London's draft plan proposes binding limits on upfront embodied carbon, but only requires reporting for whole-life carbon. The author argues that after five years of whole-life carbon reporting, the city has enough data to set limits across the entire building life cycle. Capping only upfront emissions risks pushing developers to optimize for construction-stage numbers while ignoring decades of operational and maintenance impacts. The article highlights how a narrow focus on upfront carbon can penalize designs that use slightly more material at construction to cut energy use or avoid replacements over time. Europe is already moving toward mandatory whole-life carbon disclosure under the Energy Performance of Buildings Directive. London should align with that trajectory by setting evidence-based whole-life carbon limits rather than a separate upfront cap.
