Embodied Emissions Reporting NSW
Preparation and certification of the NABERS Embodied Emissions Materials Form for NSW non-residential development, ready for lodgement at Development Application and Construction Certificate stages.

What Is Embodied Emissions Reporting?
Embodied emissions reporting measures the greenhouse gas emissions generated by producing, transporting and installing a building’s materials, rather than the energy the building uses once occupied. Reporting involves quantifying construction materials, applying recognised emission factors and documenting the result. In NSW, non-residential development captured by the Sustainable Buildings SEPP reports embodied emissions through the NABERS Embodied Emissions Materials Form. Archi-QS prepares and certifies this form.
Why material data determines the result
Embodied emissions, also called embodied carbon, sit in the materials themselves. Concrete, reinforcement, structural steel, aluminium, glazing, cladding and timber typically account for most of a building’s upfront carbon.
Reporting quantifies how much of each material a project uses, then applies recognised emission factors, or product-specific Environmental Product Declarations where available, to estimate the emissions attached to them.
Because the outcome is driven almost entirely by measured quantities, the credibility of the form depends on the accuracy of the underlying material take-off. That is quantity surveying work, and it is why measured quantities and cost planning sit at the centre of the process.
The reporting chain
Who Needs Embodied Emissions Reporting in NSW?
Not every NSW development requires embodied emissions reporting. Obligations arise under State Environmental Planning Policy (Sustainable Buildings) 2022, and the pathway differs depending on whether the project is residential or non-residential and, for non-residential work, on its estimated development cost.
NABERS: non-residential
Since 1 October 2023, new non-residential development with an estimated development cost of $5 million or more, and alterations for non-residential use from $10 million, must measure and report embodied emissions at both Development Application and Construction Certificate stages.
BASIX: residential
BASIX-affected residential development reports through the BASIX Materials Index at design stage. The index currently returns a score for information only, with no minimum target, but the material selections entered become commitments on the BASIX certificate.
Project-specific requirements
Consent conditions, State Significant Development requirements, green-building schemes and financier expectations can all call for embodied carbon reporting outside the SEPP thresholds. The pathway is confirmed project by project.
Thresholds are assessed against estimated development cost and requirements are periodically updated by the NSW Government and NABERS. Archi-QS confirms whether the Materials Form is required for your project before any work begins.
What Is the NABERS Embodied Emissions Tool?
For mandatory SEPP reporting, the NSW Government accepts the NABERS Embodied Emissions Materials Form (NSW SEPP), an Excel workbook lodged through the NSW Planning Portal. Archi-QS prepares and certifies this form. NABERS Embodied Carbon is a separate, voluntary certified rating for completed buildings, which Archi-QS does not provide.
The NABERS Embodied Emissions Materials Form
The Embodied Emissions Materials Form (NSW SEPP) is an Excel workbook published by NABERS and lodged through the NSW Planning Portal at Development Application stage and again at Construction Certificate stage. The form uses the same structure and databases as the NABERS Embodied Carbon Calculator, so the figures you submit use the same materials database and emission factors as NABERS ratings.
What the form asks for
- Premises details: location, building function, area and building height.
- Material quantities in metric units across structure and substructure, envelope, permanent internal walls and doors, external works, building services and site preparation.
- Optional product-specific emission factors drawn from Environmental Product Declarations, plus custom assemblies and construction data.
- Certifier details: identifying who entered the data and who certified its accuracy.
The form requires material quantities to be determined through an itemised list of building materials, such as a bill of quantities, and certified by a quantity surveyor, designer, engineer or NABERS Embodied Carbon Assessor. Measuring and certifying quantities is core quantity surveying work. Archi-QS forms are certified by a Certified Quantity Surveyor.
NABERS Embodied Carbon ratings
NABERS Embodied Carbon is a separate voluntary certified rating covering upfront carbon (life cycle stages A1 to A5) for new buildings and partial rebuilds, available once practical completion is reached. It must be lodged by an accredited NABERS Embodied Carbon Assessor and relies on a bill of quantities prepared by a costing specialist such as a quantity surveyor. Estimates produced outside that process cannot be advertised as a NABERS rating. Archi-QS does not prepare NABERS Embodied Carbon ratings.
Inputs to the NABERS Embodied Emissions Materials Form
Information
Data
Information
NABERS Embodied Emissions vs BASIX Materials Index
These two frameworks are frequently confused. Both deal with the emissions embodied in construction materials, but they apply to different development types, ask for different information and are completed at different stages.
| Comparison | NABERS Embodied Emissions | BASIX Materials Index |
|---|---|---|
| Primary purpose | NABERS Embodied EmissionsMeasure and report upfront embodied emissions from construction materials for SEPP compliance, using the Embodied Emissions Materials Form. | BASIX Materials IndexEstimate a residential development’s material embodied emissions and report the result within BASIX. |
| Applies to | NABERS Embodied EmissionsNon-residential development under the Sustainable Buildings SEPP: new build from $5 million estimated development cost, alterations for non-residential use from $10 million. | BASIX Materials IndexBASIX-affected residential development assessed through the BASIX tool. |
| Main focus | NABERS Embodied EmissionsMeasured quantities of structure, envelope, internal walls and doors, external works, services and site preparation. | BASIX Materials IndexSelected construction systems for floors, walls, ceilings, roof and glazing. Excludes site, finishes, fit-out and services. |
| Information required | NABERS Embodied EmissionsMaterial quantities in metric units, premises details, and optionally EPDs and product-specific emission factors. | BASIX Materials IndexDevelopment size and material selections; the calculator derives the quantities itself. |
| Reporting / assessment method | NABERS Embodied EmissionsNABERS Embodied Emissions Materials Form (NSW SEPP), lodged via the NSW Planning Portal and certified by a quantity surveyor, designer, engineer or NABERS Assessor. | BASIX Materials IndexCompleted inside the BASIX tool, producing a percentage score against the average for that development type. |
| Project stage | NABERS Embodied EmissionsDevelopment Application and Construction Certificate stages. A certified NABERS rating follows practical completion. | BASIX Materials IndexDesign stage, before the BASIX certificate is issued. |
| Key distinction | NABERS Embodied EmissionsQuantity-based reporting, certified by a suitably qualified professional. | BASIX Materials IndexSelection-based scoring, currently reported for information with no minimum target. |
NABERS and BASIX are separate frameworks and are not interchangeable. Their scope, required information, assessment methods and project stages differ, and applicability depends on the individual project. Meeting one does not satisfy the other. Archi-QS prepares the NABERS Embodied Emissions Materials Form. We do not prepare BASIX Materials Index inputs or NABERS Embodied Carbon ratings.
What Is the BASIX Materials Index?
The BASIX Materials Index is a module within the BASIX tool that estimates the embodied emissions of a residential development’s construction materials. It works from the construction systems selected for floors, walls, ceilings, roof and glazing rather than from a measured take-off, and the score is currently reported for information only. Archi-QS does not prepare BASIX Materials Index inputs.
What Information Is Required for Embodied Emissions Reporting?
The core input for quantity-based reporting is a measured schedule of construction materials, supported by the drawings and specifications it was taken from. Depending on the framework, the following may be required.
Project information
Location, building function, gross floor area, building height and the consent pathway that applies.
Material quantities
Metric quantities for substructure and structure, envelope, permanent internal walls and doors, external works, services and site preparation.
Material specifications
Concrete grades and mixes, reinforcement and structural steel, aluminium and glazing systems, cladding, timber and finishes where relevant.
Drawings and schedules
Architectural and structural drawings, specifications, window, door and finishes schedules, and any bill of quantities or cost plan.
Product documentation
Manufacturer data for specified products, particularly where a product-specific emission factor replaces a database default.
EPDs where applicable
Environmental Product Declarations for nominated products, replacing generic factors with verified product data.
Not every item applies to every project. The exact information required depends on the project and its stage. At Development Application stage, best-available estimates with documented assumptions are generally acceptable; greater detail is expected at Construction Certificate stage. Archi-QS measures quantities from the DA documentation and records any assumptions in the form. Where we also prepare your Estimated Development Cost report, the Materials Form is completed from the same quantities and project cost, so the two documents lodged with your DA are consistent.
How Does Embodied Emissions Reporting Work?
Every project follows the same six steps, from confirming that the SEPP applies to updating the form for the Construction Certificate, as set out in our services below.
When Should You Engage an Embodied Emissions Consultant?
As early as practical, ideally during early design or design development and well before the Development Application is lodged.
Early engagement makes it easier to obtain material information while it is still being specified, assess selections while they can still be influenced, identify missing product documentation, and resolve inconsistencies between drawings, schedules and quantities before they reach a submission. It also lets reporting sit inside the documentation programme rather than becoming a late-stage task. Engaging close to lodgement usually means working from incomplete information under time pressure.
Embodied Emissions Reporting Services by Archi-QS
Archi-QS prepares and certifies the NABERS Embodied Emissions Materials Form (NSW SEPP) for non-residential development. The deliverable is the completed form, issued in PDF for lodgement with your DA or CC.
Applicability check
Confirm whether the Sustainable Buildings SEPP requires the Materials Form for your project.
Documentation review
Review the architectural and structural drawings, specifications and cost plan the form will be based on.
Material take-off
Measure the material quantities the form requires for structure, envelope, internal walls and doors, external works and site preparation.
Materials Form preparation
Complete the premises details and the itemised material quantities, with product-specific emission factors from EPDs where available.
QS certification
Certify the material quantities in the form as the project quantity surveyor.
DA and CC issue
Issue the completed form for lodgement at DA stage, and update it for the Construction Certificate.
Scope note. Archi-QS prepares and certifies the NABERS Embodied Emissions Materials Form (NSW SEPP). We do not prepare NABERS Embodied Carbon ratings, NABERS Embodied Carbon Tool submissions or BASIX Materials Index inputs.
Why Choose Archi-QS for Embodied Emissions Reporting?
Measured quantities and a certified Materials Form, prepared by people who measure buildings for a living. Archi-QS delivers quantity surveying and building consultancy services across NSW.
Quantity surveying at the core
The Materials Form is fundamentally a measurement exercise. Material take-off, quantities and construction data are core quantity surveying disciplines, not an adjacent service.
Construction and materials knowledge
Practical understanding of structural systems, envelope build-ups, concrete, steel, aluminium and glazing as they are actually specified and built.
NSW documentation experience
Regular work with NSW development documentation, consent pathways and NSW Planning Portal lodgements.
Certified Quantity Surveyor
Every Materials Form is certified by a Certified Quantity Surveyor, as the form requires quantities to be determined through an itemised list of building materials.
Reviewed before issue
Each Materials Form is checked against the drawings and cost plan before issue, with assumptions recorded in the form.
One take-off for your EDC and Materials Form
Where we prepare your Estimated Development Cost report, the Materials Form uses the same quantities and project cost, so both DA documents are consistent and nothing is measured twice.
Common Embodied Emissions Reporting Problems
Most difficulties are documentation problems rather than technical ones. These are the issues that most often delay or weaken an embodied emissions submission.
Missing material information
Products specified generically, or supplier data never requested, leaving gaps filled by assumption.
Incomplete quantities
Quantities exist for some elements but not others, so the form cannot cover the expected scope.
Inconsistent documentation
Drawings, specifications and schedules disagree, and the form inherits whichever version was used.
Incorrect material classifications
Materials mapped to the wrong category or assembly, changing the result without anyone noticing.
Outdated product information
Superseded product data or expired declarations carried into a current submission.
Confusing NABERS and BASIX
The wrong framework is assumed to apply, and work is done against requirements the project was never subject to.
Starting too late
Work begins near lodgement, when material information is hardest to obtain and selections can no longer change.
Lack of supporting documentation
Figures provided without the drawings, schedules or product data needed to substantiate them.
Form not updated for CC
DA-stage quantities carried into the Construction Certificate lodgement without reflecting design changes.
Need a NABERS Embodied Emissions Materials Form for your NSW project?
Speak with Archi-QS about your DA or CC lodgement.
Frequently Asked Questions
What is embodied emissions reporting?
Embodied emissions reporting measures and documents the greenhouse gas emissions generated by producing, transporting and installing a building’s materials. It quantifies the materials a project uses, applies recognised emission factors, and presents the result in the format the applicable framework requires.
What are embodied emissions in construction?
Embodied emissions are the emissions attached to construction materials rather than to building operation. They cover the extraction, manufacture, transport and installation of materials such as concrete, reinforcement, structural steel, aluminium, glazing, cladding and timber. Together these are commonly called upfront carbon.
What is the NABERS Embodied Emissions Tool?
The term covers two different NABERS instruments. The Embodied Emissions Materials Form (NSW SEPP) is the Excel workbook used for mandatory SEPP reporting. NABERS Embodied Carbon is a separate voluntary certified rating for completed buildings, covering upfront carbon at life cycle stages A1 to A5. Archi-QS prepares and certifies the Materials Form; we do not prepare NABERS Embodied Carbon ratings.
What is the NABERS Embodied Emissions Materials Form?
It is the Embodied Emissions Materials Form (NSW SEPP), an Excel workbook published by NABERS and lodged through the NSW Planning Portal. Non-residential development captured by the Sustainable Buildings SEPP completes it at Development Application and Construction Certificate stages. Archi-QS prepares and certifies this form.
What information is required for NABERS embodied emissions reporting?
Premises details and measured material quantities in metric units, covering structure, envelope, permanent internal walls and doors, external works, building services and site preparation. Product-specific emission factors from EPDs may be provided where available, along with certifier details.
What is the BASIX Materials Index?
The BASIX Materials Index is a module within the BASIX tool that estimates the embodied emissions of a residential development’s construction materials. Introduced on 1 October 2023, it works from selected construction systems for floors, walls, ceilings, roof and glazing.
What is the difference between NABERS and BASIX materials reporting?
NABERS-based reporting applies to non-residential development and works from measured material quantities. The BASIX Materials Index applies to residential development and works from selected construction systems. They differ in scope, method and project stage, and are not interchangeable.
Who needs embodied emissions reporting in NSW?
Not every development. Under the Sustainable Buildings SEPP, new non-residential development from $5 million estimated development cost, and alterations for non-residential use from $10 million, must report embodied emissions. BASIX-affected residential development reports through the BASIX Materials Index.
When should I engage an embodied emissions consultant?
As early as practical, ideally at early design or design development and well before lodgement. Early engagement makes it easier to obtain material information, assess selections while they can still change, and resolve documentation inconsistencies before they reach a submission.
Can a quantity surveyor prepare embodied emissions reporting?
Yes. The Embodied Emissions Materials Form requires material quantities to be determined through an itemised list of building materials, such as a bill of quantities, and certified by a quantity surveyor, designer, engineer or NABERS Embodied Carbon Assessor. Measuring and certifying quantities is core quantity surveying work. Archi-QS forms are certified by a Certified Quantity Surveyor.
Can Archi-QS help with NABERS embodied emissions reporting?
Yes. Archi-QS measures the material quantities and prepares and certifies the NABERS Embodied Emissions Materials Form (NSW SEPP) for lodgement at DA and CC stages. We do not prepare NABERS Embodied Carbon ratings.
Can Archi-QS help with BASIX Materials Index requirements?
No. The BASIX Materials Index applies to residential development and is completed within the BASIX tool. Archi-QS prepares the NABERS Embodied Emissions Materials Form for non-residential development captured by the Sustainable Buildings SEPP.
Request a Materials Form fee proposal
Send us your drawings and we will confirm what the form requires and our fee, including a combined fee if you also need an Estimated Development Cost report.