06 - Materials

Bamboo, cork and other non-timber forest products – Responsible sourcing - KBCN1768

Non-timber forest products, such as bamboo and cork should be responsibly sourced to minimise the environmental impacts and protect local ecosystems. However, as they are not timber or timber-based products, these fall outside the scope of the Prerequisite. Where such products are integrated into a building, they should, nonetheless, be assessed and included in the calculator under ‘Other materials’.

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Clarification of ‘Embodied carbon benchmark comparison’ - KBCN1819

The embodied carbon benchmark comparison must always be based on the latest appropriate LCA stage that corresponds to the BREEAM assessment stage being pursued. The purpose of the benchmark comparison is to assess outcome-based embodied carbon performance, using data that is representative of the building at the relevant assessment stage.

Assessment stage requirements

Interim (Design Stage) BREEAM assessments

• Where an interim / design stage assessment is being submitted:
  • The benchmark comparison may be based on a Technical Design LCA, where this represents the latest LCA available at that stage.
  • Benchmark results at this stage are indicative and intended to support design decision-making.

Final Post-Construction Stage (PCS) BREEAM assessments

• Where a final post-construction stage (PCS) assessment is being submitted:
  • Benchmark comparison credits can only be awarded where a Post-Construction Stage (PCS) LCA has been completed.
  • A technical design LCA alone is not sufficient to support benchmark comparison credits at PCS.
  • This is because the PCS LCA is the only assessment that reflects the materials and products actually installed in the completed building, and therefore the only suitable basis for outcome-based benchmarking.

If a PCS LCA is not undertaken, benchmark comparison credits cannot be awarded at final assessment, regardless of whether a technical design LCA was previously completed. This aligns with wider industry frameworks (e.g. RICS WLCA v2 and the UK Net Zero Carbon Buildings Standard), which anchor performance claims to as-built outcomes.

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Independent third party – clarification on the definition - KBCN1805

For the purposes of BREEAM, sister companies or parent companies cannot be considered as third parties.  To be classed as an independent third party, there must be no professional connection or relationship between the LCA consultant/energy assessor, or their company, and the verification body. The third-party verifier must be independent of the LCA or energy assessor and demonstrate impartiality (for general principles, see ISO 17029). To qualify as a third party, the verifier must belong to an organisation not involved in the project and must not provide advice to the project, as this could compromise their impartiality during verification.

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LCA Concept Design stage submission before the assessment is registered - KBCN1437

In certain circumstances, it may be necessary for the design team to submit the Concept Design stage LCA before the BREEAM assessment has been registered. In such cases, please submit the LCA tool and associated files along with details of your situation as follows:

• Licensed BREEAM assessors should do so using the webform: https://tools.breeam.com/projects/queryadd.jsp
• Other interested parties can submit their case to breeam@bregroup.com

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Legally harvested and traded timber – Examples - KBCN0956

The following examples are considered compliant for BREEAM: Legally harvested:

1. Evidence of compliance with the UK government Timber Procurement Policy (see here, timber bought inside the UK only)
2. FSC, PEFC, SFI or GiB certification
3. Evidence of compliance with the EUTR (timber bought inside the EU only)
4. Risk assessment/due diligence documentation demonstrating a low risk of non-compliance with the ‘legally harvested’ requirements given in the manual.

Legally traded:

1. Evidence of compliance with the UK government Timber Procurement Policy (see here, timber bought inside the UK only)
2. FSC, PEFC, SFI or GiB certification
3. Risk assessment/due diligence documentation demonstrating a low risk of non-compliance with the ‘legally traded’ requirements given in the manual.

04-Dec-2025 - Examples updated to include Grown in Britain (GiB) certification. Previous reference to 'CPET' clarified as 'UK government Timber Procurement Policy'.
KBCN applied more widely to all relevant scheme issues in BREEAM and HQM

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Meeting the minimum standard requirement – compliance when chain of custody is broken - KBCN1816

Where there is a broken chain in the last link between the purchase and delivery of certified timber from the supplier and the forwarding distribution of the timber to the site under assessment, such as where the timber has been delivered to a subcontractor or fabricator’s premises instead of direct to site (e.g. as part of a bulk order or where limited storage is available on site), compliance can still be achieved if a documented risk assessment confirms that there is low risk of mixing or substitution of certified and non-certified timber. Ways to demonstrate compliance: A. Verification that the subcontractor or fabricator only purchases and uses certified timber. There must be robust mechanisms in place to verify that all timber materials purchased and delivered originate from sustainably managed sources. This includes maintaining documented timber procurement policies and procedures that mandate certified timber orders and delivery checks. Comprehensive supplier details should be readily accessible for review upon request to demonstrate that all timber is certified. B. Where non-certified timber is handled/stored or sourced, that there are robust control measures in place to prevent any substitution or mixing of certified and non-certified timber at every stage of the process. Documentation demonstrating compliance should be maintained and made available upon request. Examples of appropriate control measures are listed below:

Control	Evidence required
Purchasing records	All purchase orders, requisition notes, and contracts must explicitly specify the product details and confirm that materials are to originate from legal and sustainable sources.
Segregated storage of timber	Site layout map, stock control processes and records to confirm that certified timber is stored away from non-certified timber.
Segregated delivery of timber to site	- All timber must be thoroughly inspected and verified before shipment to confirm that it is correctly marked/labelled as FSC/PEFC-certified. - Delivery notes must be accurately maintained. - A second-party verification process to check tickets and stock, must be carried out upon site delivery to confirm certified status of timber.
Documentation	Comprehensive documentation must enable independent assessors to trace any timber back to its sustainable source. This includes maintaining purchase records, goods-inward notices, stock records, and sales documentation such as orders and invoices.

The above is guidance and should not replace any local or national requirements for the sourcing of legally traded and harvested timber.

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