6 Materials

Broken chain of custody for legally harvested timber - KBCN1321

The Government website referred to in the ‘Legally harvested and traded timber’ definition in the Responsible sourcing issue, provides the necessary guidance for demonstrating compliance with the prerequisite for this issue, which follows the Central Point of Expertise on Timber (CPET) report on the UK Government Timber Procurement Policy. The ‘Timber Procurement Advice Note (TPAN)’ provides a checklist (Annex E) for evidence of certified timber (category A evidence). You can find this here: https://www.gov.uk/government/publications/timber-procurement-advice-note-tpan-comply-with-tpp Annex F of this document gives further guidance if the supplier isn’t directly certified and there is a broken chain of custody. It notes that ‘As soon as ownership of products is taken by a non-CoC-certificate holder, the products cease to be 'certified'. However, if the evidence is credible, you can make a claim of legal or sustainably sourced products.

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1

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.

Design stage evidence – Responsible sourcing of construction products - KBCN0831

At design stage, a letter of commitment from the design team confirming that the products shall be procured from suppliers capable of supplying products covered by the required responsible sourcing certification scheme is acceptable. The letter must confirm the responsible sourcing certification schemes of the proposed products.

30-Oct-2025 - Applicable to HQM One, HQM V6 and UKNCR V6.1

Early product procurement policy - KBCN1309

A documented product procurement policy and procedure needs to be in place by RIBA stage 2, which sets out the requirements for all suppliers and trades to adhere to in relation to responsible sourcing of products. However, this policy and procedure can be fairly high-level at RIBA stage 2, as long as all other criteria are met, including dissemination and the encouragement of products that have responsible sourcing certification over products that don’t. At this early stage, the policy is likely to contain overarching principles and policies that later feed into a more detailed plan or strategy, further into the design stage. BS8903:2010 and BS8900-1:2013, provide guidance on what is considered good practice. Our experience with BREEAM has shown that considering the potential for responsibly sourced products early on makes procurement of these products more achievable, which in turn makes the associated credits for this more likely to achieve. This principal extends to the other issues in the Materials category as well.

30-Oct-2025 - Applicable to HQM One, HQM V6 and UKNCR V6.1

Evidence requirements – responsible sourcing of materials at post-construction - KBCN1599

Whilst the UK BREEAM manuals are less prescriptive in the evidential requirements to allow flexibility, to ensure consistency across the schemes, it is expected that robust evidence should be provided to verify the source of any certified materials and how the assessor has confirmed the products and manufacturers used. Evidence supplied at post construction stage must reflect the completed building and confirm the responsibly sourced materials that have been procured and installed on the project. Supporting documentation is required to validate letters of confirmation or schedules of materials. Evidence provided could include proof of purchase, for example, invoices, delivery tickets, purchase orders or correspondence from suppliers. This may be an example for each material sourced, rather than every delivery ticket for instance. Alternatively, evidence of the use of the responsibly sourced materials may include as-built drawings, O&M documentation or site photographs.

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1

FSC and PEFC Mixed Sources certified timber - KBCN00091

Products labelled:

FSC Mix or
PEFC Mixed Sources

Meet the BREEAM responsible sourcing requirements. This means any such products:

In HQM, and in BREEAM NC 2016 or older schemes: meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: meet the prerequisite for legal and sustainable timber.
In all schemes: can be used to demonstrate responsible sourcing.

Products carrying the FSC Mix label contain at least 70% FSC certified and recycled material. These products may contain a small proportion of FSC Controlled Wood (KBCN00054). However for BREEAM compliance, the FSC Mix label is sufficient to meet our requirements.

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1
14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

FSC Controlled Wood - KBCN00054

The FSC Controlled Wood label minimises the risk that wood comes from illegal or controversial sources, however it does not eliminate this risk. Therefore, products which are:

Labelled as FSC Controlled Wood or,
Where the majority of material in a product is comprised of FSC Controlled Wood,

Do not meet the BREEAM definition of responsibly sourced. Where FSC Mix labelled products contain FSC Controlled Wood, see KBCN00091. This means that any such products:

In HQM, and in BREEAM NC 2016 or older schemes: do not meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: do not meet the prerequisite for legal and sustainable timber.
In all schemes: cannot be used to demonstrate responsible sourcing.

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1
14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

GN18 BREEAM Recognised Responsible Sourcing Certification Schemes and BREEAM Scheme Applicability - KBCN0723

Latest version: v3.7, May 2023 BREEAM awards credits for responsibly sourcing construction products (typically under the Mat 03 issue) to encourage responsible product specification and procurement in construction. To achieve these credits, applicable specified products (as listed in the relevant technical manual) must be covered by an Environmental Management System (EMS) or a responsible sourcing certification scheme (RSCS) recognised by BREEAM. Guidance Note 18 lists the responsible sourcing certifications schemes recognised by BREEAM along with the relevant summary scores to be used in BREEAM assessments. Download Guidance Note 18 Download Guidance Note 18 v2.0 (licensed assessors only - optional for projects registered prior to release of v3.0 in September 2016) View all Guidance Notes on BREEAM Projects (licensed assessors only)

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1

GN24 Demonstrating compliance with Responsible Sourcing requirements in BREEAM - KBCN0721

Latest version: v1.1, May 2022 Guidance Note 24 provides additional guidance to assessors and specifiers on demonstrating compliance with the criteria set out in Mat 03. It should be read in conjunction with the Technical Manual for the relevant assessment scheme. It covers:

How to deal with constituent products/materials including those with certification that is different from the overall product.
The precision required in estimating quantities:
- For the cut-off volume
- Of products/materials in the building (route 2 only)
- Of different material categories in products/materials.
An example route 2 calculation.
‘Broken chain’ situations.
How to treat building services.

Download Guidance Note 24 (licensed assessors only) View all Guidance Notes (licensed assessors only)

30-Oct-2025 - Title updated. Applicable to HQM V6 and UKNCR V6.1

Insulation – Responsible sourcing - KBCN0907

Insulation is within the scope of the responsible sourcing of construction products.

30-Oct-2025 - Applicable to HQM One, HQM V6 and UKNCR V6.1

LCC – Competent person or Suitably Qualified Cost Consultant (SQCC) - KBCN1803

The definition of a competent person, or SQCC as named within HQM or BREEAM New Construction Residential, has been updated to provide further clarification and is now defined as set out below: An individual achieving all the following items can be considered to be ‘suitably qualified’ for the purpose of completing the LCC credits:

Holds a recognised qualification for undertaking life cycle costing studies and/or a degree/postgraduate diploma or equivalent qualification in quantity surveying, construction economics or other construction-related subject.
Has acquired substantial expertise through a minimum of three years relevant experience (within the last five years). The experience must clearly demonstrate a practical understanding of life cycle costing in construction and the built environment and show an ability to identify and demonstrate cost and performance enhancement measures.
Is not professionally connected to a single manufacturer

A CV should be provided demonstrating their experience and knowledge against the above requirements.

Legally harvested and traded timber – Examples - KBCN0956

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

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

Legally traded:

Evidence of compliance with the UK government Timber Procurement Policy (see here, timber bought inside the UK only)
FSC, PEFC, SFI or GiB certification
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

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.

Mixed use buildings (benchmark) – Embodied carbon reporting tool - KBCN1729

Where the assessed building is mixed use, a comparative, floor-area-weighted benchmark is used to determine the number of credits awarded for criteria ‘06 Embodied carbon benchmark comparison’. To calculate this, in the ‘Embodied carbon reporting tool’, in the ‘1. Project Input’ tab, enter:

the number of building types within the assessed building, and

the floor area (GIA) of each of the different building types

This will enable the tool to calculate the floor area weighted benchmark on the ‘5. Benchmark’ tab

Product procurement policy after RIBA stage 2 - KBCN0994

Where a product procurement policy is put together at a later stage than RIBA stage 2, ‘02 Product procurement policy and product environmental information’ credits may still be achievable. If it can be confirmed by the person responsible for the policy that the policy will not restrict procurement of responsible sourced construction products due to its late production and implementation, then the credits can still be awarded (provided all other compliance requirements are met).

30-Oct-2025 - Applicable to HQM One, HQM V6 and UKNCR V6.1

Raised access floors – Responsible sourcing - KBCN00018

For the purposes of responsible sourcing, raised access floors should be considered as part of the floor structure.

30-Oct-2025 - Applicable to HQM Beta, HQM One, HQM V6 and UKNCR V6.1

Responsible Sourcing – Scope when a BREEAM assessment covers only part of the new building - KBCN1217

To give reliable results, the assessment of responsible sourcing must capture the interactions that occur across an entire design (the system). A design decision in one part of the design will, in many cases, cause knock-on effects to other parts of the design. If only part of a building being designed is included in the assessment the designer may choose a design option that optimises responsible sourcing performance for the limited part analysed, but will be unaware of potential detrimental effects to the overall responsible sourcing performance of the building. In addition, if a responsible sourcing assessment only includes the construction products that form the BREEAM assessment area, inconsistencies arise with regards to construction products that serve all areas of the building in common. For example, an assessment on a central floor that excludes the roof, compared with an assessment on the (otherwise identical) top floor that does include the roof. This approach would be unfair. Therefore, notwithstanding the exception below for internal finishes, the responsible sourcing scope must include the whole building design (as defined in Mat 03, 'Scope of assessment') even if the area covered by BREEAM assessment is only part of the design. The exception to this is any construction products classified as '3. Internal finishes'. Internal finishes are specific to each part of the building with little or no functional relationship with other parts. Therefore, the scope of the assessment of internal finishes shall be limited to the assessed area only.

08 October 2025-made applicable to HQM and UK NCR

Responsible sourcing certification – validity - KBCN1693

Where it can be demonstrated that the responsible sourcing certificates were valid either at the time of specification, or at the time of purchase, they may contribute to the awarding of the credits. BREEAM is primarily trying to encourage designers to take responsible sourcing into consideration when specifying or selecting products and as such it is not necessary for certification to be valid at the time of design or post-construction stage submissions.

30-Oct-2025 - Applicable to HQM V6 and UKNCR V6.1

UKNC: Residential (HQM) / UKNC: Residential V6.1 / B - My home /

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