focused on adapting the Chartered Institution of Building Services Engineers (CISBE) TM65 methodology for commercial catering equipment.
TM65 provides a standardized method to calculate the embodied carbon of mechanical, electrical, and plumbing (MEP) products in the absence of Environmental Product Declarations (EPDs) – verified, transparent documentation based on life cycle assessment data that reports the environmental impact of a product from manufacture, through installation, to disposal.
TM65 is seen as a critical, internationally applicable first step to evaluating carbon emissions when manufacturers have no detailed EPDs, but it has its shortcomings when applied to foodservice. The criteria used for general building services are a poor fit for complex commercial kitchen environments, and it gives manufacturers a heavy compliance burden.
The Palace Framework provides a new, specialized benchmark for embodied carbon specifically within the hospitality and catering equipment sector and is a
big step towards increasing carbon transparency.
Catching the regulatory tide
The emergence of the new framework is timely, given that UK and EU legislation is embracing embodied carbon. The UK government is prioritizing the reduction of embodied carbon with a focus on measuring, reporting, and setting voluntary standards. Its efforts will include a national embodied emissions reporting framework and partnering with industry to introduce product standards and improve data gathering.
The EU’s requirements for Digital Product Passports (DPPs) – digital records of data on sustainability, circularity, and supply chain issues from manufacturing to recycling – under the Ecodesign for Sustainable Products Regulation (ESPR) are accelerating, with a major focus on appliances, including dishwashers and laundry equipment.
BREEAM 7, which went live in late 2025, now requires comprehensive reporting and benchmarking of embodied carbon across the building life cycle as a key component for high-level ratings.
“This is now a real thing. Now, 40% of manufacturers are measuring embodied carbon, which is a big step up from just 10% a year ago. Cost and carbon are the same thing, so looking at the whole life of equipment is what gives you a good view of what to specify,” says Hunter.
“Cheap equipment will not last, but we are seeing a long-term perspective emerge,” she adds. “People are questioning the marketing speak, energy monitoring equipment is everywhere and is exposing differences in performance, and there is now a real conversation around cost.
“People are realizing that capex and opex are the same – they are costs, the only difference being that one is immediate and the other is long-term.”
The Palace Framework has some limitations. For example, it is not as granular as an LCA (life cycle analysis) or EPD. Yet it provides a detailed starting point. It is a symptom of – and a catalyst for – the growing, industry-wide focus on whole-life carbon, including embodied emissions rather than just operational energy use.
The benchmarking battle
TM65 serves well as a benchmark for the construction industry because items such as bricks or wiring use relatively few different materials. A combi oven, however, has hundreds of components and materials. Consequently, measurement remains a challenge in foodservice.
“After 2022, more project requests followed,” says Luke Slater, technical and policy director for the UK’s Foodservice Equipment Association (FEA). “The industry was not ready to provide EPDs, so turned to a construction-ready methodology, TM65, to look at embodied carbon. It is great for bricks, glass, aluminium and so on, but it is flawed in terms of its application to catering equipment. It served its purpose initially and more manufacturers got on board, but it does not have traction out of choice, it has been forced upon it.”
Manufacturers face many challenges in providing consistent product-level carbon data, but a recent FEA survey shows that more are getting on board with the measurement process. It found that only 5% have assessed their entire product range in terms of carbon footprint; 40% have covered part of their range; and 35% are taking action though nothing is complete. Worryingly, 20% have no intention to do anything.
“At the moment, nothing is mandatory, but it may be coming, although the extent to which this will be enforceable to our industry is very fluid,” says Slater. “What we see is a refreshing change from the negativity there has been around carbon reporting, and our research shows that hospitality businesses do really care about being sustainable. Speaking on behalf of the industry, the FEA says we should look at the total amount of carbon associated with a product’s life, if we are to truly provide those operators interested in sustainability with a meaningful figure. Embodied carbon is part of that, but operational carbon is a bigger component.”
Some manufacturers, among them German company MKN, believe a global standard is required to really push progress. The company has embraced both embodied and operational carbon measurement. It provides a stainless steel option for its appliances that produces lower carbon dioxide equivalent (CO₂e) emissions in production, and a connected kitchen solution to live-measure power consumption.
“The most important thing is to create a common standard within the industry,” says Wayne Bennett, MKN’s regional vice president of sales and marketing for the UK and Ireland. “The top 20% of the market know about embodied carbon – the big hotels and corporates know it will hit them in the pocket. Many more consultants are asking for data now, but there is a misconception about what data is required.”
“People have latched onto TM65 as the solution, but it is the last resort not the first step,” he adds. “We’ve adopted it as the standard, but it is just a tool to get you into the system. Don’t rush out and spend money on TM65 because it is an overly simplistic system.”
Understanding what a global standard might look like is problematic. “For manufacturers, creating many different standards has a big cost implication,” explains Bennet. “People talk about TM65 as the savior, but it isn’t. We need to get into more detail. Embodied carbon serves the construction industry, but we need to look at operational carbon to drive the market towards quality products that will last.”
A delicate balance
TM65 primarily measures embodied carbon and doesn’t provide guidance on operational energy use, which often accounts for more than 85% of a product’s total lifetime carbon footprint, particularly for energy-intensive equipment.
“The topic has come on in leaps and bounds and there has been a sea change in terms of focus,” says energy reduction consultant Dr. Sam Mudie FCSI, director at Hospitality Energy Saving & Sustainability. “There has been a lot of ruffling of feathers driving people toward embodied carbon and there is the perception of progress in terms of measurement, though TM65 is not bespoke to catering.”
Mudie believes the principles underlying TM65 should remain as the basis for comparison between foodservice equipment and other aspects of building services, and urges manufacturers to output their data in a consistent format to support that. Re-educating manufacturers about inputting the right data, where she has seen many errors, is another priority. More urgent, however, is to keep embodied carbon in perspective.
Mudie conducted the world’s first full life cycle carbon analysis as part of her PhD in the context of a large review of the carbon situation in commercial foodservice. She believes operational carbon should be the top priority. “I found that embodied carbon was only 10% of the overall carbon footprint,” she explains. “So, manufacturers should spend money on operational carbon. That is the bit their customers care about. As the grid decarbonizes, operational carbon will become a smaller proportion and embodied carbon will become larger. You have to look at embodied carbon in a broader context, otherwise you could make the situation much worse.”
Sustainability discussions focused on operational carbon for many years, and some see the emergence of embodied carbon as a distraction from more important issues. Ultimately, the right balance must be struck. The industry must, after all, look at the big picture of total carbon.
The challenge in measuring embodied carbon is complexity and the lack of a standardized approach. The problem with measuring operational carbon is that values provided for a machine’s energy consumption, for example, are measured in laboratory conditions, not in real life applications.
“It is like the quoted miles per gallon for a car’s fuel efficiency – it is meaningless because that is tested in a specific set of circumstances and performance under test conditions is not replicated in real life,” says David Bentley, specification director for Meiko UK. “Both operational and embodied carbon are tricky. Embodied carbon should be simple, as components have the same information each time and you just need to tick boxes, but how far back down the manufacturing chain do you go?”
“Operational carbon is harder,” he adds. “At what level do you test the equipment? Combi ovens with multiple programs and which can be used in many different ways become complicated. Going forward we need a more standardized carbon measurement process. A standardized format will emerge, but for operational carbon we might need a multi-pronged approach, taking in different usage scenarios.”
Towards a clear view of carbon
It is important that the industry does not over-emphasize embodied carbon at the expense of operational emissions, but it cannot neglect it either.
“Operational carbon is about 70% of the problem,” says Hunter. “The difference is that embodied carbon relies on manufacturers, whereas operational carbon is an everybody problem.
“We don’t know how much energy equipment uses in a specific installation. Realistically, we need a joined-up approach across industry with data from hospitals, pubs, restaurants, and schools, pooled and shared.”
With effort and dedication, however, manufacturers can make great strides. Alto-Shaam, for example, has spent four years looking to get ahead of the embodied carbon issue, and has gone back through 20 years of product development to understand its portfolio. As vice president of international sales Simon Parke-Davis explains, it has gained a competitive advantage by doing so.
“The customer may understand operational carbon better, but every journey begins with embodied carbon,” he says. “Is it built with good materials? Is it reliable? How long will it last? And then what does it cost to run? The first question should be about embodied carbon. The second question should be about operational carbon, though they should receive equal attention.”
“A clear global standard would be a brilliant next step but I don’t see that happening first,” he adds.
The Palace Framework is a significant step forward, but many more steps must follow.
“It was an initial call to arms,” says Slater. “It recognized that TM65 does not go far enough, has highlighted its pitfalls, and has shown the industry has a long way to go to get the information it needs, but it didn’t recommend the next step.”
“The next five years will be transformative and we will get there,” says Hunter. “People are talking about embodied carbon and whole-life carbon, so the debate is moving. We need specific rules for each type of equipment and that could be achieved globally.”
There are clearly disagreements in terms of priority, and when it comes to common standards the foodservice sector is still finding its way, but the big goal of getting manufacturers, consultants and clients to talk about everything that contributes to the carbon footprint has been achieved. Meaningful change has already happened, and there is plenty more to come
Jim Banks
