NSW Decarbonising Infrastructure Delivery Policy Explained
Sydney’s cranes are not just lifting steel beams, they are lifting a new carbon rulebook. From April 2025, any New South Wales Government project that tops fifty million Australian dollars for buildings or one hundred million for roads, rail, or water must report and reduce upfront (embodied) carbon. For manufacturers, that policy flips embodied emissions from a nice-to-have talking point into a hard tender gate.
Why the policy landed now
New South Wales has the largest public works pipeline in Australia, earmarking about A$118 billion over four years (Infrastructure NSW Pipeline Update, 2025). The state cannot hit its legally binding net-zero target by 2050 unless the concrete, steel, glass, and asphalt that feed those projects get leaner in carbon. The Decarbonising Infrastructure Delivery Policy, launched in April 2024, answers that gap (Infrastructure NSW, 2024).
Scope and thresholds you need to know
The rule applies to every NSW Government delivery agency and kicks in at these caps:
- Building projects above A$50 million
- All other infrastructure above A$100 million (Infrastructure NSW FAQs, 2025) Projects that started a business case after 1 April 2025 must show compliance. Anything smaller or local-government funded can volunteer but is not compelled.
A single yardstick for embodied carbon
A companion Measurement Guidance, adopted nationally in June 2024, locks in one calculation method, data hierarchy, and reporting format (Infrastructure NSW, 2024). No more juggling bespoke spreadsheets from three departments. Consistent accounting means EPDs slot straight in as pre-verified evidence for product-level impacts.
EPDs move from “nice” to non-negotiable
Agencies must track upfront emissions for materials such as cement, steel, and aluminium from concept design through practical completion. Design teams can hardly do that without third-party verified factors per kilogram. Cue the Environmental Product Declaration. An EPD shortens the estimator’s homework and signals readiness to help a client hit its public pledge. Expect specifications and procurement portals to filter by EPD status the same way they already filter by fire or structural codes.
Tender maths: win rate beats unit price
Roughly 73 percent of NSW projects above the threshold use competitive design and construct or alliance models that weigh non-price criteria at 30 percent or higher (NSW Treasury Procurement Dashboard, 2024). An EPD can lift the non-price score without touching the steel mill’s cost curve. The numbers isn’t trivial: a two-point bump in the technical score often shuffles a bidder from runner-up to winner when bids cluster within three percent on price.
Data readiness checklist
- Map current LCA data by product line against the national Measurement Guidance scope.
- Close any gaps for modules A1 to A3 first, because those dominate upfront carbon.
- Gather plant utility bills and transport legs for the 2023 or 2024 reference year while records are fresh. Pulling that data later, under tender deadline stress, feels like searching for your passport ten minutes before the airport shuttle arrives.
Timeline and future add-ons
- April 2025: policy operational for new business cases.
- July 2025: NSW EPA expected to finalise the Protection of the Environment Policy for Sustainable Construction, which will embed recycled-content reporting alongside carbon (EPA NSW, 2025).
- 2026 and beyond: Infrastructure NSW will review emission-reduction targets and may set material-specific limits once baseline data matures.
Choosing your LCA wingman
Select a partner that already aligns its software factors to the Measurement Guidance, can publish EPDs under both IBU and local operators, and, critically, runs data-collection interviews inside your plant rather than emailing fifty-line spreadsheets. Your R-and-D staff will thank you.
What this means for manufacturers
If your product feeds NSW hospitals, schools, metros, or highways, an EPD now influences whether you reach the shortlist at all. Treat it like an entry badge, not a marketing brochure. Move early, lock down credible data, then reuse the same declaration across Australia’s growing web of low-carbon procurement rules. The infrastructure boom will reward suppliers who bring carbon transparency to the loading dock.
Frequently Asked Questions
Does the policy force private projects below A$50 million to measure embodied carbon?
No. The Decarbonising Infrastructure Delivery Policy targets NSW Government infrastructure only. Private or smaller jobs may adopt it voluntarily but are not required.
Which life-cycle modules must be reported under the Measurement Guidance?
The Guidance covers modules A1 to A5 for upfront carbon, with optional reporting for modules B1 to C4. Start with A1-A3 (raw material supply and manufacturing) because they dominate totals.
Will NSW set material-specific carbon caps like California’s Buy Clean law?
Not yet. Agencies are collecting baseline data through 2026. Caps or benchmark targets could follow once a statistically robust data set exists.
Can I reuse an existing EN 15804-based EPD, or do I need an Australian version?
Any EPD that aligns with EN 15804+A2 and shows system boundaries matching A1-A3 can be used, but using Australian electricity mixes and transport distances improves credibility and future-proofs the document.
What funding helps suppliers decarbonise materials sold into NSW projects?
The state earmarked A$37 million for its Carbon Recycling and Abatement Fund to support projects that cut embodied carbon or boost recycled content (EPA NSW, 2025).
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
