PRODUCT CARBON INTENSITY STANDARDS

Product carbon intensity standards set a legal ceiling on lifecycle greenhouse-gas emissions per tonne, square metre, kilowatt-hour or other unit of output. Products above the ceiling cannot be sold, installed or permitted. The product carbon intensity standards changes the manufacturer’s problem from reporting carbon to meeting a limit. Firms cut process emissions, switch inputs, redesign products or, where the accounting method recognises durable atmospheric-carbon storage, use CDR-linked materials or processes. This lever is not green procurement, a low-carbon fuel standard or a voluntary label. It would apply across a covered market, not only to one buyer or tender.

Government must make unlike products comparable by defining the functional unit, lifecycle boundary, data hierarchy, treatment of electricity, recycled inputs and imports, then publishing tightening thresholds. CDR can enter through two routes. Physical uptake can lower the lifecycle result where atmospheric or biogenic CO₂ is demonstrably stored in the product. Book-and-claim does not change the product’s physical footprint under lifecycle accounting; the rule must separately authorise verified removal units to be cancelled and allocated against output. That route needs strict eligibility, allocation and claims rules to prevent double counting or substitution for direct reductions. Small producers need conservative default data.

This lever leverages regulation to stimulate innovation and emissions reductions across supply chains. Opportunities include creating a level playing field where low-carbon products gain a competitive advantage, driving investment into cleaner processes and CDR integration. It sends a strong market signal that rewards sustainable manufacturing, potentially opening new markets for certified low-carbon products and strengthening national leadership in green industries.

Bad boundaries produce good-looking numbers and bad climate outcomes. Firms may shift emissions outside the measured lifecycle, substitute weak industry averages for plant data, or use low-quality credits if allowed. Rapid tightening can raise prices, strand production, squeeze small suppliers and redirect demand to unregulated imports. Rules that credit temporary biogenic storage too generously can confuse delayed emissions with durable removal. A single threshold can also punish products serving different safety or durability functions.

Monitoring can compare the distribution of verified product intensities, compliance failures, import shares, prices and supplier concentration before and after each threshold step. Where storage or removal counts, regulators need separate data on atmospheric origin, durability and reversals. These results should periodically determine whether to tighten, redesign, delay or split the standard, rather than merely confirm that firms filed declarations.

Engaging the industry early is essential to ensure standards are realistic and effective. Manufacturers and suppliers can test data availability and compliance cost. Lifecycle experts and verifiers can challenge calculation rules. Customs, market-surveillance and permitting bodies can expose enforcement gaps. CDR developers should show when atmospheric carbon is stored rather than captured from fossil streams. Workers, consumers and communities can identify price, employment, safety and local environmental trade-offs before thresholds are fixed.

Supranational authorities can set market-wide product rules and police imports, as the EU has done for battery carbon footprints and future ceilings. National governments can legislate lifecycle methods, data requirements and enforceable thresholds. States and provinces can add rules where their constitutional authority permits, as California has done through its building code. Cities can use bylaws and permits to exclude non-compliant materials or buildings, as Marin County and Vancouver demonstrate. Application at higher levels of governance could improve comparability and reduce leakage while lower levels can move faster when they control permitting.