London Retrofit-First SPD: A Manufacturer’s Carbon Cheat-Sheet
Corporate fit-out giants eyeing the Square Mile have a new rulebook: reuse before rebuild. The City of London’s Planning for Sustainability Supplementary Planning Document (SPD), adopted in January 2025, makes “retrofit first” more than a slogan. For manufacturers, the guidance turns product data—especially Environmental Product Declarations (EPDs)—into a passport for planning approval. Miss the signal and your steel, glazing, or HVAC kit may never cross the draughty threshold of a London tender.
Retrofit beats rebuild: the new planning default
Demolition is now the exception, not the norm. Applicants must show a Pre-Redevelopment Audit proving why an existing structure cannot be reused or adapted (City of London SPD, 2025). That flips value perceptions: components designed for disassembly, refurbishment, or reuse sit higher on every material schedule.
Whole-life carbon files land on every desk
Every major scheme must submit a Whole-Life Carbon Assessment that spans modules A1–C4, mirroring EN 15978. Developers will interrogate cradle-to-grave numbers long before a shovel hits ground, pulling figures from manufacturers’ EPDs to populate the spreadsheet.
Embodied carbon benchmarks tighten the screws
The SPD aligns with Greater London Authority (GLA) benchmarks: upfront carbon in a new office must slide under 950 kg CO₂e/m², while the aspirational threshold sits at 600 kg CO₂e/m² (GLA WLC Guidance, 2022). For refurbs, the UK Net Zero Carbon Buildings Standard pegs 2025 targets at 600 kg CO₂e/m² and trending lower by 2030 (UKNZCBS, 2024). Products without credible carbon data risk blowing the cap.
EPDs: the passport for your materials
Planning officers do not grade marketing copy. They verify third-party numbers. An EN 15804-compliant EPD provides the ingredient list, carbon nutrition label, and methodological audit trail in one PDF, ready to drop into a WLC calculator. No EPD, no entry.
Circular economy documents favour modular, low-impact specs
Applicants must lodge a Circular Economy Statement detailing how components can be removed, reused, or recycled (City of London SPD, 2025). Modular façades with documented take-back schemes shine. So do products with recycled content verified in Section 3 of the EPD. Glazing units glued together for eternity? They fall to the bottom of the shortlist.
Timing: deadlines inside the City’s planning calendar
The SPD applies to applications validated after 1 April 2025. Retrofits hitting committee in Q4 2025 must finalise product schedules by midsummer to lock carbon numbers. Leave EPD creation until the eleventh hour and you may watch the committee date sail past, which would be embarassing.
Win the spec play: three quick moves
- Map your catalogue against the GLA carbon caps today.
- Fast-track EPDs for the SKUs that land under the 950 kg CO₂e/m² headline figure.
- Hand sales teams a one-page cheat-sheet linking each product’s EPD page number to the SPD requirement it satisfies.
Key Takeaway for 2025 bids
London’s Retrofit-First SPD compresses sustainability from a nice-to-have into a planning gatekeeper. Manufacturers who serve ready-made, third-party-verified carbon data will glide through that gate while slower rivals wait outside in the drizzle.
Frequently Asked Questions
Does the City of London SPD mandate specific embodied-carbon limits for products?
No. The SPD sets whole-building benchmarks aligned with GLA guidance (< 950 kg CO₂e/m² upfront for offices). Product-level impacts roll up into that total, so lower-carbon SKUs give developers more breathing room.
Are third-party EPDs compulsory for planning approval in the Square Mile?
The SPD does not spell out “EPD or rejection,” but Whole-Life Carbon Assessments require verified data. Without an EN 15804 EPD or equivalent, you leave developers guesstimating, which can sink a scheme.
Will retrofit projects need NABERS UK ratings as well?
Yes. The SPD endorses a 4-star NABERS target for retrofitted offices and 5-star for new builds (The Planner, 2025). Operational energy scores sit alongside embodied-carbon numbers in the same submission.
How soon should we start an EPD if our product lacks one?
Plan on six to nine months from data pull to publication with a competent partner. Starting after the architect issues RIBA Stage 2 reports is often too late.
Does the SPD make Whole-Life Carbon Assessments compulsory for small refurbishments?
Assessments are mandatory for major developments—1,000 m² new floor area or sites over one hectare—but planners can request them for smaller projects if carbon impact is significant (City of London, 2025).
We already have EPDs published in 2020. Do we need new ones?
Check the underlying PCR expiry; if still current, your EPD remains valid. However, revised benchmarks may demand updated data to prove alignment with 2025 limits (RICS, 2024).
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.
