London Plan 2021: Manufacturer Playbook
London’s planning rules quietly decide who gets specified. Whole-life carbon assessments and circular economy reporting now sit beside drawings and fire strategy. If product data is thin, design teams default to conservative factors that make swapping in a better product harder than it should be. Here is the practical read on what the London Plan really asks for and how EPDs remove friction.
What the London Plan actually requires
Policy SI 2 makes Whole Life-Cycle Carbon (WLC) assessments a must for planning applications referable to the Mayor, with many boroughs applying the same ask to major schemes. Referable examples include developments over 150 homes and buildings above 30 metres outside the City of London (Mayor of London Order, 2008) (legislation.gov.uk, 2008).
London Plan Guidance sets out when to submit, what to cover, and the template to use. Boroughs also ask for Circular Economy Statements that include a bill of materials and reuse plans (GLA Circular Economy Guidance, 2022).
Why this drives demand for product EPDs
WLC calculations pull hard on A1 to A3 data. If an assembly lacks verified product numbers, assessors lean on sector averages that can be pessimistic. Product‑specific, third‑party verified EPDs slot straight into the model, reduce uncertainty, and protect the spec when value‑engineering starts.
Think of the WLC model like a playlist. Generic datasets are the radio. EPDs are your lossless tracks.
Carbon offset costs sharpen the math
Where operational net‑zero cannot be met on site, many boroughs price residual tonnes at £95 per tonne of CO₂ over 30 years, which equals £2,850 per tonne for typical s106 payments. That figure appears in current borough guidance and park development corporations, and it is material to bid viability (Lambeth Council, 2025; LLDC, 2022).
Lower embodied carbon from manufacturer EPDs can trim modelled tonnes and therefore cash outlay. That is real headroom in tough pro formas.
Timelines and touchpoints
Design stage WLC goes in at planning, then a post‑construction WLC confirms what was actually built. Circular Economy Statements follow the same rhythm and track retention, reuse, and material recovery metrics. Teams that package EPDs with declared units, plant locations, and transport modes see faster sign‑off because reviewers can trace assumptions (GLA WLC Guidance, 2025) (GLA WLC Guidance, 2025).
Data standards to watch
RICS’ Whole Life Carbon Assessment standard, second edition, took full effect on 1 July 2024. GLA guidance notes this and still requests assessments aligned to its template, with the option to additionally report to the second edition where helpful (RICS, 2024) (RICS, 2024; GLA WLC Guidance, 2025).
Translation for manufacturers. Clear, auditable product data wins. EPDs that map cleanly to EN 15804 and declare transport and packaging details reduce assessor caveats that can inflate results.
How EPD choices influence WLC outcomes
Pick the right PCR to match how peers are reported, so comparisons are apples to apples. Choose the declared unit that mirrors how the product is bought and installed. Provide background on secondary materials, recycled content and electricity source. One misplaced assumption can skew A1 to A3 like a sticky keyboard note.
When geography matters, publish plant‑specific EPDs for high‑volume SKUs. London projects are sensitive to transport modes and distances. Factory‑specific data avoids defaulting to worst‑case trips.
Being spec‑ready, fast
A lightweight manufacturer pack that sits beside the EPD saves hours during pre‑app.
- A short data sheet that maps EPD modules to WLC inputs and flags any allocation choices.
- Plant addresses, typical delivery modes, packaging assumptions, and recommended wastage rates.
- Contact details for a technical owner who can confirm substitutions within 24 hours.
- A one‑page CE note on disassembly, take‑back, and reuse options for the product family.
We have seen review cycles shrink simply because answers were ready. It sounds basic, but it works.
Common pitfalls to avoid
Swapping a generic European average into a London job without checking electricity mix can add avoidable tonnes. Ignoring installation wastage in A5 gets caught at post‑construction and can trigger tense reopeners. Publishing a single, catch‑all EPD for several plants looks tidy, yet it can backfire when a borough planner asks for site‑specific factors. Do not be that team, please.
The small print that matters
The GLA adopted its WLC guidance in March 2022 and continues to update practice notes. The thresholds for referral remain anchored in the Mayor of London Order categories, which include height and unit counts by location (GLA, 2022; Mayor of London Order, 2008) (GLA Engagement Portal, 2022). Reliable citywide averages for embodied carbon caps are not published yet, so anyone selling a single magic number is guessing.
Bottom line for manufacturers
London is a WLC market now. EPDs convert engineering work into planning confidence, trim offset exposure, and keep products in the conversation when designs pivot late. Get your top movers covered first, then build depth by plant and by SKU. It is not glamourous, but it is how specs are actually won in the capital, and it is definately how they are kept.
Frequently Asked Questions
Which applications in London must submit Whole Life-Cycle Carbon assessments and what are the numeric thresholds?
WLC assessments are required for schemes referable to the Mayor under Policy SI 2. Examples include more than 150 residential units and buildings above 30 metres outside the City of London. Boroughs often extend similar asks to major applications. These thresholds come from the Town and Country Planning (Mayor of London) Order 2008 (Mayor of London Order, 2008) (legislation.gov.uk, 2008).
What carbon offset price should teams expect in London if residual emissions remain?
Many boroughs apply £95 per tonne of CO₂ for 30 years, which totals £2,850 per tonne for Section 106 payments. This figure appears in current borough guidance, for example Lambeth and the London Legacy Development Corporation (Lambeth Council, 2025; LLDC, 2022).
Which methodology should assessments follow in 2026?
GLA WLC guidance and template remain the primary reference for referable applications, with applicants able to additionally provide assessments aligned to the RICS Whole Life Carbon Assessment standard, 2nd edition, which has been in full effect since 1 July 2024 (RICS, 2024) (RICS, 2024; GLA WLC Guidance, 2025).
About the Author
John brings a clear, research-driven perspective on the EPD, LCA and HPD space and keeps a close pulse on environmental trends and standards in North America, helping clients understand where the industry is heading and how to get there.
