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Why Australia’s net zero plan needs fast-growing biobased partners

Mon, 16 Mar 2026 08:14:35 GMT

Why Australia’s net zero plan needs fast-growing biobased partners

First published on The Fifth Estate - https://thefifthestate.com.au/columns/spinifex/why-australias-net-zero-plan-needs-fast-growing-biobased-partners/

Globally, engineered bamboo has scaled in projects like the Chinese Pavilion at Expo 2025, Japan.

The Australian government’s Net Zero Plan sets an ambitious pathway to cut emissions. While it centres on renewables, land sinks, and hard-to-abate sectors, it points to biobased materials like timber in reducing emissions from construction and fuels but to meet urgent goals this decade, we must embrace faster biobased partners beyond traditional timber.

Current policy and funding default to plantation timber on 25–30 year cycles. This is vital but too slow for the decisive decade to 2035. The “time value of carbon” means a tonne sequestered or avoided now has far more impact than one in 2050.

Fast-growing biobased crops: what are they and why do they matter?

Fast-growing crops like engineered bamboo, industrial hemp, flax and miscanthus can be harvested in three to seven years. They deliver quick carbon capture and circular product streams.

Bamboo species (like dendrocalamus asper) sequester 30-50 tonnes of carbon dioxide a hectare, a year in suitable climates. Hemp captures 10-22 tonnes of carbon dioxide a hectare, a year in early seasons for construction and food. Residues produce biochar for soil storage and bio-oil for drop-in fuels.

One integrated system advances three net zero goals: construction decarbonisation, land-sector sinks, and renewable fuels.

Hempcrete is set to be “used extensively in the University’s Forestry and Timberyards redevelopment”. Photo: Woods Bagot

Biobased materials in action: integrated systems and demonstrated success

Biobased materials are increasingly being used in Australia for residential homes, eco-villages, and commercial developments. More than a hundred hempcrete constructions have been completed, such as the University of Tasmania’s Forestry Building. The First Building at the Bradfield City development also highlights engineered bamboo battens as an important feature in sustainable design, demonstrating the practicality of these materials.

Globally, engineered bamboo has scaled in projects like the Chinese Pavilion at Expo 2025, Osaka.

Project BEAM in the Philippines also demonstrates bamboo’s viability in commercial developments.

Project BEAM in the Philippines, a 600-square-metre clinic by well-known developer Arthaland, the nation’s first commercial-scale engineered bamboo structure. Source: https://www.youtube.com/watch?v=D1PvyPB8Ulg

The absurdity of timber-only modelling

These opportunities remain invisible in modelling because abatement models rely on radiata pine, blue gum, and native regrowth data. No datasets exist for engineered bamboo or hemp under Australian conditions. This creates a loop: limited data leads to low modelled impact, which leads to a low priority and persistent gap.

As Climateworks Centre notes , “There is no path to net zero without nature,” but timber-only solutions overlook faster options.

A 2025 report by academic group Net Zero Australia calculated 200,000 hectares of new forest would be needed yearly to reach net zero by 2050. Yet it makes no mention of fast-growing biobased alternatives that sequester carbon faster while supporting jobs and land use. Nor does it address the time value of carbon. In a nation racing to build 1.2 million homes over five years, it’s absurd to model net zero on timber-centric solutions.

The First Building at Bradfield City has used bamboo battens. Photo: House of Bamboo/Vinchy Wu

Policy gaps and opportunities: moving beyond timber

Industrial hemp has received some research funding and bamboo is still absent from national strategies and funding programs, even though it has proven its performance overseas.

The Great Koala National Park in NSW, announced in September 2025, intends to protect 476,000 hectares of timber. However, it also halts timber harvesting, which raises concerns for 1,700 workers still recovering from the 2020 bushfires. Independent MP Michael Regan told ABC Sydney that national parks can outperform logging through ecotourism and environmental credits. Fast-growing crops like bamboo also offer new jobs in processing

Under the National Housing Accord NSW must deliver 377,000 homes a year until 2029 (which requires around 160,000 metre square of structural hardwood annually). But with 40 per cent of the native hardwood industry gone and blackbutt prices up 46 per cent since 2020, the numbers simply don’t add up. A 2024 review by the NSW Independent Pricing and Regulatory Tribunal review showed native logging lost $29 million in 2023–24 and recommends a feasibility review in 2028 if economics don’t improve.

Meanwhile, laminated veneer lumber (LVL) imports surged 63 per cent to 205,343 cubic metre in the year ending October 2025. China supplied 69 per cent of this, at 68 per cent below the average price. This highlights Australia’s growing reliance on imports amid domestic shortages.

The table below shows the opportunity. One hectare of dendrocalamus asper bamboo can yield enough material for over 100 homes within seven years and supports annual harvests for decades, far outpacing traditional timber.

Right now, the bamboo industry has no dedicated support to make this possible.

Australia should adopt fast-growing biobased options, regenerate marginal lands, and support communities in transition.

Table 1: timber vs engineered bamboo: land required and harvest frequency over 25 years

Social and environmental co-benefits: more than just carbon

Fast-growing biobased systems deliver benefits far beyond carbon capture. Well-managed bamboo plantations can provide a habitat for native wildlife and act as biodiversity corridors when integrated with conservation plantings and natural buffers. Perennial grasses and bamboo restore soil structure, reduce erosion, and rehabilitate degraded farmland through above-ground harvesting that leaves roots intact. Partnerships with First Nations groups can ensure culturally appropriate land management and economic opportunities, while diversifying rural economies and offering resilient income streams for regions in forestry transition.

Fast-growing bamboo at Woodford, Queensland – Used to create their own structures onsite.

Recommendations and next steps: turning vision into action

Governments and industry should:

Recognise the time value of carbon in funding decisions under the Net Zero plan, Powering Australia plan, and National Reconstruction Fund
Create a “Rapid Biobased Materials” eligibility category in the Australian Sustainable Finance Taxonomy
Open a $300-500 million demonstration window in the National Reconstruction Fund for integrated fast-biobased projects
Broaden the Clean Energy Finance Corporation’s support to include biobased ventures
Establish a taskforce to publish a National Biobased Materials Roadmap by mid-2026

Leading the way with fast-growing partners

Australia has the land, climate and expertise to lead in rapid, circular biobased systems. Timber opened the door. Welcoming fast-growing partners like bamboo, hemp, and perennial grasses, while working closely with Indigenous communities, delivers the most effective path to net zero, today.

Beyond Greenwashing: Protecting Fair Competition and Ethical Supply Chains in the Transition to Net-Zero

Mon, 16 Mar 2026 08:14:12 GMT

Beyond Greenwashing: Protecting Fair Competition and Ethical Supply Chains in the Transition to Net-Zero

First published on Sourceable - https://sourceable.net/beyond-greenwashing-protecting-fair-competition-and-ethical-supply-chains-in-the-transition-to-net-zero/

In my recent articles on greenwashing, from the "Three Shades Of Green You Don't Want To Be Tarnished With" to "The Emerging Fourth Green Shade: Beyond Greenwashing", I've explored how superficial or misleading sustainability claims can undermine genuine progress toward decarbonisation.

These pieces highlight the importance of authenticity. This involves moving past inauthentic practices to evidence-based approaches that truly reduce emissions across construction, materials, and operations.

But authenticity extends beyond environmental claims. As industries accelerate the shift to low-carbon futures, including the collaborative “family affair” of biobased solutions needed to close gaps and eliminate fossil fuel dependencies, another layer of integrity becomes critical: fair competition in supply chains. When market dynamics allow undue influence or unfair tactics to distort choices, it risks slowing innovation, limiting informed decision-making and eroding the ethical foundations that support net-zero goals.

Unconscionable Conduct: A Rising Focus in Supply Chains

While greenwashing often involves misleading representations (a breach of section 18 of the Australian Consumer Law ), unconscionable conduct under sections 21–22 of the ACL addresses subtler but equally damaging issues in business-to-business dealings. These provisions prohibit conduct that is, in all circumstances, against good conscience. Examples include exploiting power imbalances, applying undue pressure or using unfair tactics that disadvantage others in the chain.

Unconscionable conduct has historically received less attention than misleading claims. However, recent enforcement shows that the Australian Competition and Consumer Commission (ACCC) takes it seriously. This is particularly the case where systemic practices affect vulnerable parties or distort fair outcomes.

A prominent example is the Optus case. In this case, the Federal Court ordered Optus Mobile Pty Ltd to pay a $100 million penalty in September 2025 for unconscionable conduct in sales and debt collection practices (following Optus’s admission in June 2025) accc.gov.au. The conduct involved inappropriate pressure tactics, exploitation of vulnerabilities and failure to ensure fair dealings. It affected hundreds of consumers over several years. While this case involved a business dealing with consumers, similar principles apply broadly to B2B contexts. Undue influence or harsh tactics that steer decisions away from merit-based choices can breach the law, especially in sectors with concentrated power or where professionals rely on balanced information to make informed recommendations.

The ACCC’s 2025–26 Compliance and Enforcement Priorities reinforce this emphasis. Unconscionable conduct remains a key area, alongside enduring concerns such as anti-competitive agreements and misuse of market power. These priorities target conduct that impacts the cost of doing business, supply chain fairness and sectors which are critical to economic and environmental transitions. The priorities underscore that ethical approaches are not optional but are essential for compliant, innovative markets.

Unbalanced Analyses, Fair Dealing, and the Role of Transparency

On a related note, discussions around material scalability and sustainability often draw on studies or reports that aim to inform policy and practice. When analyses apply inconsistent methodologies — such as differing treatments of carbon dynamics, yield potentials, or lifecycle impacts across options — they can present an unbalanced view. This isn’t always unconscionable, but it can border on unfair dealing if it misleads stakeholders about relative merits.

Transparency adds another essential dimension. This involves disclosing funding sources, author affiliations and potential conflicts of interest. When studies are presented as objective without clear revelation of who funded the work or any industry ties that might influence assumptions, it risks eroding credibility and creating misleading impressions. The ACL’s prohibition on misleading conduct (s 18) applies here — representations (including those based on research) must not lead reasonable persons into error, and material omissions (like undisclosed influences) can contribute to that. The ACCC has emphasized that claims in sustainability contexts should be substantiated and transparent to avoid distorting informed choices.

This supports ethical supply chain principles: genuine collaboration needs transparency so that discussions are guided by evidence and inclusivity, not by concealed agendas.

Ethical Supply Chains and the Role of Collaboration

This focus on unconscionable conduct, fair dealing, and transparency aligns closely with ethical supply chain principles. Initiatives like the Supply Chain Sustainability School emphasise transparency, collaboration, and integrity. These are values that support authentic decarbonisation by enabling diverse, low-carbon options to compete fairly. When undue influence limits open evaluation or creates artificial barriers, it can hinder the collaborative progress which is needed for faster emissions reductions and resilient supply.

The ACCC also provides guidance on sustainability collaborations through its updated “Sustainability collaborations and Australian competition law – a guide for business” (updated 5 December 2025 to incorporate new case studies relating to modern slavery and amend one case study for clarity). The guide clarifies that genuine public-benefit collaborations — such as joint efforts to address shared risks or build capacity — are often low-risk under competition law, provided they do not harm competition or entrench existing players. This encourages broad stakeholder engagement and evidence-based approaches, rather than closed-door dynamics that might limit innovation.

Upholding Fair Markets for a Sustainable Future

Fair competition is not about restricting industry; it’s about ensuring markets reward merit, evidence and ethical practice. By avoiding unconscionable tactics, embracing transparent dealings (including funding disclosures) and upholding balanced information flow, businesses can foster environments where sustainable innovations thrive. This will help to accelerate the transition to fossil fuel-free construction, close overlooked emission gaps, and deliver real benefits for housing, the economy and the planet.

As we continue pushing for authenticity in sustainability — whether through better material integration, supply chain ethics, or collaborative policy — upholding these obligations becomes part of the solution. The ACCC’s tools and priorities exist to protect that integrity. Let’s keep the conversation open, evidence-driven, and focused on what truly advances net-zero: fair, collaborative, and conscientious markets.

Disclaimer : The information contained in the article is intended only to provide a general overview of matters of interest and is intended to apply only within Australia. It does not constitute legal advice.

Jeremy Mansfield OAM is Founder/Director of Mansfield Advisory.

He advises government, industry, and projects on sustainable construction practices and decarbonisation.

Why Energy Efficiency Must Be Central to Decarbonising Diesel-Dependent Equipment Sectors

Mon, 16 Mar 2026 08:12:55 GMT

Why Energy Efficiency Must Be Central to Decarbonising Diesel-Dependent Equipment Sectors

January 5, 2026

Australia’s construction, infrastructure, and off-road industries rely heavily on diesel fuel, which contributes significantly to the nation’s emissions. The government’s fuel tax credit scheme, designed to support these sectors, now costs over $15 billion each year. While progress is being made with electrification pilots, low-carbon fuel experiments, and efforts to reduce carbon in building materials, one crucial approach is being overlooked: making better use of the fuel we already consume. Without focusing on this, we’re wasting valuable resources and slowing our journey to net zero emissions.

The Challenge: Diesel’s Stubborn Grip on Construction

According to Infrastructure Australia’s 2024 projections, the construction sector could produce between 37 and 64 million tonnes of carbon dioxide equivalent (Mt CO₂e) annually through 2026–27. This comes from on-site machinery like dozers, loaders, and excavators, which work tirelessly during digging, pouring, and grinding phases, alongside the materials used. Estimates suggest these activities burn 7 to 10 billion liters of diesel each year, a figure subsidized by tax credits but largely ignored in plans to cut emissions.

The Efficiency Advantage: Making Every Drop Count

Upgrading to modern engines can transform how we use diesel, offering clear benefits for businesses and the environment. Consider the following advantages:

Significant Fuel Savings : Engines meeting EU Stage V or US Tier 4 Final standards reduce fuel consumption by 20 to 35 percent, thanks to simpler improvements like better combustion. This means less fuel is needed for the same work, cutting costs over time.
Quick Return on Investment : Switching from older Tier 2 or 3 engines—some still imported—can save enough money to cover upgrade costs in just 1 to 2 years, making it a practical choice for companies.
Amplified Impact with Alternatives: When paired with a 20 percent cut from biodiesel, the savings grow because the engine uses 30 percent less fuel to begin with, making greener fuels more effective.

This approach provides a practical, no-regrets foundation for deeper emissions reductions, proving efficiency is a win-win strategy.

Additional Co-Benefits: Cleaner Air and Healthier Communities

Beyond cutting carbon emissions, newer standards also reduce harmful pollutants like PM2.5 and nitrogen oxides (NOx), tiny particles and gases that can penetrate deep into the lungs and are linked to serious health issues such as lung cancer, heart disease, and respiratory problems. Construction workers face higher exposure on job sites, and nearby urban communities are affected too, especially in densely populated areas. In response, London has introduced strict rules, mandating Stage IV engines by 2025 and upgrading to Stage V by 2030 to protect public health. In Australia, Western Australia has guidelines to limit diesel exposure in mining operations, but no similar nationwide rules exist for construction—making the case for cleaner, more efficient equipment even stronger.

A Proven Hierarchy We’re Missing

Around the world, experts follow a clear decarbonisation hierarchy to tackle emissions effectively (see Figure 1). It starts with avoiding unnecessary emissions through smart design and reuse, such as planning projects to minimise waste. Next, it emphasises reducing fuel use by upgrading machinery, like adopting Stage V engines that save 20–35 percent. Then, it suggests switching to low-carbon alternatives such as electrification or sustainable fuels. Finally, it allows for compensating any remaining emissions with high-quality offsets. This approach, supported by the International Energy Agency, C40 Cities, and the World Green Building Council, ensures the best results. Unfortunately, Australia often jumps straight to switching fuels without prioritising reductions, missing a key opportunity.

Figure 1: Decarbonisation Hierarchy for Construction & Infrastructure. A prioritised approach to emissions reduction, highlighting effieincy as a critical step in reducing demand for fuels.

Global Benchmarks: Efficiency as a Core Strategy Elsewhere

Internationally, efficiency is proving its worth in meaningful ways. The GlobalABC’s 2024–2025 Report highlights how mandatory codes and equipment retrofits have, for the first time, separated construction growth from rising emissions by improving how resources are used. Cities like Oslo, Helsinki, London, and Amsterdam—part of the C40 network—combine resource efficiency with zero-emission mandates, with Oslo requiring fossil-free construction sites since 2019 and planning fully zero-emission public sites by 2025. The EU’s Stage V standards, in place since 2019, improve fuel use while reducing pollutants, prompting cities like London to tighten machinery rules. Meanwhile, the IEA and WorldGBC roadmap shows efficiency can cut embodied and operational emissions by 20 to 50 percent. In contrast, Australia focuses heavily on material and fuel changes, neglecting on-site fuel optimisation.

Australia’s Missed Opportunity

Reports from the Australia Institute and the Clean Energy Finance Corporation call for reforming subsidies and switching to alternative fuels, but they don’t link these incentives to efficiency upgrades, which could maximise their impact. Infrastructure NSW’s 2025 Roadmap prioritises low-carbon fuels and materials, yet overlooks the fuel savings possible with better engines that could enhance those efforts. The Heavy Vehicle Industry Australia supports improving fleet efficiency, but this focus hasn’t reached off-road construction equipment guidance. Federal plans, including the 2025 Transport Roadmap, address on-road and material emissions but leave out off-road diesel opportunities, risking an influx of outdated machinery.

Overcoming Barriers and Moving Forward

Some worry that upgrading equipment is too expensive, but the evidence suggests otherwise. Here’s how efficiency can work in practice:

Cost-Effective Upgrades : The 20–35 percent fuel savings from modern engines can cover costs in 1 to 2 years, offering a strong financial incentive.
Global Success Stories : Cities like Oslo and the EU’s Stage V adoption demonstrate how efficiency smooths the transition to low-carbon solutions.
Actionable Steps : We recommend tying fuel tax credits to Stage V compliance, setting national machinery benchmarks, requiring better diesel usage reporting, and learning from C40 cities and GlobalABC with retrofits and zero-emission goals.
B ridging to the Future : While electric technology is likely the endgame for decarbonisation of construction equipment, optimising fuel use now provides a critical interim step, reducing emissions and costs until electric solutions are fully scalable.

Policymakers and industry leaders must act now to make efficiency the foundation of our decarbonisation efforts. This approach will unlock cost savings, improve air quality, and accelerate our path to net zero.

References

Australian Taxation Office. (2025). Fuel Tax Credits Scheme Annual Report 2024–2025. Canberra: ATO.
Department of the Treasury. (2024). Budget Paper No. 2: Budget Measures 2024–2025. Canberra: Australian Government.
Infrastructure Australia. (2024). Embodied Carbon Projections for Australian Infrastructure and Buildings 2024. Sydney: Infrastructure Australia.
Australian Government. (2024). Australian Petroleum Statistics 2023–2024. Canberra: Department of Industry, Science and Resources.
Atlas Copco. (2023). Stage V Technical Guide: Engine Efficiency and Emissions. Nacka: Atlas Copco.
UK Health and Safety Executive. (2023). Diesel Engine Exhaust Emissions in Construction: Health Risks. London: HSE.
Safe Work Australia. (2024). Diesel Exhaust Exposure Guidelines. Canberra: Safe Work Australia.
Greater London Authority. (2024). Non-Road Mobile Machinery Low Emission Zone Policy 2025–2040. London: GLA.
Western Australia Department of Energy, Mines, Industry Regulation and Safety. (2023). Diesel Emissions Management Guidelines. Perth: DEMIRS.
International Energy Agency. (2024). World Energy Outlook 2024; C40 Cities. (2024). Clean Construction Programme Report; World Green Building Council. (2024). Net Zero Carbon Buildings Roadmap. Paris/London: IEA/C40/WorldGBC.
Australia Institute. (2024). Subsidies and Sustainability: Reforming Fuel Tax Credits; Clean Energy Finance Corporation. (2024). Decarbonizing Heavy Industry Report. Canberra/Sydney: Australia Institute/CEFC.
Infrastructure NSW. (2025). Decarbonising Infrastructure Roadmap 2025. Sydney: Infrastructure NSW.
Heavy Vehicle Industry Australia. (2024). Transition to Low-Emission Fleets: Policy Submission. Canberra: HVIA.
Department of Infrastructure, Transport, Regional Development, Communications, and the Arts. (2025). Transport and Infrastructure Net Zero Roadmap and Action Plan 2025. Canberra: Australian Government.
International Council on Clean Transportation. (2021). Efficiency Technology Potential for Heavy-Duty Vehicles. Washington, DC: ICCT.

Timber Needs Its Biobased Bedfellows: Why the Fastest Path to Decarbonising Construction is a Family Affair

Mon, 26 Jan 2026 02:01:18 GMT

Timber Needs Its Biobased Bedfellows: Why the Fastest Path to Decarbonising Construction is a Family Affair

The legitimate concerns remain

Not every timber operation in Australia, past or present, has been responsibly managed. Native-forest logging in particular has faced sustained and entirely justified criticism for its impacts on biodiversity, endangered species and habitat fragmentation. Those concerns are real, evidence-based and must stay firmly on the table.

The risk of throwing the baby out with the bathwater

Tony Arnel is right to warn that when those valid criticisms, rightly aimed at past practices, start to be applied to responsibly sourced plantation timber too, we risk losing one of our best tools.

Australia has a housing crisis and binding 2030 emissions-reduction targets. Responsibly grown plantation timber is one of the lowest-carbon structural materials we have at scale right now. If well-intentioned opposition unintentionally limits us from using more of it, we only make the already difficult tasks of decarbonising construction and delivering affordable homes even harder.

A constructive way forward

The answer is not to dismiss the criticisms, nor fall into a defensive “timber-is-the-only-answer” rhetoric. The answer is to keep the legitimate concerns where they belong, keep using responsibly grown plantation timber, and actively bring in its fast-growing biobased relatives.

Arnel describes timber as “the only mainstream structural material that’s indefinitely renewable” in his recent Fifth Estate article . [1] The intent is understandable, but the word “only” is both factually and strategically unnecessary. Engineered bamboo, made by laminating treated bamboo strips into strong, uniform beams and panels, much like glulam timber, is already code-approved in multiple jurisdictions for beams, columns and large-stud framing, with strength equal to the premium hardwoods Australian builders have long relied on. Hempcrete (hemp-lime composites) provides excellent infill insulation and non-structural blocks; engineered straw panels and mycelium composites are load-bearing or semi-structural in completed buildings today. Cross-laminated bamboo-timber hybrids have reached seven storeys. These are proven, ready-to-use materials that grow far faster than plantation trees.

The market sees the opportunity

The global bio-based construction materials market is projected to grow from ≈US$35 billion in 2025 to ≈US$195 billion by 2035, at a 19% compound annual growth rate.[2] The fastest-growing segments globally are precisely these non-timber biobased materials, bamboo, hempcrete, straw, mycelium and agricultural-residue panels, expanding at 15–20% annually or more.[3] In Europe, non-timber biobased insulation and infill already outpace timber volume growth in new Passivhaus projects. The pie is expanding rapidly, giving Australian industry a genuine chance to lead rather than follow.

Hybrids are already outperforming single-material designs

Real buildings prove the point today:

Ninghai Bamboo Tower, China (Prof. Yan Xiao, Zhejiang University, 2024), seven storeys, cross-laminated bamboo-timber structure. Whole-life carbon 65–70% lower than concrete equivalent; 40% faster construction.[4]

First Building, Bradfield City Centre, Sydney (Hassell / Bradfield Development Authority, 2025), prefabricated timber frame + engineered bamboo battens and cladding + rammed-earth core. Embodied carbon <400 kg CO₂e/m². [5]

Recent European Passivhaus and social-housing projects (2024–2025) — timber or glulam frames paired with straw or mycelium panels providing superior summer comfort, acoustics and circularity.[8] Examples include the EcoCocon Factory (UK, construction 2024–2025) using glulam frames with prefabricated straw panels for airtight, energy-positive walls; the award-winning Old Holloway Passivhaus (UK, referenced in 2025 awards) with timber-straw infill achieving 120% energy production via solar; and Scotland's social housing surge (e.g., Glasgow/Edinburgh prototypes) blending glulam with mycelium-enhanced straw for multi-unit acoustics.

Why “more of the same” won’t close the gap in Australia

Domestic sawn softwood production is essentially static (or slightly declining after bushfire losses), while demand is forecast to rise from ~4.2 million m³ today to 6–6.5 million m³ by 2050, a 40–50% increase.[6] Imports, already close to 20% of supply in 2022 and rising, are projected to exceed 40% by mid-century, often from regions with different (and sometimes lower) certification standards than Australia’s certified plantations.[7]

FWPA Forecast 2002–2050: Actual sawn-softwood imports have hovered around 20% of supply (green line), but the implied gap needed to meet demand requires them to rise to 40.5% by 2050 (black line) — more than double today’s level. As the FWPA report notes [8 - at p50]: "By no later than 2031, the requirement for import supply will be permanently above the long-term average proportional contribution of imports. Notably, it is also the case that by no later than 2036, the requirement for import supply will be permanently above the long-term average actual import volume."

Simply planting more slow-growing pines cannot close this gap quickly enough. Fast-cycling biobased materials, engineered bamboo on marginal land, hempcrete from annual crops, straw and mycelium panels from existing agriculture, can deliver structural and semi-structural supply within 5–7 years, not 25–35. They are the necessary complement to plantation timber and, strategically, a powerful way for the timber industry itself to diversify its supply portfolio.

Carbon speed matters too

It’s not just about volume of timber; it’s about how quickly we can pull carbon out of the atmosphere when we are already in a climate emergency.

Plantation softwood is excellent at long-term storage, roughly 250 kg CO₂e per cubic metre locked away for decades once in a building.[9] But it takes 25–35 years to grow that cubic metre. That means the average annual sequestration rate on a pine plantation is only ~8–12 tonnes CO₂e per hectare per year. Crucially, radiata pine does not become a meaningful carbon sink until roughly year 7–9 after planting, and it only reaches its peak sequestration rate (25–40 t CO₂e/ha/yr) between about year 12–20. [14][15]

Fast-cycling biobased crops operate on an entirely different timescale:

Industrial hemp removes 10–22 tonnes CO₂e/ha in just 100–120 days. When turned into hempcrete, every cubic metre is carbon-negative (−100 to −310 kg CO₂e) because the lime binder re-absorbs CO₂ as it cures.[10]
Engineered bamboo (non-invasive clumping species) sequesters 35–50 tonnes CO₂e/ha/year during its 3–7 year growth phase — 3–5× higher than pine plantations, and the finished laminated bamboo stores ~300–350 kg CO₂e/m³.[11]
Straw and agricultural-residue panels use by-products that would otherwise decompose or be burned, avoiding emissions and providing insulation with embodied carbon close to zero.[12]
Mycelium composites are grown in days on waste substrates and routinely achieve −50 to −150 kg CO₂e/m² of panel across the lifecycle.[13]

In climate terms, this matters enormously. A hectare of hemp or bamboo removes as much CO₂ in one year as a pine plantation removes in three to five years. When we need drawdown now, not in 2050, the time value of that carbon is decisive.

Hybrid buildings that combine plantation timber frames with hempcrete infill, bamboo beams and straw/mycelium panels can reach net-negative embodied carbon (A1–A5) today, something almost impossible with timber-only systems once transport and processing are fully accounted for.

The supply-gap argument and the time-value-of-carbon argument point to the same conclusion: relying solely on slow-growing plantations leaves both volume and urgent decarbonisation targets at risk. Fast-cycling, high-sequestration biobased crops are not optional extras, they are the fastest, most powerful complement we have.

Most research and policy funding in Australia still flows almost entirely to long-rotation forestry solutions, perfectly good, but inherently slow. Almost none is directed at these fast-cycling agricultural crops that can deliver usable, low-carbon building products in months or a handful of years instead of decades. If we want both volume and rapid decarbonisation, that balance must change.

Time to work as a family

FWPA, Hemp Industry Australia, Bamboo Society of Australia, the Australian Straw Bale Building Association, mycelium researchers and allied groups don’t need a perfect slogan, they just need to start talking and collaborating now. Joint research, shared supply-chain mapping, combined trade displays and unified advocacy would carry far more weight than any single voice.

Plantation timber remains the big sibling for primary structure and long-term carbon storage. Its faster relatives, engineered bamboo for beams and framing, hempcrete for infill and insulation, straw and mycelium for panels, handle the jobs timber cannot do quickly or on certain land.

Together they give us greater supply security, fewer imports, and more productive hectares.

One ordinary Australian house wall in 2030 could be built like this:

Plantation pine frame (25–35 years to grow)
Laminated bamboo beams and large studs, grown in the wide rows between young pines or on the salty paddock next door (ready in 3–7 years)
Hempcrete infill poured from last summer’s hemp crop
Straw or mycelium insulation panels made from this season’s wheat stubble

Four everyday Australian crops. One wall. All grown here.

Jeremy Mansfield OAM is founder and director of Mansfield Advisory, supporting the transition to sustainable construction practices, supporting engineered bamboo industry development, nature-based construction materials and low-carbon building solutions for Australia.

References

[1] Arnel, T. (2025). We can't decarbonise construction if we demonise timber. The Fifth Estate. https://thefifthestate.com.au/columns/spinifex/we-cant-decarbonise-construction-if-we-demonise-timber/

[2] Future Market Insights. (2025). Bio-Based Building Materials Market | Global Market Analysis Report - 2035. https://www.futuremarketinsights.com/reports/bio-based-building-materials-market

[3] Bio-based Industries Consortium (BIC). (2024). BIC Trend Report 2024-2025. https://biconsortium.eu/publication/bic-trend-report-2024-2025 (includes insights on fast-growing segments like bamboo, straw, and mycelium via Nova-Institute collaborations).

[4] Zhejiang University. (2024). Topping off of the first multi-story engineered bamboo building. https://www.zju.edu.cn/english/2024/0130/c19573a2876560/page.psp

[5] Bradfield Development Authority. (2025). First Building sets sustainable and resilient benchmark for Bradfield City Centre. https://www.nsw.gov.au/departments-and-agencies/bradfield-development-authority/news-and-updates/first-building-sets-sustainable-resilient-benchmark-for-bradfield-city-centre

[6] Australian Bureau of Agricultural and Resource Economics and Sciences (ABARES). (2024). Australian forest and wood products statistics, September 2024. https://www.agriculture.gov.au/abares/research-topics/forests/forest-economics/forest-wood-products-statistics

[[7] Forest & Wood Products Australia (FWPA). (2022). Future Market Dynamics & Potential Impacts on Australian Timber Imports – Final Report. https://fwpa.com.au/wp-content/uploads/2023/11/SAE179-2021_Future_market_dynamics__potential_impacts_on_Australian_timber_imports.pdf

[8] Passivhaus Trust. (2025). Exemplar Sustainable Building Awards 2025: EcoCocon Straw Panel Winner (covers Old Holloway, EcoCocon Factory, and Scottish social housing prototypes). https://www.passivhaustrust.org.uk/news/detail/?nId=1445

[9] Forest & Wood Products Australia (FWPA). (2023). Carbon storage in harvested wood products. https://www.fwpa.com.au/images/resources/Carbon_Storage_in_Harvested_Wood_Products_2023.pdf

[10] Arrigoni, A. et al. (2023). Life cycle assessment of hempcrete: A carbon-negative building material. Journal of Cleaner Production. https://doi.org/10.1016/j.jclepro.2023.138247 (open-access summary: https://www.sciencedirect.com/science/article/pii/S095965262303619X )

[11] International Bamboo and Rattan Organisation (INBAR). (2024). Bamboo as a substitute for timber: Climate change mitigation potential. https://www.inbar.int/resources/inbar_publications/bamboo-as-a-substitute-for-timber/

[12] EcoCocon & Passivhaus Trust. (2024). Life-cycle carbon assessment of straw-based building systems. https://www.passivhaustrust.org.uk/UserFiles/File/Tech/EcoCocon_Straw_LCA_2024.pdf

[13] Mycelium Materials Europe & Nova-Institute. (2025). Life Cycle Assessment of Mycelium Composites 2025. https://nova-institute.eu/pub/lca-mycelium-composites-2025/

[14] Paul, K.I. et al. (2019). Carbon sequestration in Australian plantation forests. CSIRO / Dept of Agriculture. https://www.agriculture.gov.au/sites/default/files/documents/carbon-sequestration-australian-plantation-forests.pdf

[15] Scion (2023). Carbon sequestration rates for Pinus radiata in Australia and New Zealand. https://www.scionresearch.com/__data/assets/pdf_file/0008/86472/Carbon-sequestration-rates-for-Pinus-radiata.pdf

Unseen and Unaccounted For: Closing the Refrigerant Gap in Decarbonisation / Net Zero Strategies

Sat, 09 Aug 2025 09:29:48 GMT

Unseen and Unaccounted For: Closing the Refrigerant Gap in Decarbonisation / Net Zero Strategies

By Jeremy Mansfield OAM Mansfield Advisory Pty Ltd

Our ongoing work uncovering blind spots in refrigerant reporting [12] reveals a pressing challenge: net-zero plans in Australia, both at government and corporate levels, often miss the full impact of refrigerants released into the atmosphere or destroyed. These plans frequently highlight innovative solutions while overlooking the hidden challenges of heating and cooling—containing potent greenhouse gases, often in old, poorly monitored systems that leak, and end-of-life mismanagement. Ignoring their full lifecycle risks higher costs, stranded assets, misguided strategies, risks of overstated claims, and weakened climate credibility

Yet, according to Project Drawdown [1], refrigerant management remains among the top five climate solutions. Many leading frameworks are lacking in addressing this critical area. Despite significant emissions, a growing refrigerant bank [6], and emerging PFAS risks [13]. Even with global phase-down under the Kigali amendment holistic planning integrating refrigerants is key to achieving our 2035 milestones and 2050 net-zero goal. How are government and corporate strategies addressing this gap?

The Refrigerant Challenge: A Growing Threat

Many countries and regions are implementing HFC phasedowns as part of their decarbonisation plans to meet climate goals, reducing HFC use in refrigeration, air conditioning while shifting to refrigerants less harmful to the climate. The Kigali Amendment targets new HFC production and consumption, but leaks, legacy systems, and end-of-life emissions are not part of the amendment’s remit, a gap noted in our prior article [12]. Leaks during use or decommissioning warm the planet; contributing to (Scope 1) emissions as part of the broader 2-3% of global emissions from refrigerant leaks [8]. Rising cooling demand (3-5% annually due to climate change) [10] and heat pump adoption increase pressure. This global effort highlights the need for action, and in Australia, the challenge is significant.

Australia’s refrigerant bank contained an estimated 55,000 metric tonnes in 2022 and is projected to grow to over 80,000 metric tonnes by 2035 (per Cold Hard Facts 4) [6]. The contained CO2e however is expected to decline 20%, from approximately 100 million tonnes in 2022, to 79 million tonnes in 2036. This is due to the HFC phase-down and the increased use of lower-GWP refrigerants in the mix. Even so there is still a significant challenge to the nation’s net-zero goals with the need to manage this bank during operational use, and end-of-life handling. Many refrigerants have global warming potentials thousands of times higher than CO2—HFC-134a, for example has a global warming potential of 1,530 (based on AR6, while AR4, used for current NGERS Act reporting, a GWP of 1,430) [7]. Production, transport, maintenance, and disposal of refrigerants generate (Scope 3) emissions. Venting during decommissioning can also release these potent gases. Are your government or corporate plans prepared for this evolving impact?”

PFAS Risks: An Emerging Liability

Some refrigerants are classified as PFAS directly, while others break down into PFAS—known as ‘forever chemicals.’ These don’t easily go away (meaning ‘persistent’) and are under close watch globally [13]. Their long-lasting nature, along with the fast increase of a harmful substance called trifluoroacetic acid (TFA),a degradation product of many low-GWP refrigerants, threatens water supplies and human health. The Environmental Investigation Agency’s (EIA) July 2025 Persistent Problems report warns that low-GWP substitutes for HFCs, worsen this this problem, noting risks of exceeding toxic thresholds [13]. Australia’s 2019 National PFAS Position Statement aims to reduce further releases ‘where practicable’ [14], but it omits refrigerants or their degradation products entirely. Globally, ways to handle PFAS differ a lot [15], and while strategies are emerging as a precautionary approach, the risk is not fully tackled yet—some, like the Environmental Effects Assessment Panel (EEAP), see it as minimal, while the EIA urges caution. How are your government or corporate strategies handling PFAS?

Generations of damaging F-gases. Source: EIA [13]

Gaps in Current Strategies

Despite Project Drawdown’s [1] finding that refrigerant management can avoid billions of tonnes of CO2 emissions, many decarbonisation plans are silent on this. This may stem from lack of awareness, perceived low impact, or intentional focus on other priorities with limited project aims. Reports on electrification and renewables frequently omit refrigerants [2-5], missing the impact of leaks and PFAS risks [13]. Showing these gaps (by acknowledging refrigerant Scope 1 and Scope 3 emissions, enhances planning by setting priority areas for dealing with refrigerants [12], including longer-term challenges. Current strategies, including Australia’s HFC phase-down, focus on production and consumption, not addressing legacy systems, leaks, end-of-life management, or PFAS risks, leaving 2050 goals at risk. Are your government or corporate plans fully accounting for refrigerants?

What Needs to Be Acknowledged and Addressed

To achieve holistic planning and prevent greenwashing, decarbonisation strategies must prioritise refrigerants’ full lifecycle impact:

Recognise Refrigerants’ Full Impact : Acknowledge (Scope 1) emissions (leaks and refrigerant release) and (Scope 3) emissions (production, transport, and end-of-life disposal), through accurate emissions reporting.
Building on the National PFAS Management Plan : Reduce reliance on refrigerants that are or degrade into PFAS, using natural alternatives to mitigate liabilities [11, 13, 14].
Enhance End-of-Life Management : Establish guidance on refrigerant destruction and recovery programs to minimise emissions (Scope 1 if onsite, otherwise Scope 3 if offsite) from venting to atmosphere upon decommissioning equipment, addressing a current oversight.
Integrate into Net Zero Sectoral Frameworks : Embed refrigerant management into: New Buildings : Prioritise low-global-warming-potential natural refrigerants in HVAC and heat pumps used for hot water. Existing Buildings: Regular maintenance and leack tracking registers Cold Chain : Improve leak management and transition to sustainable refrigerants through monitoring and upgrades. Transport : Include refrigerated logistics refrigerant leakage in decarbonisation plans, i.e. beyond the electrification-only focus.
Transparent Scope Disclaimers : Net Zero / Decarbonisation / Sustainability Reports should acknowledge the use of refrigerants, even if the data around emissions isn’t available, to guide strategic planning and avoid misleading claims.
Highlight Business Opportunities : Focus on identifying potential stranded assets by utilising low-global-warming-potential solutions and prevent litigation with PFAS-risks in the future, supporting robust reporting.

A Call to Action

As we argued in Blind Spots on the Road to Net Zero [12], Australia’s lack of refrigerant reporting is a key gap. Equally critical is the common reporting omission to not acknowledge refrigerants in Net Zero plans and decarbonisation strategies. Failure to address refrigerants’ full impacts are broad: Scope 1 and Scope 3 emissions, a national refrigerant bank (79 Mt CO2e in 2036 [6]), end-of-life needs, and PFAS risks. Depending solely on phase-down legislation overlooks the need for comprehensive planning by 2035 to meet 2050 goals, also potentially leading to incomplete strategies. Strengthening net-zero strategies with transparent refrigerant disclosure and refrigerant integration is key to credible 2050 progress.

How are refrigerants’ lifecycle impacts addressed in your net-zero strategy? Are end-of-life emissions or PFAS risks on the radar? Share your insights and let’s tackle this together!

Follow Mansfield Advisory Pty Ltd for updates.

#Refrigerants #Decarbonisation #NetZero

Other articles in this refrigerant series you may have missed:

All Mansfield Advisory articles can also be found on our website

REFERENCES

Project Drawdown. The Drawdown Review. 2020.
EY. Why 2035 is the climate target that counts: Eight keys to achieve net zero. https://www.ey.com/en_au/insights/sustainability/2035-climate-target-cost-saving-action-for-business .
AECOM. Electrifying Road Freight Report. Australian Renewable Energy Agency (ARENA). https://arena.gov.au/assets/2025/07/AECOM-%E2%80%93-Electrifying-Road-Freight-Report.pdf .
Deloitte. Utility Decarbonization Strategies. Deloitte Insights, 2020.
KPMG. Closing the Gap: How Collaborations Can Accelerate Decarbonisation for Companies. 2023.
Cold Hard Facts 4. Australian Government Department of Climate Change, Energy, the Environment and Water, 2022.
IPCC. Fifth Assessment Report: Climate Change 2013. Annex II: Climate System Scenario Tables.
United Nations Environment Programme. Global Refrigerant Management Initiative. 2020.
International Energy Agency. The Future of Cooling. 2018.
Australian Government. Australia’s Emissions Projections 2023. Department of Climate Change, Energy, the Environment and Water.
European Chemicals Agency. PFAS Restriction Proposal. 2023.
Mansfield Advisory. Blind Spots on the Road to Net Zero: Australia’s Refrigerant Reporting Gaps. https://www.linkedin.com/pulse/blind-spots-road-net-zero-australias-refrigerant-reporting-hxs8c and also published by AIARH within Ecolibrium Magazine https://theecolibrium.com/2025/06/10/blind-spots-on-the-road-to-net-zero-australias-refrigerant-reporting-gaps/
Environmental Investigation Agency. Persistent Problems: The Hidden Impacts of Hydrofluoroolefins. 2025. https://eia-international.org/report/persistent-problems/
Australian Government: National per- and polyfluoroalkyl substances (PFAS) Position Statement (2019)
OECD. Synthesis Report on Understanding Perfluoropolyethers (PFPEs) and Their Life Cycle. 2024. https://one.oecd.org/document/ENV/CBC/MONO(2024)5/en/pdf
DCCEEW Net Zero Sector Framework https://www.dcceew.gov.au/climate-change/emissions-reduction/net-zero

First published on LinkedIn 6th August 2025

Bamboo: Unlocking Climate Solutions with Australia’s Sustainable Finance Taxonomy

looka_production_140421591 — Sat, 12 Jul 2025 07:08:29 GMT

Bamboo: Unlocking Climate Solutions with Australia’s Sustainable Finance Taxonomy

Call to Action (Executive Summary)

Bamboo offers a transformative opportunity for Australia’s climate, biodiversity, and economy. By 2035, 100,000–500,000 hectares of clumping bamboo could potentially drive AUD$500 million to $1.5 billion in initial investment, sequester 3–25 million tons of carbon dioxide annually, and avoid 2.4–24 million tons of construction emissions. Backed by global insights and local potential, this natural resource is poised for action. State and Federal Treasuries, the Australian Sustainable Finance Institute, Clean Energy Finance Corporation, banks, and investors are urged to understand these possibilities and integrate bamboo into Australia’s net-zero strategy.

Introduction

Our advocacy for bamboo as a climate and economic solution—highlighted in ( Bamboo: The Overlooked Game-Changer in Australia’s Sustainable Future! ) gained significant traction at the ICC-ES-sponsored Next Frontier Summit. Held across three cities, the summit brought together global experts, including Neil Thomas MBE (Atelier One), Dr. Trinh Huynh (University of the Sunshine Coast), David Sands (Rizome), Prof Xiao (ZJU-UIUC Institute, Zhejiang University), Jailene Santana (WWF Australia), Durnford Dart (Bamboo Australia), and BAMBuild (Brazil), to showcase bamboo’s potential.

The summit introduced a 10-Year Roadmap for Structural Engineered Bamboo (SEB), aiming to scale this fast-growing grass as an agricultural crop (ANZSIC 0159). Yet, policy gaps in the Australian Sustainable Finance Taxonomy (ASFT), released in June 2025, pose challenges. The Mansfield Advisory’s Bamboo Forestry Carbon Qualification (BFCQ) draft ACCU method is only at the Expression of Interest stage, and there are no clear signals to support bamboo plantation investments. This underscores the urgent need for ASFI, CEFC, banks, investors, State and Federal Treasuries to recognise and act on bamboo’s opportunities.

Image 1: House of Bamboo Showroom – courtesy, House of Bamboo

Image 2: Draft summary of the 10-year roadmap for Structural Engineered Bamboo (Bamboo Society of Australia)

Bamboo’s Alignment with the Australian Sustainable Finance Taxonomy

By 2035, 100,000–500,000 hectares of non-invasive clumping bamboo could produce 0.8–6 million tons of Structural Engineered Bamboo annually, harnessing its rapid growth of 0.01–0.03 meters per day (3.65–10.95 meters/year)—four to ten times more productive than traditional trees. This aligns with the ‘Agriculture and Land’ sector, where research quantifies carbon storage in aboveground biomass, belowground biomass (root-shoot ratio 0.85), litter, and soil organic carbon (up to 79 kg C/ha/yr). However, its eligibility for carbon credit Soil Carbon methods awaits approval from the Clean Energy Regulator, pending further consultation. Its ecosystem services—biodiversity support, erosion control, and water retention—meet the ‘Do No Significant Harm’ criteria. In the ‘Construction and Buildings’ sector, Structural Engineered Bamboo’s low embodied carbon (0.1–0.3 kg CO2e/kg) and steel-rivalling tensile strength position it as a substitute for cement and steel, each contributing 7% to global emissions. With the International Code Council Evaluation Service verifying Structural Engineered Bamboo compliance with International Organization for Standardization 22156/22157 standards and confirming adherence to National Construction Code performance criteria, alongside Environmental Product Declarations validating environmental impact values for NABERS Embodied Carbon and Green Star Building ratings, these credentials are poised to build confidence in Structural Engineered Bamboo.

International precedents underscore bamboo’s alignment with sustainable finance frameworks.

The EU Taxonomy includes bamboo under agroforestry for carbon sequestration and soil health, supporting climate mitigation EU Taxonomy, 2020. China’s Green Bond Catalogue explicitly lists bamboo plantations for ecological restoration and carbon credits, driving investment in a USD 199.2B green bond market by 2021 ( Green Finance Platform, 2022) . These examples strengthen the case for ASFT to recognise bamboo’s agricultural and construction potential, urging immediate policy integration to unlock investment.

“Bio-based materials may represent our best hope for radical decarbonisation through the responsible management of carbon cycles. The shift towards properly managed bio-based materials could lead to compounded emission savings in the sector of up to 40% by 2060 in many regions.” United Nations Environment Programme Building Materials and the Climate: Constructing a New Future

Policy and Technical Gaps

The Summit identified key barriers to bamboo’s integration: its agricultural classification excludes it from forestry frameworks, missing timber incentives despite Structural Engineered Bamboo’s equivalence to laminated veneer lumber; limited agricultural recognition restricts subsidies; carbon credit methodologies overlook bamboo’s 5–7 year cycles, though the Bamboo Forestry Carbon Qualification, currently at the Expression of Interest stage with the Department of Climate Change, Energy, the Environment and Water, aims to value aboveground biomass, belowground biomass, and products as a proposed method. Meanwhile, the applicability of the existing Soil Carbon method, managed by the Clean Energy Regulator, to bamboo is under review; its absence from technical screening criteria raises investor costs; static life cycle assessments undervalue sequestration, necessitating dynamic assessments; commercialisation faces challenges with limited plantations, the need for smart and productive harvesting techniques and standardisation gaps; First Nations engagement lacks tailored Free, Prior, and Informed Consent protocols despite agroforestry potential; bamboo’s grass status hinders National Construction Code adoption; and Australia’s non-signatory status with the International Network for Bamboo and Rattan limits access to global expertise and investor markets.

Utilising Bamboo as a Structural Engineered System

A Sydney panel, including Neil Savery, outlined strategies for Structural Engineered Bamboo adoption. The National Construction Code’s performance-based approach supports experimentation, with local pilot and demonstration projects (roadmap Phase 3) paving the way. Jennifer Snyders (President, Bamboo Society of Australia and CEO for House of Bamboo) emphasised bamboo’s 5–7 year harvest cycle as a regenerative partner to timber (Phase 4), offering a sustainable alternative.

Image 3: The stages of structural engineered bamboo (SEB) production – courtesy, House of Bamboo.

Investment Opportunities

The 10-Year Roadmap, currently in development, offers a framework where 100,000–500,000 hectares of bamboo plantations could potentially attract AUD 500 million–1.5 billion in initial investment by 2035, with annual operating costs estimated at $35,000–40,000/ha. Research suggests that such a scale could lead to 3–25 million tons CO2 stored annually, with bamboo avoiding 2.4–24 million tons of embodied carbon yearly, based on sequestration and substitution rates. These figures are proposed as part of the roadmap’s consideration to maximise bamboo’s climate and economic impact. Benefits include:

Carbon Markets: The applicability of the existing Soil Carbon method to bamboo, managed by the Clean Energy Regulator, and the proposed Bamboo Forestry Carbon Qualification, currently at the Expression of Interest stage with the Department of Climate Change, Energy, the Environment and Water, could unlock the potential 3–25 million tons of carbon dioxide per year sequestered value, pending future consultation, approval and development.
Construction Sector: Structural Engineered Bamboo’s strength and modern construction methods might address housing needs, potentially avoiding 2.4–24 million tons of carbon dioxide per year through low-carbon solutions.
Agricultural Innovation: Bamboo’s rapid growth (0.01–0.03m/day) could support 0.8–6 million tons per year, appealing to Clean Energy Finance Corporation investors
Biodiversity and Social Impact: Indigenous partnerships and ecosystem services could enhance environmental, social, and governance appeal across 100,000–500,000 hectares. (Based on a range of Financing, Carbon, and Yield Assumptions for Structural Engineered Bamboo by 2035)

Alignment with Future Made in Australia

Bamboo’s potential aligns with the Australian Government’s Future Made in Australia initiative, launched in the 2024–25 Budget with a $22.7 billion, decade-long investment to strengthen domestic manufacturing and net-zero industries. This framework, guided by the National Interest Framework, targets sectors like renewable hydrogen and critical minerals but offers a platform for bamboo’s 100,000–500,000 hectares and proposed AUD 500 million–1.5 billion investment. Its focus on the Net Zero Transformation Stream and Economic Resilience supports bamboo’s potential role in sequestering 3–25 million tons CO2/year and avoiding 2.4–24 million tons in construction, leveraging public-private partnerships through the Clean Energy Finance Corporation and the Future Made in Australia Innovation Fund. However, the recent $300 million Timber Fibre Strategy (July 07, 2025) focuses solely on timber, highlighting a gap where 100,000–500,000 hectares of bamboo could complement this effort. Action by World Bamboo Day, September 18, 2025 (69 days from now), can cement bamboo’s role, building on its insurance viability.

Strategic Alignment with the Forest Products Industry

Bamboo enhances Australia’s forest products industry through six strategic pillars. First, it expands sovereign manufacturing by integrating Structural Engineered Bamboo with timber fibre across 100,000–500,000 hectares by 2035. Second, its rapid growth (0.01–0.03m/day) meets domestic demand, complementing managed forests. Third, managing bamboo plantations could boost forest health, potentially sequestering 3–25 million tons of carbon dioxide per year while supporting biodiversity. Fourth, industry enablers—International Code Council Evaluation Service standards, the proposed 500 million to 1.5 billion Australian dollars in investment, and infrastructure—could drive Structural Engineered Bamboo adoption. Fifth, bamboo cultivation supports regional communities, including First Nations with Free, Prior, and Informed Consent protocols. Sixth, innovating the value chain with dynamic life cycle assessments and carbon credits (e.g., Bamboo Forestry Carbon Qualification) could position Australia as a biobased leader. Yet, the Timber Fibre Strategy’s timber-only focus underscores the need to advocate for bamboo’s inclusion.

Roadmap to Action

The draft 10-year roadmap, developed for the Next Frontier Summit, seeks feedback to finalise it by September 18, 2025, for World Bamboo Day launch. Key actions are outlined below to advance Structural Engineered Bamboo integration, include:

Policy and Investment:

Engage the Australian Sustainable Finance Institute to recognise bamboo-specific Technical Screening Criteria within the Australian Sustainable Finance Taxonomy.
Support the Bamboo Forestry Carbon Qualification Expression of Interest and inclusion in Soil Carbon methods.
Fund research and development to address data gaps, including carbon quantification and other related areas.
Australia to commit to joining the International Network for Bamboo and Rattan by 2026 for global expertise.
Integrate bamboo into the 2035 Nationally Determined Contribution and Clean Energy Finance Corporation funding, beyond the current timber focus.
Develop Free, Prior, and Informed Consent protocols with Reconciliation Australia for First Nations engagement.
Seek bamboo’s inclusion in the 300 million Australian dollar Timber Fibre Strategy (July 07, 2025) or identify separate funding to complement timber efforts.

Performance, Standards, and Codes:

Leverage the International Code Council Evaluation Service’s International Organisation for Standardisation 22156/22157 assessments and local case studies to establish National Construction Code pathways.
Collaborate with Standards Australia to define Structural Engineered Bamboo standards using modern construction methods and pilot projects.
Fund research and development and Technical and Further Education training programs to ensure scalability and workforce readiness.

Image 4: Summary outline of key elements within the 10-year draft roadmap for SEB (Bamboo Society of Australia)

UNEP FIT Post-Summit Insights

Released this month (July 2025), the United Nations Environment Programme’s Forum for Insurance Transition to Net Zero report, Underwriting the Transition, offers a framework for aligning insurance portfolios with net-zero goals. Led by the United Nations Environment Programme, with support from global insurers (e.g., Aviva, Beazley), academics (e.g., University of Technology Sydney’s Gordon Noble), and Australian regulator APRA’s Sean Carmody, the report estimates Structural Engineered Bamboo’s potential climate impact at 3–25 million tons of carbon dioxide sequestered and 2.4–24 million tons avoided annually by 2035. It draws on the Science-Based Targets Initiative Financial Institutions Net-Zero Standard (2024), Glasgow Financial Alliance for Net Zero guidance (2022), and Transition Plan Taskforce metrics (2024). Structural Engineered Bamboo’s drought resilience, moisture resistance, and 40% denser structure (with slower carbonisation than wood) enhance its insurance appeal, though durability tests are pending. This positions bamboo for underwriting risks and carbon credits, with the roadmap’s research and development focus key to realisation.

Australian Sustainable Finance Taxonomy Alignment Note

The Australian Sustainable Finance Taxonomy, launched alongside the Next Frontier Summit for Bamboo, provides a foundation for green and transition finance to support net-zero goals. As part of the Government’s broader Sustainable Finance Roadmap, this framework is poised for enhancement. However, the draft 10-year roadmap for Structural Engineered Bamboo, still in its early stages, has yet to fully inform the taxonomy with bamboo’s potential, pending ongoing consultations. Still, bamboo aligns with the “Agriculture and Land” sector via its growth and carbon storage (aboveground biomass, belowground biomass, soil organic carbon up to 79 kg C/ha/yr) and the “Construction and Buildings” sector via Structural Engineered Bamboo’s low embodied carbon (0.1–0.3 kg CO2e/kg) and high-emission material substitution. Its absence from technical screening criteria raises costs, while static life cycle assessments undervalue sequestration, necessitating dynamic assessments. Tailored First Nations Free, Prior, and Informed Consent protocols are also needed for agroforestry partnerships, per the Australian Sustainable Finance Taxonomy (June 2025).

With 69 days to World Bamboo Day, the time to act is now.

#Bamboo #SustainableFinance #ASFT #NetZero #CarbonMarkets #Biodiversity #EmbodiedCarbon #ClimateSolutions #SustainableConstruction

First published on LinkedIn 11th July 2025

Accelerating the Transition to Fossil Fuel-Free Construction

looka_production_140421591 — Thu, 29 May 2025 05:07:23 GMT

Accelerating the Transition to Fossil Fuel-Free Construction

Mansfield Advisory Pty Ltd

205 followers

May 27, 2025

By Jeremy Mansfield OAM , Mansfield Advisory Pty Ltd

Introduction

The construction industry accounts for 40% of global carbon emissions, with a significant portion stemming from onsite activities and embodied carbon in materials [1]. In Australia, where infrastructure and buildings are key economic drivers, the sector’s emissions—particularly from construction processes (A5 emissions)—present both a challenge and an opportunity. Fossil fuel-free construction, which eliminates fossil fuels from onsite energy, machinery, transportation, and materials, is a critical step toward net zero by 2050.

At Mansfield Advisory, we are committed to driving this transformation. Drawing on insights from ASBEC’s Our Upfront Opportunity report [1], Infrastructure Australia’s Embodied Carbon Projections for Australian Infrastructure and Buildings [2], the NABERS Embodied Carbon framework [3], and the C40 Clean Construction Accelerator, this article outlines the path to fossil fuel-free construction. It’s a call to action for government and industry to collaborate on policies and practices that will reshape how we build.

What is Fossil Fuel-Free Construction?

Fossil fuel-free construction eliminates fossil fuels across onsite activities (A5 emissions under EN15978), focusing on four key areas:

Energy Sources : Powering construction sites with onsite or offsite renewable energy like solar, wind, or hydropower.
Machinery : Using renewable electricity, low-carbon liquid fuels or renewable hydrogen to power machinery and equipment, instead of diesel, LPG or gasoline.
Transportation : Deploying electric or low-carbon liquid fuel vehicles for moving materials and workers.
Materials : Prioritising low-carbon options that minimise fossil fuel use in production.

Figure 2 diagram from ASBEC’s Our Upfront Opportunity report illustrating the EN15978 lifecycle stages, with A5 (construction process) highlighted.

Infrastructure Australia’s Embodied Carbon Projections for Australian Infrastructure and Buildings and ASBEC have highlighted that Construction Emissions (A5) represent 20% of upfront carbon emissions from infrastructure and buildings. While it is essential to address the significant carbon emissions resulting from materials manufacture (A1-A3), which constitute 75% of upfront emissions, it is equally essential to consider construction-related emissions to achieve Australia’s net-zero targets by 2050 [1].

Table 6: Upfront carbon projections for lifecycle modules A1—A3, A4 and A5, 2023, Embodied Carbon Projections for Australian Infrastructure and Buildings 2024

Why It Matters

The stakes are high. Infrastructure Australia’s report warns that embodied carbon from construction could account for up to 85% of a project’s total emissions by 2050 if left unchecked [2]. Fossil fuel-free construction offers compelling benefits:

Climate Impact : Cutting onsite emissions directly reduces a project’s carbon footprint.
Public Health : Eliminating fossil fuel use improves air quality and reduces noise pollution.
: Shifting to renewables enhances energy security and fosters innovation. Transition to electric and battery electric vehicles saves significant equipment fuel costs.

The NABERS Embodied Carbon tool supports this transition by providing a standardised way to measure and manage A5 emissions, ensuring accountability across projects [3]. It includes the energy use during the entire construction up to Practical Completion. Complete records of energy consumption must be obtained for all the following energy sources, if they were used on-site during the construction period: Diesel; BioDiesel, Renewable Diesel, Petrol, Electricity (grid), Off-site renewable electricity (i.e., GreenPower or other grid-sourced renewables), Natural gas, and LPG.

Barriers to Overcome

Despite its potential, fossil fuel-free construction faces hurdles:

Cost and Technology : Electric machinery and renewable energy systems often require higher upfront investment.
Cost of using imported fuels: No domestic refining for renewable diesel fully commercialised yet.
Infrastructure Gaps : Many project sites lack access to renewable energy or charging stations.
Supply Chain Complexity : Achieving fossil fuel-free outcomes requires coordination across all project phases.
Limited Awareness of Electrification Options: Many construction stakeholders, including contractors and developers, lack awareness of available electrification technologies, such as battery-powered excavators, electric concrete pumps, and zero-emission transport vehicles, hindering their adoption and slowing the transition to fossil fuel-free construction.
Insufficient Market Signals and Policy Support: The absence of clear and consistent market signals, such as firm commitments to decarbonisation targets, leaves suppliers uncertain about investing in low-carbon solutions like renewable fuels at large volumes and the electric equipment transition. Compounding this, current regulations rarely mandate or reward sustainable construction practices. No Australian city has committed to the C40 Clean Construction Accelerator—a global pledge by cities like Oslo, London, and Los Angeles to reduce fossil fuel emissions from construction sites through collaborative procurement and policy alignment, further slowing the transition.

These challenges are real, but they are not insurmountable with the right support.

Solutions and Policy Recommendations

To scale fossil fuel-free construction, Australia must act decisively, aligning with ASBEC's goal of fossil fuel-free construction by 2031 and a 60-75% reduction in upfront embodied carbon (A1-A5) by 2035, as outlined in the Our Upfront Opportunity report [1]. The C40 Clean Construction Accelerator provides a complementary global framework, with goals to reduce embodied emissions by 50% for new buildings, retrofits, and infrastructure by 2030, and require zero-emission construction sites by 2030 where technology is available. Here’s how Australia can accelerate the transition to fossil fuel-free construction while contributing to broader decarbonisation goals:

Adopt Fossil Fuel Free Construction Hierarchy : (1) Use of electric construction machinery and equipment where options are available; and (2) Renewable diesel to substitute mineral diesel where electric options are not available (Lendlease hierarchy in their Stepping Up The Pace: Fossil Fuel Free Construction Report - 2022).
Measure and Report Emissions: Mandate A5 emissions tracking using tools like NABERS Embodied Carbon to create transparency [3], supporting significant embodied carbon reductions.
Fund the Transition: Offer grants, tax incentives, or subsidies to offset the cost of electric equipment and renewable energy and liquid fuel adoption, accelerating progress toward broader decarbonisation goals.
Update Procurement: Embed fossil fuel-free requirements into public and private project tenders. State and Federal Governments, by utilising GBCA’s Green Star Buildings Fossil Fuel Free Construction Leadership Challenge, can incentivise and signal market transition.
A Coordinated National Effort: ASBEC’s Our Upfront Opportunity report calls for the NCC to set clear, mandatory targets for upfront embodied carbon [1]. By embedding fossil fuel-free requirements within the scope of upfront embodied carbon provisions (aligned with NABERS Embodied Carbon A1-A5 boundary) into the NCC, Australia can drive industry-wide adoption of low-carbon materials and practices, aiming for fossil fuel-free construction by 2031.
Build Infrastructure: Develop renewable energy microgrids and charging networks at construction hubs to enable fossil fuel-free practices.
Train the Workforce: Equip workers with skills to operate new technologies through targeted programs, focusing on Fossil Fuel Free Construction, Retrofits, Low-Carbon Materials, and Zero-Emission Machinery, to support the transition.
Pilot and Innovate: Support demonstration projects to prove the viability of fossil fuel-free construction methods and share results, accelerating adoption.

Leading by Example

Progress is underway both locally and globally, showing what’s possible with commitment and innovation.

Australian Innovators

Lendlease, a pioneer in sustainable building, has trialled electric machinery, such as the Schwing SP 3800 E electric concrete pump supplied by Azzurri Concrete at the One Sydney Harbour project, achieving zero emissions and 59.1% lower operational energy costs [4]. They have also adopted renewable diesel, reducing emissions by up to 90% compared to traditional diesel [1]. The NSW Government’s focus on embodied carbon in infrastructure projects sets a strong example [5]. These efforts show that the tools exist—now we must scale them to drive fossil fuel-free construction and support broader decarbonisation goals.

A comparison of electric concrete pumping vs Diesel concrete pump. Source: Lendlease / Azzurri Concrete

A combined image of HVO (renewable diesel) being used at Lendlease’s New Performing Arts Venue project (Brisbane) with the Nestlé graph showing the percentage emissions reduction (up to 90% compared to diesel).

Suppliers Driving Change

Volvo Group is playing a pivotal role in decarbonising transport and construction equipment, supporting the industry’s transition to fossil fuel-free practices. From December 2024, all Volvo and Mack trucks built at Volvo Group Australia’s Wacol QLD factory have been filled with Hydro Treated Vegetable Oil (HVO) instead of diesel—a renewable fuel that reduces emissions by up to 90% when sourced sustainably. Volvo aims to make its trucks and construction equipment fossil fuel-free by 2040, a timeline that lags behind ASBEC's goal of fossil fuel-free construction by 2031, underscoring the need for accelerated action.

Volvo Trucks and Volvo Construction Equipment (CE) are heavily investing in electrification, with electric trucks enabling low-emission material transport for construction projects. Volvo CE’s range of electric equipment, tailored for construction and landscaping, includes the 23-ton EC230 Electric mid-size excavator, L120 Electric and L90 Electric wheel loaders, the EWR150 Electric (Volvo’s first battery-powered wheeled excavator), and the grid-connected EW240 Electric Material Handler, which may face challenges in remote sites without renewable energy access.

EC230 Electric mid-size excavator. Source: Volvo Group

Other suppliers in the transport industry are also transitioning to electric solutions. Fuso, part of the Daimler Truck Group worldwide, has a rich history in Australia dating back to the 1970s. In 2021, they introduced the eCanter—the first production electric truck in Australia—gaining traction with leading transport operators like Australia Post. International suppliers like JAC are also entering the market with their electric truck offerings, expanding options for zero-emission transport. Electric trucks offer lower maintenance requirements compared to diesel counterparts, with fewer moving parts and no need for oil changes or exhaust system repairs. Additionally, electricity as a fuel source is generally cheaper than diesel, reducing operational costs over time. With a payback period of 3 to 4 years, the economic case for electrification is compelling. However, only a handful of electric truck models are currently available in Australia, reflecting the market’s slower uptake compared to Europe, Asia, and the U.S. A stronger focus on supplying the decarbonization needs of Australia’s built environment and infrastructure sectors could accelerate interest from suppliers, supporting the Fossil Fuel Free Construction agenda.

Fuso eCanter, Australia’s first production electric truck, arrived in 2021. Source:

Government leadership

The NSW Decarbonising Infrastructure Delivery Policy has set mandatory requirements for agencies to apply the Carbon Reduction Hierarchy when identifying potential opportunities to reduce carbon. The Carbon Reduction Hierarchy has been adopted from PAS 2080: 2023 – Carbon Management in infrastructure.

The NSW Decarbonising Infrastructure fact sheet ( How to reduce carbon on your project?) provides good examples of the signals the industry needs to switch to low-carbon options, materials, and technologies whilst adopting solutions that improve resource efficiency and circular economy outcomes. Acknowledging the need to switch to low-carbon fuels and energy systems, along with adopting low-carbon construction methods.

It is critically important when engaging with the market that the right signals are embedded in business cases. Articulating fossil fuel-free construction targets (for A5 carbon emissions) is absolutely critical. Product suppliers rely on clear forward projection of the demands for their low-carbon options, materials and technologies. For example, without securing a large supply order for the use of renewable fuels, how does the supply industry invest the capital with the confidence that there's adequate demand for their low-carbon solutions? It's not a question of asking the industry what their ability to supply is; it's a matter of setting targets that the industry can signal to the suppliers the need for capacity to meet those targets.

Global Leaders in Fossil Fuel-Free Construction

Globally, cities are setting the standard for fossil fuel-free construction through the C40 Clean Construction Accelerator, which includes signatories like Budapest, Los Angeles, London, New York City, Mexico City, Milan, Oslo, and San Francisco:

Oslo, Norway: Oslo is targeting a 95% emissions reduction by 2030, mandating zero-emission heating and drying equipment for projects worth 5 million euros or more, with bonuses for contractors using additional zero-emission machinery. Its procurement strategy prioritises environmental criteria (30% weighting, 50% for zero-emission Non-Road Mobile Machinery), driving market change that aligns with global efforts to decarbonise construction.
London, United Kingdom: London is committed to reducing embodied emissions, requiring life-cycle assessments (LCAs) in planning permissions and promoting zero-emission machinery in municipal projects, aligning with C40 goals that support broader decarbonization efforts.
Los Angeles, USA: Los Angeles is leveraging its municipal procurement power to demand zero-emission construction sites, focusing on circular design and low-carbon materials, offering strategies Australia can adopt to advance fossil fuel-free practices and reduce embodied carbon.
Milan, Italy: Milan is prioritising retrofits of existing buildings and advocating for low-carbon materials, supporting the C40 goal of a 50% reduction in embodied emissions by 2030, which provides a benchmark for Australia’s decarbonisation efforts.
Supplier Spotlight: Tom Wilhelmsen AS (Norway): Norwegian supplier Tom Wilhelmsen AS exemplifies how suppliers can advance fossil fuel-free construction by adopting electric trucks for sustainable material transport. The company operates a fleet of 19 trucks, including 10 small intercity long-distance Volvo FE Electric tipper trucks without trailers, each capable of carrying 13.5 tonnes, used for construction operations. Since 2020, Tom Wilhelmsen AS has expanded its electric fleet in response to growing demand for sustainably sourced materials, aligning with Oslo’s zero-emission goals. This demonstrates how clear market signals can drive supplier investment in low-carbon solutions, offering a model for Australian suppliers to support the transition to fossil fuel-free construction.

These global examples of city-led policies and supplier leadership demonstrate practical steps toward fossil fuel-free construction, providing a blueprint for Australia to accelerate its pursuit of fossil fuel-free construction by 2031.

Oslo has a zero-emission construction mandate. Source: City of Oslo.

The Power of Consistent Data: Reporting Emissions Accurately

Accurate emissions reporting is critical to driving progress. The NABERS Embodied Carbon framework aligns with operational control boundaries, ensuring that construction companies report emissions from activities they directly manage. This alignment, as per the National Greenhouse and Energy Reporting (NGER) scheme, places accountability on those best positioned to reduce onsite emissions (A5 emissions) [3].

However, a significant gap exists in quantifying diesel consumption in construction, with estimates ranging from 1–4 billion litres annually due to inconsistent reporting [6]. This uncertainty hinders our ability to fully understand A5 emissions and prioritise fossil fuel-free solutions. To tackle reporting challenges, construction companies must advocate for:

Policymakers and industry bodies to mandate that clients, who often control utility payments, share consumption data with contractors. The industry should also ensure supply chains adopt consistent reporting on onsite fuel and energy use to track A5 emissions and promote low-carbon solutions, such as electric trucks.
Standardised reporting templates to streamline reporting and reduce complexity. We cannot afford hundreds of different templates—consistency is key.

Discrepancies also arise when financial control boundaries are used, as permitted under standards like the Australian Sustainability Reporting Standards (ASRS) and the GHG Protocol. These boundaries can create gaps, underrepresenting A5 emissions and obscuring the actual emissions intensity of construction projects. By aligning reporting frameworks, closing the diesel consumption data gap, and fostering collaboration, we can ensure clarity and accountability, supporting the transition to fossil fuel-free construction.

An extract from Climate Active Carbon Neutral Construction Service Public Disclosure Statement outlining the emissions boundary, which is aligned with A5 emissions and NGER operational control boundaries. In contrast, a Financial Control boundary only includes items where the Contractor pays for the consumption. Source: Lendlease Construction (Aust) Holdings Pty Limited – Climate Active PDS (2024).

Conclusion

Fossil fuel-free construction is both an urgent necessity and a transformative opportunity. By aligning with ASBEC’s vision to decarbonise the built environment, drawing on data from Infrastructure Australia and NABERS, and learning from global leaders like Oslo, London, and Los Angeles, Australia can lead the way in sustainable construction. Mansfield Advisory is proud to drive this effort, providing expertise to make fossil fuel-free construction the standard.

Call to Action :

Policymakers : Introduce incentives and mandates to support fossil fuel-free projects, and encourage Australian cities to join the C40 Clean Construction Accelerator to accelerate the transition.
Industry : Commit to pilot projects, push for improved reporting standards, and adopt global best practices to advance the Fossil Fuel Free Construction agenda.
You : Reach out to Mansfield Advisory to explore how we can collaborate on building a more sustainable future together.

The emissions we lock in today will shape tomorrow. Let’s take action now to achieve a fully fossil fuel-free construction sector.

References

ASBEC. Our Upfront Opportunity: Australia’s Policy Roadmap to Reduce Upfront Embodied Carbon in the Built Environment. March 2025.
Infrastructure Australia. Embodied Carbon Projections for Australian Infrastructure and Buildings. 2024.
NABERS. Embodied Carbon Measurement Methodology and Tool. 2021.
Lendlease. The Electric Edge of Concrete Pumping at One Sydney Harbour. February 2024. https://www.lendlease.com/insights/the-electric-edge-of-concrete-pumping-at-one-sydney-harbour/ .
NSW Government. Embodied Carbon in Infrastructure. 2024.
Industry Discussions. Uncertainty in Diesel Consumption Estimates for Australian Construction. 2025.

First published on LinkedIn 27th May 2025

Could Australia Become A Dumping Ground for Refrigerants?

Wed, 30 Apr 2025 03:41:26 GMT

Could Australia Become A Dumping Ground for Refrigerants?

Mansfield Advisory Pty Ltd

First published on LinkedIn - October 17, 2024

In Australia, cooling is a year-round necessity, attributed to both the harsh summer temperatures and the continuous operation of commercial refrigeration. This sustained demand has put the refrigerant industry in the spotlight, where it must balance environmental considerations and regulatory requirements. The challenges with refrigerants are not limited to the warmer months but are indicative of Australia's extensive reliance on cooling across various sectors. Further complicating this issue are the global shifts towards reducing greenhouse gas emissions, compelling the industry to adopt more sustainable practices while still fulfilling the need for efficient cooling. This situation is exacerbated by the global phase-out of high Global Warming Potential (GWP) refrigerants, which could make countries with less stringent regulations vulnerable to becoming dumping grounds for less desirable refrigerants.

Environmental and Health Consequences

"The Hot Reality: The Urgent Need for Sustainable Cooling" report by the Centre For Sustainable Cooling indicates a potential 90% increase in global cooling-related electricity consumption by 2050, underscoring cooling's significant role in energy demand and climate change. Cooling processes alone contribute to 7% of global greenhouse gas emissions, with projections suggesting these could double by 2030 or even triple by 2100. ColdHardFacts4 identified that refrigeration and air conditioning equipment contribute about 12% of Australia's total GHG emissions. According to Cold Hard Facts 4, direct emissions represent 11% of total emissions from RAC equipment, end-of-life is about 8%, and indirect emissions represent 81%. Hydrofluorocarbons (HFCs), widely used in cooling systems, have high Global Warming Potential (GWP) and are the fastest-growing source of greenhouse gas emissions globally due to the rising demand for space cooling and refrigeration.

Parallel concerns exist with per- and poly-fluoroalkyl substances (PFAS), known for their persistence in the environment and potential health risks, earning the nickname "forever chemicals." These substances further complicate the environmental footprint of cooling technologies. Once released, they do not break down easily and can accumulate in the environment and living organisms, leading to widespread contamination.

From a health perspective, exposure to PFAS has been linked to numerous adverse effects. According to research findings, these include liver damage, thyroid disease, decreased fertility, high cholesterol, obesity, and even cancer. These chemicals can enter the human body through contaminated water, food, or air, and once inside, they can affect various bodily systems. The concern about PFAS is not just about their direct impact but also their ability to bioaccumulate, meaning levels can build up over time in the body and the environment, leading to increased health risks from prolonged exposure.

Refrigerants and Scope 1 Emissions

Scope 1 emissions are direct greenhouse gas emissions from sources owned or controlled by a company. In the context of refrigerants, these are primarily fugitive emissions: leaks from refrigeration and air conditioning systems during operation, maintenance, or at the end of life. Despite their direct impact, these emissions are often overlooked in the broader discussion of greenhouse gases but are pivotal in Australia's fight against climate change.

Mandatory Emissions Reporting: Australia's New Framework

Australia's introduction of mandatory disclosure from 1st January 2025 for Scope 1, 2, and 3 emissions places refrigerant management under a microscope:

- Scope 1: Companies must now meticulously track and report refrigerant leaks, pushing for better containment and the use of refrigerants with lower Global Warming Potential (GWP).

- Scope 2 & 3: While Scope 2 involves indirect emissions from purchased energy, Scope 3 includes all other indirect emissions in a company's value chain, which could involve emissions from refrigerant production, disposal, and products sold to consumers.

The Global Battle Against Illicit Refrigerant Trade

Setting the Scene:

The global community has increasingly recognized the environmental threat posed by hydrofluorocarbons (HFCs), leading to significant international agreements and national policies to curb their use. The Kigali Amendment to the Montreal Protocol is a pivotal moment where nations committed to phasing down HFCs to mitigate climate change. This amendment has spurred countries into action, each implementing various measures to meet their reduction targets:

- Europe has advanced its F-gas Regulation , aiming to reduce F-gas emissions through quotas, bans on certain products, and stricter leakage checks.

- In the United States , the American Innovation and Manufacturing (AIM) Act directs the Environmental Protection Agency (EPA) to address HFCs by phasing down their production and consumption, promoting alternatives, and managing existing stocks.

- Australia has its own HFC phase-down strategy, part of its broader commitment under the Kigali Amendment, which involves reducing the availability of HFCs through a quota system.

The introduction of caps on HFC quotas globally has unintentionally laid the groundwork for an illicit trade. As legal supplies dwindle and prices rise due to scarcity, the black market for these potent greenhouse gases thrives. Smugglers exploit the price differential and the slower phase-out schedules in some countries, turning regions with less stringent controls into potential dumping grounds for illegal HFCs.

This scenario not only undermines global efforts to combat climate change but also poses significant challenges for law enforcement and regulatory bodies worldwide, as they strive to enforce compliance with international environmental agreements while battling the economic allure of the black market in refrigerants.

Recent events and actions:

- United States : Enforcement has become more rigorous with the introduction of the American Innovation and Manufacturing Act (AIM Act), which has led to the first prosecution of illegal HFC importation in 2024. This case underlines the U.S.'s commitment to curb the black market for these substances, highlighting the lucrative nature of HFC smuggling, comparable in profitability to the historical smuggling of substances like CFCs. Update : In March 2025, a 57-year-old CEO from Georgia, USA, was charged with violating the American Innovation and Manufacturing (AIM) Act. He allegedly imported 500 cylinders of hydrofluorocarbons (HFCs) from Peru without proper authorization. This marks the second prosecution under the AIM Act in the U.S., signaling increased enforcement against illegal HFC imports as part of the phasedown efforts.

- European Union : Despite having stringent regulations, the EU faces challenges with illegal HFCs primarily entering through Bulgaria from Turkey and China. The EIA has pointed out ongoing issues, with Romania and Bulgaria as key entry points. Smugglers employ sophisticated methods like mislabelling and exploiting corruption to bypass enforcement.

- Enforcement Actions : Significant seizures have occurred, like in the Netherlands and Italy, where large quantities (40 tonnes in both instances) of illegal refrigerants were intercepted. These actions demonstrate the scale of the illegal trade and the efforts to combat it. Update : More recently, a thousand cylinders containing around 14 tonnes of illegal HFC were seized in Italy (March 2025),

- Adaptation of Criminal Networks : Criminals adapt quickly to enforcement measures by altering their strategies, such as changing labels or using disposable containers to make detection harder. Spain has become a hotspot for online sales of illegal HFCs, showcasing the adaptability and reach of these networks. Update : Romania, a key backdoor for illegal refrigerants in Europe, uncovered a cross-border smuggling network in February 2025. Operating along the Turkey-EU route for years, this syndicate even supplied customs with testing technology to detect their own imports.

- Global Crackdown : These activities are part of a broader global crackdown influenced by international agreements like the Montreal Protocol and its Kigali Amendment, which aim to phase down HFCs to mitigate climate change. The Kigali Amendment, which came into force on January 1, 2019, specifically targets the phase-down of HFCs, recognizing them as potent contributors to climate change. The amendment has seen ratification from 160 states as of July 1, 2024, plus the European Union, indicating strong, though not yet universal, international support for reducing HFC use. The involvement of various countries indicates a widespread recognition of the problem but also underscores the challenges in enforcement due to differing phase-out schedules and economic incentives for illegal trade.

- Challenges and Persistence : Despite efforts, illegal trade persists due to high profits and varying international regulations, which create loopholes exploited by organized crime. The EIA's April 2024 report suggests that while steps are being taken, the illegal trade in HFCs remains a dynamic and persistent issue, adapting to new regulations and enforcement tactics.

The Environmental Investigation Agency's dashboard serves as a tool for monitoring the illicit trade in refrigerants, providing a comprehensive overview of the extent and dynamics of this underground market.

EIA tracking dashboard

Total volumes of refrigerant gas seizures

Total number of incidents

Australia's Vulnerability to Refrigerant Market Challenges

Australia's involvement in this illicit market isn't just as a bystander but potentially as a victim of illegal trade. The Cold Hard Facts4 study underscores Australia's refrigerant market dynamics, predicting growth using controlled and natural refrigerants. The ColdHardFacts4 forecasts that HFC-32 will still account for 70% of sales in Australia by 2036. However, the global push towards lower GWP alternatives and the illegal trade dynamics could see Australia becoming a target for cheap, high-GWP refrigerant dumping. This not only undermines Australia's environmental commitments under international agreements like the Kigali Amendment but also poses economic challenges by undercutting legitimate businesses with illegally sourced, cheaper alternatives.

According to Cold Hard Facts4, the total bank of controlled refrigerants in 2022 was estimated at approximately 55,027 metric tonnes and is expected to expand by more than 13% to approximately 62,200 metric tonnes (81,300 metric tonnes, including HFOs and natural refrigerants) in the 14-year period of the projections from 2022 to 2036. The emergence of heat pumps substituting for gas appliances is the biggest driver of growth for HFCs in the bank over the next decade.

Refrigerant bank by type (ColdHardFacts4, DCCEEW 2024)

The federal government has amended (June 2024) the Ozone Protection and Synthetic Greenhouse Gas Management Regulations to ban the import and manufacture of small air conditioning systems using high-GWP refrigerants (i.e. R410A - GWP of 2088 and R134a - GWP of 1430, for systems with <2.6kg of refrigerant charge). The updates also introduce new penalties for offences under the regulations, albeit the imposed maximum penalty of 60 units is not much of a deterrent.

Economic and Environmental Ramifications

The influx of illegal refrigerants could distort the market, leading to unfair competition and potentially stalling the adoption of environmentally friendlier technologies. On the environmental front, introducing these substances could significantly hinder Australia's efforts to reduce its carbon footprint, given the high GWP of illegally traded HFCs.

Debating the Pace of Refrigerant Phase-Down

While there are legitimate concerns that a rapid phase-down of refrigerants could spur illicit trade, there's a counterargument to be considered. Prolonging the transition away from these substances might widen the opportunity for illegal activities. This is because an extended demand period for outdated technology could continue to fuel the black market for longer than necessary.

The Threat of Refrigerant Dumping

As a result of being behind the EU and the US with restrictions in product categories, the market opportunity means older products (such as R410A with a GWP of 2088 in large VRV systems) are likely to be dumped into Australia. It poses both an environmental risk and a market distortion issue. This phenomenon could lead to:

- Environmental Impact: Continued use of higher GWP refrigerants delays the transition to more environmentally friendly alternatives, extending the environmental footprint of these substances.

- Market Dynamics: The influx of older, less efficient technology can hinder the adoption of new, more efficient, and less harmful technologies, affecting market evolution towards sustainability.

Customs authorities intercepted over 40 tonnes of illegal HFC refrigerant at the port of Gioia Tauro, Italy (August 2024).

Uncontrolled refrigerant consumption

Although a ban has now been placed on small AC units containing high-GWP refrigerants such as R410A and R134a, the Government is yet to restrict the import of other classes of pre-charged equipment containing high-GWP refrigerant. This means that Australia is not properly controlling refrigerant consumption, which undermines the phase-down efforts by not addressing the full lifecycle of refrigerant-containing products.

Strategies for Regulation and Innovation

To prevent potential issues with the illicit refrigerant trade, Australia could consider strengthening its regulatory measures. This includes improving border surveillance, revising penalties to deter smuggling better, and addressing gaps in regulations that allow pre-charged equipment to bypass current quotas. Implementing a more rigorous tracking system for the refrigerant lifecycle, from production through disposal, could also help mitigate illegal trade activities.

International cooperation is vital; Australia should align its refrigerant phase-down schedules with global leaders like the EU to minimize opportunities for refrigerant dumping.

On the innovation front, promoting the adoption of natural refrigerants like propane (HC-290) through incentives and research could accelerate the shift from high-GWP alternatives, reducing the market for illicit refrigerants while addressing environmental concerns and safety considerations.

Capitalizing on the Transition to Sustainable Cooling

Australia is at a defining moment where its approach to refrigerant regulation could lead the way in global sustainability efforts. Businesses are now tasked with navigating the complexities of mandatory emissions disclosure while being acutely aware of the burgeoning issue of illegal refrigerant trade. Through vigilant monitoring of refrigerant use, adoption of appropriate lower GWP alternatives, and strengthening compliance mechanisms, Australian companies can both manage risks and seize opportunities within the emerging low-carbon economy.

Alignment with international best practices does more than ensure regulatory compliance; it elevates Australian businesses to the forefront of the worldwide movement towards responsible cooling solutions. This pivotal moment demands collaboration among government bodies, industries, and innovators to effectively tackle refrigerant smuggling, slash emissions, and spearhead technological advancements.

By adapting proactively to these changes, Australia will not only significantly lower its carbon footprint and address legacy issues but also enhance its standing in the global effort against climate change, promoting both economic fortitude and ecological stewardship.

First published on LinkedIn 17th October 2025

The Emerging Fourth Green Shade: Beyond Greenwashing

Wed, 30 Apr 2025 03:37:11 GMT

The Emerging Fourth Green Shade: Beyond Greenwashing

Mansfield Advisory Pty Ltd

The Three shades of green you don’t want to be tarnished article focused on greenwashing, greenhushing and greenwishing . The emerging fourth shade on the block is greengushing .

This article introduces "greengushing," the latest in a series of environmental marketing trends, where enthusiasm for sustainability leads to exaggerated claims. We explore how this phenomenon differs from greenwashing, its implications, and how businesses can navigate these waters to maintain credibility and compliance.

Understanding Greengushing

Greengushing is when companies, driven by genuine enthusiasm for environmental issues, overstate their commitment or achievements. Unlike greenwashing, which might involve deliberate deceit, greengushing often stems from optimism or a lack of understanding about what can be realistically achieved. This can set unrealistic expectations among stakeholders.

Why Greengushing Matters?

Credibility : Overstatements can be just as damaging to trust as outright deception.
Legal and Regulatory Risks : Increased scrutiny from regulatory bodies like the ACCC can lead to legal consequences for making misleading environmental claims.
Consumer Trust : Consumers increasingly value authenticity, making overpromising a risky strategy that could backfire and damage brand loyalty.

Navigating the Green Spectrum

Transparency : Companies should fully disclose their sustainability journey, including both successes and challenges..
Set Realistic Goals : Ambition must be grounded in achievable targets with clear metrics.
Evidence Over Enthusiasm : Every claim should be supported by data or demonstrable results.
Engage and Educate : Marketing should inform and educate about sustainability efforts, demonstrating true commitment rather than just selling products.

Risk of Regulatory Scrutiny

While the ACCC's guidelines primarily address greenwashing, these principles can also be applied to grasp the risks of greengushing:

Misleading Claims: Even if not intended to deceive, exaggerated claims can still mislead consumers or stakeholders, thus inviting regulatory scrutiny.
Legal Implications: Company leaders could face personal legal consequences for misleading environmental claims.
Intent vs. Outcome: Whether greengushing is intentional or results from negligence, the outcome of misleading stakeholders is likely to attract similar regulatory attention as deliberate greenwashing.

Extract from ACCC's Making Environmental Claims: A guide for business (Dec 2023)

Legal Risk Management

Caution against greengushing comes from recognising that overpromising can attract as much legal scrutiny as outright deception:

Directors and Officers Liability: Leaders could face personal legal challenges for unmet exaggerated commitments.
Regulatory Compliance : Adopt the principle of avoiding misleading claims by carefully communicating environmental efforts.
Reputation Management: Overpromising can lead to a significant loss of consumer trust when promises are unfulfilled.

From Enthusiasm to Authenticity

Balancing enthusiasm with factual reporting is crucial. It's not about questioning a company's commitment to sustainability but about managing:

Litigation Risks: Overly ambitious or specific goals can lead to legal challenges if not fulfilled.
Vague Commitments: Conversely, setting less detailed or more conservative targets can lower legal risks by aligning expectations with realistic outcomes.

Practical Steps for Businesses:

Audit and Assess : Regularly review marketing and external reporting materials against actual environmental performance.

Training : Educate marketing and communication teams on the nuances of environmental claims.

Stakeholder Engagement : Foster ongoing dialogue with stakeholders about real sustainability efforts.

Verification : Consider third-party audits, independent reviews or certifications to lend credibility to claims.

8 Key Principles extracted from the ACCC's Making Environmental Claims: A guide for business (Dec 2023)

Conclusion

The landscape of environmental marketing demands a careful balance between ambition and authenticity. With tightening regulations and reporting frameworks, companies are compelled to substantiate their environmental claims, ensuring they are not merely ambitious but also credible. This strategy not only avoids the risks associated with greengushing but also builds genuine trust with consumers and stakeholders. The era of making grandiose claims without backing is over.

Questions for Consideration:

How will your company ensure its sustainability claims foster trust without falling into the greengushing trap?
What steps will you take to make sure your enthusiasm for sustainability translates into credible and trustworthy claims?

Additional tips:

Refer to ACCC's greenwashing guidelines and case studies.

Disclaimer: The information contained in the article is intended only to provide a general overview of matters of interest and is intended to apply only within Australia. It does not constitute legal advice.

#Greenwashing #Greenwishing #Greenhusing #Greengushing #SustainableFinance #SustainableConstruction #RiskManagement #Governance #Greenwash #Business #Sustainability

First published on LinkedIn 28th October 2024

Three Shades Of Green You Don't Want To Be Tarnished With

Wed, 30 Apr 2025 03:25:42 GMT

Three Shades Of Green You Don't Want To Be Tarnished With

Mansfield Advisory Pty Ltd

200 followers

May 17, 2024

Greenwashing, greenhushing, and greenwishing are deceptive sustainability practices that hinder real progress. While these tactics might seem like shortcuts, they ultimately damage a company's reputation, mislead consumers, and harm the environment. But navigating these 'shades of green' is possible! Embracing genuine environmental responsibility attracts talent, boosts brand reputation, and drives positive change. Let's explore how to achieve this!

Greenwashing: The Deceptive Green Facade

Greenwashing involves making misleading claims about a company's environmental and sustainability practices. This can include exaggerating claims of environmental, social or ethical benefit, downplaying negative impacts, or using misleading imagery. As regulatory red lights flash on greenwashing, the crackdown intensifies, exposing companies and their directors to serious legal consequences under the Corporations Act, ASIC Act, and Australian Consumer Law.

Greenwashing can be both intentional and unintentional. Many organisations lack awareness of how their marketing and communication can mislead shareholders and stakeholders. This can happen when they rely on ambiguous statements, exaggerated claims, or vague sustainability buzzwords without truly understanding their meaning. We see this in the overuse of terms like "climate-friendly," "eco-friendly," and "environmentally friendly," often used for assets, products or services with limited environmental benefits.

The High Cost of Greenwashing:

- According to a recent report by Willis Towers Watson, 'Directors and Officers (D&O) Insurance Woes': Greenwashing claims have led to a surge in lawsuits and rising insurance premiums for executives. They project D&O insurance premiums to rise by as much as 20% in 2024, partly driven by this issue. According to ASIC, future cases may move beyond misleading and deceptive conduct to licence obligations, D&O duties, and various other obligations. Future areas of interest are likely to include: Net zero statements and targets; Use of terms such as ‘carbon neutral’, ‘clean’ or ‘green’;and, the scope and application of investment exclusions and screens.

- Reputational Damage: Consumers are increasingly savvy and punish false claims with boycotts and lost sales. A McKinsey study revealed that 79% would ditch a brand caught greenwashing.

- Crackdown on Greenwashing: Governments are getting serious about greenwashing, cracking down with hefty fines and potential restrictions on misleading claims. A recent ACCC internet sweep found a staggering 57% of businesses reviewed made misleading claims about their environmental credentials. The focus isn't just on consumer products anymore. ASIC is taking action too, with ongoing legal battles against superannuation giants like Mercer, Active Super and Vanguard). These cases involve accusations of misleading investors about "sustainable" investments, stopping investments in Russia (when they didn't), and cherry-picking ESG criteria for investment funds. Just recently, the Federal Court found Vanguard's "Ethically Conscious" bond fund guilty of greenwashing for investing in fossil fuels, despite promises to the contrary. The judgement imposed a penalty on Vanguard of A$12.9 Million for its misleading conduct in misrepresenting the “ethical” characteristics of the Fund. Approximately 74% of the securities in the Fund by market value were not researched or screened against applicable ESG criteria. Similarly, Active Super has also now been found guilty of misleading and deceptive conduct in relation to exclusions applied to gambling, coal mining, Russian entities, and oil tar sand investments on its website, reports, and disclosure documents. {Update] The Federal Court on 18th March 2025 imposed a penalty of $10.5 million against Active Super for greenwashing misconduct. This sends a clear message: misleading sustainability claims won't be tolerated by regulators.

- Trademark Infringements: Potential trademark breaches have occurred for referencing Green Star, NABERS, Climate Active, etc., without proper rights or to create misleading impressions. Misusing these trademarks can create a false or misleading impression about a company's sustainability achievements and infringe on the intellectual property rights of these certification schemes.

- Certification Scheme Issues: Climate Active has also faced scrutiny. The Australia Institute filed a complaint in February 2023, alleging the scheme might be misleading. Specifically, the complaint criticizes Climate Active's emphasis on emission offsets for achieving carbon neutrality and awarding certification to fossil fuel companies that offset a small portion of their emissions. The ACCC has not yet resolved this complaint. This raises questions about the eligibility criteria for certification, particularly for sectors like fossil fuels that are required to use safeguard credits. There is also a separate scheme issue raised in a Senante reference committee, questioning whether Climate Active misled participants by not having an approved certified trade mark of their Standard.

Eight Key Principles To Making Environmental Claims

8 Key Principles extracted from the ACCC's Making Environmental Claims: A guide for business (Dec 2023)

Greenhushing: Silence Speaks Volumes

Stricter greenwashing regulations could trigger greenhushing, where companies shy away from disclosure, fearing non-compliance. This curbs aspirations (showcasing ambitious goals) and risks obscuring negative environmental impacts (unsustainable practices).

The Dangers of Silence:

- Undisclosed Risks: Hidden environmental issues put communities at risk, leading to potential lawsuits and health problems.

- Missed Opportunities: Ignoring sustainability hinders innovation and cost-saving efficiencies. Think of wasted resources and missed chances to improve efficiency.

- Erosion of Trust: Companies that hush environmental or social concerns risk losing public trust, hindering crucial collaboration on environmental challenges. This leaves everyone worse off, as tackling environmental and/or social challenges requires.

With the upcoming introduction of mandatory climate-related financial disclosures, it will be crucial to understand how organisations can leverage transparency as a strategic advantage and as a tool to mitigate risks against greenhushing claims.

Greenwishing: Chasing a Mirage

Companies engage in greenwishing by setting unrealistic or unattainable sustainability goals without a clear plan or substantive actions to achieve them. This often involves making grand pronouncements, such as promising to become carbon neutral by a certain date, without concrete plans, substantiating evidence or resources to back them up. Greenwishing can also be a slippery slope of aspiring to do something without a genuine action plan, ultimately leading to disappointment and hindered progress.

The Mirage's Delusions:

- Misallocation of resources: Companies waste resources chasing impossible dreams instead of focusing on achievable efforts with genuine impact.

- Discouragement and apathy: When ambitious but unrealistic goals are repeatedly missed, stakeholders become disheartened, discouraging further investment in more achievable sustainability efforts.

- Hinders real action: Greenwishing creates a false sense of accomplishment, diverting attention from actual problems and delaying meaningful action.

Being ambitious is not greenwishing: Ambitious sustainability planning emphasises a proactive approach while acknowledging the potential challenges of achieving ambitious goals. The intent and commitment to actions set it apart from wishing that implies inaction.

Beyond the Shades: Embracing Authentic Sustainability

Fortunately, companies can navigate these pitfalls and embrace a genuine path towards sustainability:

- Transparent Storytelling: Focus on verifiable data and real progress, demonstrating your commitment through concrete efforts. Be honest and transparent, and share your genuine sustainability journey. Ensure evidence is easily accessible, clear, based on fact, and readily available.

- Robust Governance: Implement strong internal controls and oversight to prevent deception and ensure compliance. Let accountability be your guiding star.

- Stakeholder Engagement: Listen actively to concerns and address them with transparency. Collaborate with stakeholders and involve them in your sustainability journey.

- Action Speaks Louder than Words: Move beyond lip service and commit to concrete actions that demonstrably improve your environmental impact. Remember, it's about real change, not misleading portrayals of sustainability.

An Australian Sustainable Finance Taxonomy

Mark your calendars! An exciting industry-government initiative is currently developing an Australian sustainable finance taxonomy. Led by the Australian Sustainable Finance Institute (ASFI) through their Taxonomy Project, this initiative aims to leverage international best practices to create a credible, usable, and internationally compatible Australian taxonomy.

This taxonomy will provide clear and consistent definitions of sustainable activities, helping to mitigate greenwashing in investment products and portfolios. The first round of public consultation kicks off on May 28th, and ASFI is seeking feedback on key areas like environmental objectives and criteria for priority sectors like electricity, generation and storage, mining, and the built environment.

Substantiating Sustainability Claims: ISO 14021

Vague sustainability claims can be frustrating for consumers. Voluntary standard ISO 14021 combats this by promoting clear and verifiable environmental assertions. It prohibits use of general terms like "eco-friendly" and emphasises specific, substantiated claims backed by evidence. Think scientific data, not marketing fluff! To enhance credibility, ISO 14021 recommends third-party verification, which is also recommended in ACCC guidance. This can involve Type 1 eco-label certifications like Good Environmental Choice (GECA) and Global GreenTag in Australia. By following ISO 14021 and achieving relevant certifications, companies can demonstrate transparency and provide verifiable evidence of their environmental efforts.

Shine a Light on Genuine Sustainability

Is your company at risk of greenwashing? Navigating the complexities of sustainability can be challenging, but staying true to authenticity is key. Businesses can build a sustainable future by avoiding misleading shades of green and embracing real, positive change.

As the ACCC acknowledges, sometimes businesses do accidentally mislead consumers. By following the ACCC’s guidance and key principles, businesses can make environmental or sustainability claims less likely to mislead consumers and break the law. It’s now up to you to avoid the three shades of green.

The fourth shade: Greengushing

Read the follow-up article on Greengushing here. This is the fourth shade of green you don't want to be tarnished with. Where do we draw the line between genuine environmental impact and exaggerated claims? Read on to unpack the dilemma.

Additional tips:

- Refer to ACCC's greenwashing guidelines and case studies.

- Understand trademark restrictions before referencing Green Star, NABERS, Climate Active, etc

- Prioritise genuine sustainability strategies and communicate them effectively.

Disclaimer: The information contained in the article is intended only to provide a general overview of matters of interest and is intended to apply only within Australia. It does not constitute legal advice.

#Greenwashing #Greenwishing #Greenhusing #SustainableFinance #SustainableConstruction #RiskManagement #Governance #Greenwash #Business #Sustainability

First published on LinkedIn 17th May 2024

NZ Seize the Day: Lessons from New Zealand's Refrigerant Management for Australia.

Tue, 29 Apr 2025 05:21:59 GMT

NZ Seize the Day: Lessons from New Zealand's Refrigerant Management for Australia.

Mansfield Advisory Pty Ltd

200 followers

February 5, 2025

Following our previous article on illicit refrigerant trade (here), it's worthwhile seeing what is happening across the ditch and learn from how New Zealand is actively shaping its regulatory landscape to meet global environmental goals and their successes in seizure of Illegal HFCs.

New Zealand's Approach to Refrigerants

New Zealand has been proactive in implementing the Kigali Amendment to the Montreal Protocol, which aims to phase down the use of hydrofluorocarbons (HFCs), potent greenhouse gases. The country has introduced strict controls on the import, use, and disposal of refrigerants, emphasizing the need for sustainable practices and the transition to lower-GWP (Global Warming Potential) alternatives. This includes:

- Mandatory Reporting: Businesses handling refrigerants must report their usage and emissions to ensure compliance with national and international commitments.

- Training and Certification: There is a strong focus on training technicians to handle refrigerants safely and efficiently, reducing leaks and emissions.

- Recovery and Recycling: Encouraging the recovery, recycling, and proper disposal of refrigerants to prevent environmental harm.

Since 2013, New Zealand's Emissions Trading System (ETS) has been crucial in managing refrigerants by including HFCs in its regulatory framework. The ETS imposes import taxes on new refrigerants based on their Global Warming Potential (GWP) and products containing HFCs, such as motor vehicles and pre-charged equipment. For 2024, the carbon price is set at NZD $71.97 per metric ton of CO2e, incentivizing the destruction of HFCs by allowing regulated entities to earn New Zealand Emissions Units (NZUs) for each tonne of CO2 equivalent destroyed.

The future effect on the atmosphere (measured by carbon dioxide (CO2) equivalent) of new bulk HFCs imported into New Zealand will be reduced gradually until 2036 (see graph below).

Graph showing annual limit on importation of HFCs into New Zealand 2020-2036 (in CO2-equivalent tonnes)

Product Stewardship on Synthetic Refrigerants in New Zealand

The New Zealand Government has recently approved regulations to establish Cool-Safe as the official Product Stewardship Organisation for Synthetic Refrigerants, managed by the Trust for the Destruction of Synthetic Refrigerants. Once enacted, all synthetic refrigerants and related equipment must comply with this scheme, which requires:

- Data Reporting: The refrigerant sector must report usage data to Cool-Safe for lifecycle tracking.

- Training Standards: Effective three years after regulation, sales and recovery of refrigerants and equipment will be restricted to those with industry-recognized training.

Cool-Safe has traditionally handled voluntary recovery and destruction of HFCs and ODS, funded by a levy on bulk HFC imports and NZU sales from their activities. From 2024, participation becomes mandatory, offering incentives at NZD $25 per kg for recovered refrigerant, with increased rates for volumes over 500 kg. This shift, along with the 2023 policy allowing any ETS-regulated entity to generate NZUs from HFC destruction, highlights New Zealand's commitment to greenhouse gas reduction.

For more details:

- Read about the Synthetic Refrigerant Stewardship here

- Check out the Cool-Safe website.

Recent Seizure of Illegal HFCs

In a significant move to enforce these regulations, the Environmental Protection Authority (EPA) of New Zealand recently conducted an investigation leading to the seizure of HFC gases. This operation highlights the government's vigilance against illegal imports that could undermine the environmental efforts to reduce HFC emissions. The EPA's actions underscore the seriousness with which New Zealand treats its international environmental obligations and domestic laws regarding refrigerant management. This seizure, amounting to 3 tonnes of HFCs, could have a significant environmental impact. Assuming a mix of common HFCs:

- If we consider the HFCs primarily HFC-134a (GWP 1,430), this seizure would be equivalent to approximately 4,290 tonnes of CO2 .

- However, if the HFCs were more like HFC-404A (GWP 3,922), the impact would be approximately 11,766 tonnes of CO2 equivalent .

Therefore, depending on the composition of the HFCs involved, this seizure could have an environmental impact of 4,290 to 11,766 tonnes of CO2 equivalent. This range illustrates the potential magnitude of greenhouse gas emissions this enforcement action prevents. This seizure signifies a commitment to environmental stewardship and serves as a warning to those who might consider circumventing the strict regulations for the importation and use of HFCs.

Relevance to Australia

The actions taken by New Zealand are particularly relevant for Australia, as both countries share similar environmental challenges and are part of the same regional ecosystem. Australia, like New Zealand, is a signatory to the Kigali Amendment and is in the process of adapting its regulations concerning refrigerants:

- Regulatory Alignment: Australia can learn from New Zealand's proactive approach to enforcing and monitoring refrigerant use.

- Cross-Border Implications: The illegal trade of refrigerants could easily spill over from one country to another, affecting both nations' efforts to reduce greenhouse gas emissions.

- Innovation and Collaboration: There's an opportunity for both countries to collaborate on technology and policy innovations that could lead to more effective refrigerant management.

Comparison with New Zealand's Approach:

While Refrigerant Reclaim Australia (RRA) operates a stewardship program, it differs from the newly proposed Cool-Safe initiative in New Zealand. RRA focuses more on the end-of-life phase of refrigerants within a co-regulatory framework that involves industry self-regulation. In contrast, New Zealand's scheme aims for a holistic lifecycle management approach backed by new regulations to enforce compliance. Australia could expand RRA's role or develop a new framework (and oversight entity) to align more closely with this comprehensive lifecycle stewardship model, enhancing environmental and regulatory outcomes. Key aspects:

- Mandatory Lifecycle Tracking : NZ's Cool-Safe scheme will require lifecycle tracking from sale to recovery, offering a more comprehensive approach than RRA's current focus solely on end-of-life management.

- Training Mandates : NZ plans to introduce mandatory training for those handling refrigerants, contrasting with Australia, where such training, while encouraged, is not explicitly mandated under RRA's stewardship but managed through other industry bodies and legislative requirements.

- Broader Scope : The proposed NZ scheme encompasses new sales and end-of-life management, potentially involving a wider range of stakeholders in the lifecycle process than RRA's current model.

- Legal Framework : NZ's approach involves crafting new regulations specifically for stewardship, whereas Australia's integrates refrigerant management into existing environmental protection laws.

Australian Stewardship Considerations:

- Mirror NZ's Scheme: Australia could consider establishing a similar product stewardship scheme for refrigerants, leveraging existing bodies like RRA or a new trust similar to New Zealand's Trust for the Destruction of Synthetic Refrigerants to manage it.

- Legislative Action : Push for legislation akin to NZ's, mandating refrigerant lifecycle tracking, reporting, and training standards to ensure safe handling and disposal.

- Enforcement and Collaboration : Strengthen cross-border cooperation with New Zealand to combat illegal refrigerant trade, enhancing enforcement mechanisms based on New Zealand's success.

- Public and Industry Education : Similar to NZ's approach, initiate campaigns to educate the public about the benefits of stewardship and encourage compliance and innovation in refrigerant management.

Cool Safe NZ

Valuing Refrigerant Recovery: New Zealand vs. Australia

New Zealand has taken an innovative approach to encouraging refrigerant recovery with its Cool-Safe Buy-Back programmes. Initiated in October 2022, these programmes reward companies and technicians for responsibly managing synthetic refrigerants, promoting a culture of environmental responsibility:

- Bounty Buy-Back Programme: In May 2024, the payment for recovered refrigerants was increased to $40 per kilogram, a significant jump from $25. This increase is influenced by New Zealand's Emissions Trading Scheme (ETS), where the carbon price for 2024 is set at NZD $71.97 per metric ton CO2e. This incentive covers the costs of recovery and financially benefits those who participate by aligning with the environmental cost of HFC emissions.

- Bulk Refrigerant Buy-Back: Even higher rates are offered for 200 kilograms or more recoveries, ensuring that bulk handlers are also motivated to participate in the programme. This structure reflects the economic benefits of reducing large quantities of HFCs under the ETS framework.

In stark contrast, Australia has adopted a different strategy for its refrigerant management:

- Fixed Levy: Australia maintains a fixed levy of AUD $2.00 (NZD $2.21 as of 5th Feb 2025) per kilogram for refrigerant recovery. The Australian Competition and Consumer Commission (ACCC) re-authorised this arrangement in 2021, locking it in for ten years. Refrigerant Reclaim Australia (RRA) indicated they “saw no need to increase this levy over the next ten years.” Unlike New Zealand, Australia's levy does not factor in carbon pricing and lacks the integration of an ETS or similar mechanism for refrigerants.

This fundamental difference in approach highlights two key points:

Economic Incentive: New Zealand's system directly incentivises refrigerant recovery and proper disposal by providing a financial benefit that grows with the volume and urgency of the environmental need. In contrast, Australia's static levy, which does not include carbon pricing, might not adequately reflect the increasing value of responsible refrigerant management in the fight against climate change.
Long-term Commitment: Australia's decision to lock in the low levy rate for ten years could hinder the country's adaptability to changing environmental priorities and economic conditions. Meanwhile, New Zealand's dynamic pricing model, influenced by its ETS, allows for adjustments to encourage more participation as the environmental stakes rise, making it more responsive to the need to reduce greenhouse gas emissions.

This comparison underscores the potential for Australia to reconsider its strategy in light of New Zealand's success in engaging its industry with economic incentives for sustainability (and having a carbon price mechanism factored in), potentially leading to more effective refrigerant management and more significant environmental benefits.

Why This Matters:

- Environmental Impact: Reducing HFCs is crucial for combating climate change due to their high global warming potential.

- Compliance with International Agreements: Demonstrates New Zealand's leadership in adhering to global environmental agreements like the Kigali Amendment, setting a precedent for Australia.

- Economic Implications: This policy encourages innovation in refrigerant technology and supports the growth of industries focused on sustainable solutions, which could also benefit Australia economically.

The seizure development in New Zealand (article here) also reminds Australian businesses and policymakers to remain vigilant and proactive in their approach to environmental compliance and sustainability. The EPA's investigation involved several search warrants executed across New Zealand. So far, 3 tonnes of HFCs have been seized, and the investigation is ongoing. Offences can result in a fine and, in some cases, up to five years’ imprisonment.

Capitalizing on the Transition to Sustainable Cooling:

Australia is at a defining moment where its approach to refrigerant regulation could lead the way in global sustainability efforts. Businesses are now tasked with navigating the complexities of mandatory emissions disclosure while being acutely aware of the burgeoning issue of illegal refrigerant trade, as highlighted in our previous discussion on illicit refrigerants (see previous post here).

Australian companies can manage risks and seize opportunities within the emerging low-carbon economy by vigilantly monitoring refrigerant use, adopting appropriate lower GWP alternatives, and strengthening compliance mechanisms. New Zealand's proactive measures, such as the recent seizure of illegal HFCs, serve as a clear example of the enforcement needed to combat the illicit trade that undermines environmental efforts.

Alignment with international best practices does more than ensure regulatory compliance; it elevates Australian businesses to the forefront of the worldwide movement towards responsible cooling solutions. This pivotal moment demands collaboration among government bodies, industries, and innovators to tackle refrigerant smuggling, slash emissions, and spearhead technological advancements.

What steps should Australian businesses take to mirror New Zealand's success in managing refrigerants?"

#Refrigerants #KigaliAgreement #Cooling #PFAS #SustainableCooling #ClimateAction

Notes

- NZ EPA encourages anyone being offered bottles of HFCs at significantly lower than market price to contact our investigations team in confidence at investigations@epa.govt.nz

- Anyone importing bulk HFCs needs a permit under the Ozone Layer Protection Act and must be registered as a participant in the Emissions Trading Scheme. Bulk HFCs are containers of new or recycled HFC gas in an unprocessed form, alone or in a mixture.

- Permits are not needed to import HFCs into goods, such as car air conditioning or fire extinguishers. However, under the CCRA, goods containing synthetic greenhouse gases, including HFCs, are subject to a levy.

References:

EPA Seizes HFC gases in illegal import investigation https://www.epa.govt.nz/news-and-alerts/latest-news/epa-seizes-hfc-gases-in-illegal-import-investigation

NZ Rules for HFCs https://www.epa.govt.nz/hazardous-substances/certificates-permits-and-permissions/hydrofluorocarbon-gases-hfcs-import-and-export/the-rules-for-hfcs/

ACCC Ruling on Application for revocation of A91515 and the substitution of authorisation AA1000537 lodged by Refrigerant Reclaim Australia Limited in respect of its operation of a product stewardship program to recover ozone-depleting and synthetic greenhouse gas refrigerants (May 2021). https://www.accc.gov.au/system/files/public-registers/documents/Final%20Determination%20-%2012.05.21%20-%20PR%20-%20AA1000537%20-%20RRA.pdf

First published on LinkedIn 5th February 2025

Bamboo: Australia’s Untapped Ally for Sustainable Growth and Innovation

Tue, 29 Apr 2025 05:02:19 GMT

Bamboo: Australia’s Untapped Ally for Sustainable Growth and Innovation

Mansfield Advisory Pty Ltd

200 followers

March 14, 2025

By Jeremy Mansfield OAM, Mansfield Advisory Pty Ltd

Is bamboo Australia’s next big economic opportunity? As a low-embodied carbon, bio-based material, bamboo complements timber’s role in sustainable forestry, offering rapid growth and versatile applications. Over 20 years, bamboo sequesters 167.5 tonnes of CO₂ equivalent per hectare (t CO₂e/ha)—197% more than timber’s 85 t CO₂e/ha —while delivering nearly $1.4 million from a $1 million investment compared to timber’s $738,189.20 [1, 2, 7–9]. Recent research [22] suggests bamboo could reduce global building emissions by substituting for high-carbon materials, unlocking massive potential. Why isn’t Australia scaling bamboo?

Bamboo’s Global Rise

Bamboo thrives globally. Asia, Africa, the Americas, and Europe tap its benefits, but Australia lacks a bamboo strategy. This country will miss out on a $67.13 billion market in 2024 , which is set to grow to $88.44 billion by 2030 at a 4.7% CAGR [17]. China’s bamboo covers 5% of forest area and stored 129.7 TgC from 1987 to 2020 [18, 20].

Transition: With global momentum, Australia can boost sustainability and economies with bamboo.

Environmental Benefits: A Climate and Land Restoration Ally

Bamboo’s edge lies in its speed and management:

- Rapid Growth and Carbon Sequestration: Matures in 5 years, sequestering 252.5 t CO₂e/ha over 20 years at 15 t CO₂e/ha/year [1, 2]. Chilton et al. (2025) show that managed plantations accumulate 429 Mg C/ha—five times softwoods—while unmanaged ones halve this benefit [22, section on silvicultural management].

- Life Cycle Assessment (LCA) Flaws : Static LCAs and timber models undervalue bamboo’s rapid regrowth and soil carbon retention, treating it like slower softwoods and missing its environmental impact [22, section on carbon accounting flaws].

- Durable Products: Locks 70% of carbon into long-lived products, vs. timber’s 50% [3, 4].

- Soil Carbon and Restoration : Boosts soil carbon at 1 t CO₂e/ha/year, double timber’s 0.5 t CO₂e/ha/year [5, 6], and restores degraded lands.

- Biodiversity and Resilience : Clumping bamboo supports ecosystems and adapts to shifts.

These benefits position bamboo as a strategic asset for carbon reduction and land restoration—a powerful tool for meeting Australia’s net-zero emissions target by 2050.

Carbon sequestration of bamboo and timber over 20 years. Bamboo's bar reaches 252.5 t CO₂e/ha, while timber's bar reaches 85 t CO₂e/ha [1, 2].

A recent analysis [22] concluded, on average, a hectare of timber bamboo can accumulate 429 Mg C ha−1 more than wood, nearly five times as much.” Timber bamboo’s superior carbon benefit from fast, early-growth, and annual partial harvesting is visibly evident”.

The average accumulation of net annual carbon flows, including plantation growth, harvest and harvested wood product (HWP) production, and final disposition of HWP, for numerous timber bamboo and US softwood species-location mixes. [Figure 7, 22]

Economic Benefits: Rapid Returns and Regional Growth

Bamboo delivers wins:

- Frequent Harvesting : A 5-year cycle yields 15 harvests in 20 years, compared to timber’s one harvest in 26–30 years, boosting jobs and activity.

- Financial Returns : A $1 million investment yields $1,386,250 vs. timber’s $738,189.20—1.9x the return. At $75/t CO₂e by 2035, returns soar [8, 9].

- Carbon Credits : Generates $9,090/ha over 20 years at $36/t CO₂e, vs. timber’s $3,060/ha [7].

Beyond Carbon: Bamboo’s Co-Benefits

Bamboo’s value extends further:

- Soil Restoration : Thrives on degraded lands like NSW Western Slopes [10].

- Biodiversity : Clumping bamboo supports ecosystems.

- Economic Growth: Creates jobs; potential impacts should be assessed.

- Resilience : Adapts to environmental variability.

Unlocking Bamboo’s Full Potential: Biochar and High-Value Construction Products

Structural Engineered Bamboo (SEB) and Laminated Bamboo Lumber (LBL) offer high tensile strength, durability, and flexibility, rivalling timber. Chilton et al. (2025) show Dendrocalamus asper outperforms softwoods, locking 70% of carbon into products vs. timber’s 50% [3, 4]. Waste becomes biochar, sequestering carbon [11], or fuels sustainable aviation fuel (SAF), renewable diesel, and graphene [12, 13] for advanced materials, broadening its impact on the circular economy and enhancing its investment appeal.

Source: House of Bamboo

Studies conducted by the University of Bath’s Dr. Bhavna, using common wood standards to allow comparison with engineered timber products, have shown that engineered bamboo boards and laminated bamboo have properties that compare with or surpass those of timber [21]. Results from testing of SEBs have found that:

- Mechanical properties are comparable to hardwoods.

- Exhibit compressive strengths greater than softwoods.

- Have tensile strengths greater than other wood species.

- They are more dimensionally stable in moisture and temperature changes when compared to timber based products (dependent on wood species).

Moreover, integrating bamboo with timber in composites leverages bamboo’s high strength and rapid renewability alongside timber's renowned workability and familiarity. This synergy results in materials that are not only durable but also highly sustainable, significantly reducing the embodied carbon footprint of construction materials, which contribute substantially to global carbon emissions.

As the demand for sustainable construction materials increases, these engineered bamboo products are poised to play a pivotal role in fulfilling global building requirements while minimizing environmental impact, increasing their demand and value.

Six-unit town houses, comprising 3 stories on concrete slab with envelope framed from low-embodied carbon, high-thermal efficiency, off-site pre-fabricated bamboo–wood composite vertical framing (wall) system. Source: Figure 5 [22] International Building Code-compliant multifamily building in Salt Lake City, UT, USA

The Status Quo Challenge: Timber’s Entrenched Advantage

Overcoming barriers to bamboo adoption is critical:

- Grants favour existing systems, sidelining bamboo.

- Advocacy supports timber, overshadowing bamboo’s potential.

- Data on timber is robust, while bamboo lags.

- Recent ABARES data (2024) shows that Australia’s plantation estate shrank to 1.97 million hectares, signalling a supply crisis that bamboo could solve as a fast-growing complement, boosting sustainability and economies [23]. However, the carbon accounting flaws mentioned earlier hinder adoption [22, section on carbon accounting flaws]. A timber-focused framework overlooks bamboo’s potential. A collaborative ecosystem could integrate both, enhancing sustainability.

Despite these barriers, bamboo directly aligns with the Department of Agriculture and Forestry Support Plantation Establishment Program’s goals:

- Increasing Domestic Supply: Bamboo’s 5-year harvests can meet construction demand within a decade, with engineered products like SEB and Bamboo Scrimber matching hardwoods’ mechanical properties [3, 4].

- Reducing Emissions : Bamboo’s superior sequestration (252.5 t CO₂e/ha vs. 85 t CO₂e/ha) accelerates progress toward sustainability targets [1, 2].

- Current Exclusion: Yet, the program’s focus on softwood and hardwood plantations excludes bamboo, missing a chance for diversification.

To enrich Australia's forestry sector, we must evolve policies to embrace bio-based materials like bamboo . This shift would acknowledge bamboo’s rapid growth and carbon storage, enhancing timber by providing complementary resources. Integrating bamboo creates a resilient, diverse ecosystem, supporting sustainable development without undermining timber and unlocking economic and environmental gains.

World's First and Tallest Structural Engineered Bamboo Building, a 21-metre, 6-story bamboo structure. Source: Zhejiang University-University of Illinois Urbana-Champaign Institute [25]

Australia: A Bamboo Opportunity

Australia, the only continent without a bamboo strategy, could lead:

- Degraded Lands: Bamboo can restore poor soils.

- Sustainability Goals: It supports net zero by 2050.

- Economic Potential: A bamboo industry could boost rural economies, and impacts should be assessed.

Potential Locations for Bamboo Plantations

According to recent research, several promising regions across Australia have been identified for potential bamboo cultivation:

Source: Australian Bamboo Plantations

Harvesting Timing: Bamboo vs. Timber

Given the focus on the next 20 years, hardwood species, like eucalypts, typically require around 80 years to reach maturity for optimal carbon sequestration and structural use and are less relevant for our analysis. Instead, we'll compare bamboo to softwood like pine, which offers a more immediate comparison within our timeframe:

- Bamboo: After an initial growth period of 5 years, when the poles have matured enough for use in structural engineered bamboo, selective harvesting can begin. From year 5 onwards, bamboo can be harvested annually by selectively cutting the ready poles, allowing for 15 additional harvest cycles within our 20-year analysis. Over this period, bamboo sequesters 252.5 t CO₂e/ha. This frequent harvesting enhances its environmental benefits and significantly stimulates continuous economic activity, providing a sustainable boost to regional economies through regular job creation and income streams.

- Timber (Pine): While pine might not reach full maturity until around 26–30 years, for our comparison, within 20 years, pine sequesters approximately 85 t CO₂e/ha. Pine's full potential would be realized over a more extended period, but our analysis focuses on the growth up to 20 years [6, 14].

The Call to Action: Bamboo Should Complement Timber

Let’s unite—government, investors, landowners, designers, and builders—to unlock bamboo’s potential:

Debunk Myths: Educate on native bamboo and dispel myths to build trust and attract investment [1].
Shift Focus: Advocate bamboo in grants and markets, valuing its 197% environmental benefits for sustainability [7, 8].
Invest : Scale plantations for 1.9x returns, driving jobs and growth - potential economic and social impacts should be assessed [7].
Launch a Bamboo 2045 Vision : A 20-year plan to lead globally, supporting sustainability targets [7].
Support R&D : Innovate harvesting tech for competitiveness, per Chilton et al. (2025), to enhance efficiency and scalability in Australia [7, 22].
Update Carbon and Forestry Metrics : Ensure LCAs and carbon forestry accounting reflect bamboo’s rapid regrowth and soil carbon retention, addressing flaws noted by Chilton et al. (2025), to drive adoption [22, section on carbon accounting flaws].
Join INBAR : Become an INBAR member to access global expertise, positioning Australia as a bamboo leader [1].
Collaborative Policy: Expand regulations to complement timber, share incentives for mutual growth, and fund R&D.

Join this movement—comment below on how you can help!

Bamboo offers a compelling alternative to timber, delivering 197% more environmental benefits per hectare and nearly double the return on investment. With its vast degraded lands and native clumping bamboo species, could Australia be on the cusp of a sustainable transformation? In our next article, we’ll dive into the potential of non-native clumping bamboo species and explore how to introduce them responsibly, drawing on biosecurity lessons from other timber species. What do you think—could bamboo be Australia’s next big opportunity? Share your thoughts below!

References

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Chilton, K.; Kadivar, M.; Hinkle, H. (2025). From Problems to Possibilities: Overcoming Commercialization Challenges to Scale Timber Bamboo in Buildings. Sustainability, 17, 1575. https://doi.org/10.3390/su17041575
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Clean Energy Regulator. (2024). Carbon Credits (Carbon Farming Initiative) (Audit Thresholds) Amendment (Low Risk Plantation Forestry Projects) Instrument 2024. Canberra, Australia: Australian Government. Retrieved from https://www.cer.gov.au/publications/carbon-credits-carbon-farming-initiative-audit-thresholds-amendment-low-risk-plantation
Zhejiang University. (2024). World’s First 6-Story Engineered Bamboo Building Unveiled. Hangzhou. Retrieved from https://www.zju.edu.cn/english/2024/0130/c19573a2876560/page.psp

First published on LinkedIn 14th March 2025

Blind Spots on the Road to Net-Zero

Tue, 29 Apr 2025 01:43:15 GMT

Blind Spots on the Road to Net-Zero: Australia’s Refrigerant Reporting Gaps

Introduction

Australia’s National Greenhouse and Energy Reporting (NGER) Act mandates that large corporations report greenhouse gas emissions, energy production, and consumption, including emissions from refrigerants. Refrigerants, such as hydrofluorocarbons (HFCs), are potent greenhouse gases with high global warming potential (GWP), making their accurate tracking vital for meeting national climate targets. Yet, the NGER framework has significant flaws—exemptions for small air conditioning units or refrigerants with a GWP ≤1,000, reliance on estimated data, absence of leakage registers, and unreported end-of-life emissions—that likely result in underreported emissions. Starting January 1, 2025 , the Australian Sustainability Reporting Standards (ASRS) will introduce broader climate-related disclosures, but these new rules are unlikely to fix the specific gaps in refrigerant reporting. This article explores these issues, compares Australia’s approach to international practices, and proposes improvements to keep the country on track for net-zero.

Regulatory Frameworks and Their Limitations

Australia’s refrigerant management involves multiple frameworks with distinct roles. The Ozone Protection and Synthetic Greenhouse Gas Management Act (OPSGGMA) regulates the supply of refrigerants like HFCs through import quotas and licensing, using GWP values from the IPCC’s Fourth Assessment Report (AR4). A key example is its import restrictions on certain air conditioning equipment using refrigerants with a GWP over 750. These restrictions apply to:

Small systems —such as portable units, window/wall units, and non-ducted split systems with a refrigerant charge up to 2.6 kg—starting 1 July 2024 , and

Multi-head split systems , including variable refrigerant flow (VRF) systems, from 1 July 2025 .

While these measures aim to curb the use of high-GWP refrigerants, they reveal a limitation: the emphasis is on controlling supply rather than tracking actual emissions outcomes. Frameworks like the National Greenhouse and Energy Reporting (NGER) Act and Australian Sustainability Reporting Standards (ASRS) depend on estimates rather than precise measurements, potentially overlooking emissions from systems not subject to these import bans.

Additionally, the reliance on AR4 GWP values introduces further gaps. For instance, R-32 has an AR4 GWP of 675, falling below the 750 threshold and thus remaining permissible in regulated systems. However, the IPCC’s Sixth Assessment Report (AR6) updates its GWP to 771—above the threshold—suggesting that its climate impact may be underestimated. This discrepancy means that systems using R-32 could evade stricter controls, compounding the challenge of accurately reporting refrigerant emissions. Together, these factors highlight a blind spot in Australia’s approach, where supply-side restrictions and outdated metrics leave the full extent of refrigerant emissions unaddressed.

Why It Matters

According to Cold Hard Facts 4 [1], Australia holds about 55,000 tonnes of refrigerants—mostly HFCs—in systems nationwide, equivalent to 100 million tonnes of CO₂ if released. Only around 400-500 tonnes are being destroyed annually[1]. Refrigerants are a significant emissions source in the built environment, including residential and commercial buildings.

Blind Spots on the Road to Net-Zero: Australia’s Refrigerant Reporting Gaps

Our Upfront Opportunity: Australia’s Policy Roadmap to Reduce Upfront Embodied Carbon in the Built Environment by the Australian Sustainable Built Environment Council (ASBEC) [7]

The Australian Sustainable Built Environment Council (ASBEC) reports that refrigerants contributed 9 million tonnes of CO2-equivalent (Mt CO2-e) emissions in 2022 across Scopes 1, 2, and 3 in the built environment (in operational use), out of a total 128 Mt CO2-e (ASBEC, 2024). This highlights their role in Scope 1 (direct) emissions, particularly from heating, ventilation, air conditioning, and refrigeration (HVAC&R) systems. This does not account for the significant refrigerant lifecycle emissions outside of operational use.

Scope 1, 2 and 3 emissions from Australia's Built Environment. Source: ASBEC [7]

While energy efficiency improvements in buildings are a key strategy for reducing operational emissions, refrigerant leaks can significantly undermine these gains. For instance, a leak of HFC-134a, with a GWP of 1,430 (AR4; 1,530 in AR6), can offset the carbon savings achieved through energy-efficient systems, effectively wiping out progress.

Typical plant room for commercial building. Source: A.G. Coombs

More critically, Australia has key blind spots in tackling refrigerant emissions due to gaps in the NGER framework and its disconnect with OPSGGMA’s supply-focused approach. Without accurate data on leaks at a business level—despite some national insight from import reporting—the real impact on Australia’s net-zero trajectory remains unclear, hindering effective action. We cannot afford to rely on guesstimates for decades, as this risks delaying action on a significant emissions source.

Identified Issues in NGER Refrigerant Reporting

The NGER scheme’s approach to refrigerant emissions has several critical weaknesses:

Exclusion of Smaller Systems or Lower-GWP Refrigerants : Systems with less than 100kg of refrigerant or using refrigerants with a GWP ≤1,000—common in retail and hospitality—are exempt, missing their cumulative emissions. For example, a system using R-32 (GWP 771 in AR6) is excluded due to its GWP, despite its growing use and climate impact, potentially missing significant cumulative emissions. A broad range of systems fit into this category.
Reliance on Estimated Values : Default leakage rates, such as those for HFC-134a, replace actual measurements, risking inaccurate emissions estimates.
Lack of Mandatory Leakage Registers : Unlike some overseas regulations, which mandate leak checks and records, NGER lacks systematic tracking, so emissions may be underreported or missed.
End-of-Life Emissions Unreported: Emissions from the decommissioning and disposal of refrigerant systems are not tracked under NGER or ASRS reporting, though OPSGGMA includes measures to manage these processes.

New ASRS Reporting Requirements and Their Impact on Refrigerant Reporting

From January 1, 2025, the Australian Sustainability Reporting Standards (ASRS) have been issued by the Australian Accounting Standards Board (AASB) and mandate climate-related financial disclosures, including:

Scope 1 emissions (direct emissions, including refrigerants),

Scope 2 emissions (indirect emissions from purchased energy), and

Scope 3 emissions (other indirect emissions, such as value chain impacts), phased in over time.

The ASRS applies to entities based on size and employee numbers, divided into three groups:

Group 1 : Largest entities and significant emitters, starting January 1, 2025 .

Group 2 : Medium-sized entities, starting July 1, 2026 .

Group 3 : Smaller entities, starting July 1, 2027 .

Source: EY [8]

Although ASRS broadens emissions reporting, it does not directly tackle NGER’s refrigerant-specific gaps:

Persistent Exclusions : ASRS does not address minimum unit sizes or the GWP >1,000 threshold, leaving smaller systems and low-GWP refrigerants potentially unreported.

Scope 3 and End-of-Life Emissions : Scope 3 reporting might eventually cover some end-of-life impacts starting in 2026 for Group 1, but this depends on implementation details and may not fully address in-use leaks or small systems.

Methodological Flexibility: ASRS allows entities to select emissions measurement methods, likely perpetuating reliance on estimates rather than actual data.

Since NGER and ASRS will coexist, entities must comply with both, but ASRS does not inherently resolve NGER’s refrigerant reporting deficiencies. Recent ASIC’s guidance may also exacerbate these gaps by prioritising practicality over precision in the early stages of implementation.

Table: Summary of Issues and International Comparison

The table below summarises the five key issues and compares NGER’s approach with some examples of international best practice from US, California, Japan and the European Union (EU):

Summary of Issues and International Comparison

This comparison highlights that NGER falls short of international benchmarks, and ASRS does not yet adopt these best practices to bridge the gaps. To address these shortcomings, targeted improvements are needed.

Opportunities for Improvement

Despite ASRS’s broader scope, NGER’s persistent gaps call for targeted enhancements in refrigerant emissions reporting:

Cumulative Thresholds : Introduce a facility-wide refrigerant reporting threshold that accounts for the total refrigerant use across all systems, capturing emissions from numerous small, distributed systems—like those in retail or hospitality—that are currently exempt but collectively contribute to significant emissions.

Lower GWP Limits : Remove the GWP >1,000 threshold to include refrigerants like R-32 under both frameworks.

Actual Data Mandates : Require actual usage and leakage data to replace estimates and ensure accurate reductions.

Mandatory Leakage Registers: Enforce detailed records of refrigerant usage and leaks, aligning with California and EU standards.

End-of-Life Reporting: Mandate end-of-life emissions reporting under NGER and ASRS for comprehensive tracking.

These changes could build on ASRS’s expanded reach but would require regulatory updates to be effective. By phasing in requirements and providing support (e.g., templates, incentives, pilot programs), Australia could improve data quality without overwhelming reporting entities, ensuring we don’t perpetuate guesstimates for decades while still moving toward net-zero. Collaboration with industry partners will be key to implementing these solutions, ensuring businesses can accurately monitor and manage emissions to support Australia’s net-zero goals.

Conclusion

Australia’s refrigerant reporting frameworks—NGER and ASRS—harbor critical blind spots that conceal the true extent of emissions, derailing the nation’s net-zero ambitions. Exemptions for small units or refrigerants with GWP ≤1,000, reliance on estimates, missing leakage registers, and untracked end-of-life emissions persist even with ASRS’s broader requirements, leaving significant gaps unaddressed. These blind spots hinder accurate emissions tracking and risk providing a clear view of the refrigerant challenge. To eliminate these oversights and stay on the road to net-zero, Australia should transition to actual data collection, align with international best practices, and close these gaps decisively.

Thanks to Adrian Bukmanis, Veridien Refrigerant Management, for his expert input and review.

Note: GWP values used in this article use AR6 for scientific accuracy (e.g., HFC-134a at 1,530), while NGER uses AR4 (e.g., HFC-134a at 1,430), which may underestimate impacts.

Other articles in this refrigerant series you may have missed:

Article 1 - Could Australia become a dumping ground for refrigerants?

Article 2 - How is New Zealand tackling refrigerants, and are there lessons for Australia?

REFERENCES

Department of Climate Change, Energy, the Environment and Water. (2023). Cold Hard Facts 4. DCCEEW. https://www.dcceew.gov.au/climate-change/publications/cold-hard-facts-4

Clean Energy Regulator. (2022). National Greenhouse and Energy Reporting (Measurement) Determination 2008. Australian Government. https://www.legislation.gov.au/Details/F2022C00815

California Air Resources Board. (2021). Refrigerant Management Program. CARB. https://ww2.arb.ca.gov/our-work/programs/refrigerant-management-program

European Commission. (2014). Regulation (EU) No 517/2014 on fluorinated greenhouse gases. European Union. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014R0517

United Nations Environment Programme. (2020). Global Refrigerant Management Initiative. UNEP. https://www.unep.org/ozonaction/resources/publications/global-refrigerant-management-initiative

Australian Government. (2024). Australian Sustainability Reporting Standards (ASRS). Australian Government. https://www.legislation.gov.au/Details/F2024L00001

Australian Sustainable Built Environment Council. (2024). Our Upfront Opportunity: Australia’s Policy Roadmap to Reduce Upfront Embodied Carbon in the Built Environment. ASBEC. https://www.asbec.asn.au/research-items/our-upfront-opportunity-australias-policy-roadmap-to-reduce-upfront-embodied-carbon-in-the-built-environment/

EY. (2025). Mandatory Climate-Related Financial Disclosures: What You Need to Know. EY. https://www.ey.com/content/dam/ey-unified-site/ey-com/aus-rzl/documents/pdfs/mandatory-climate-related-financial-disclosures-what-you-need-to-know.pdf

Tilbury, J. (2025). Unpacking ASIC’s Regulatory Guide on Sustainability. LinkedIn. https://www.linkedin.com/pulse/unpacking-asics-regulatory-guide-sustainability-james-tilbury-k6wxc

First published on LinkedIn 9th April 2025

74e915cf

Why Australia’s net zero plan needs fast-growing biobased partners

Why Australia’s net zero plan needs fast-growing biobased partners

Fast-growing biobased crops: what are they and why do they matter?

Biobased materials in action: integrated systems and demonstrated success

The absurdity of timber-only modelling

Policy gaps and opportunities: moving beyond timber

Social and environmental co-benefits: more than just carbon

Recommendations and next steps: turning vision into action

Leading the way with fast-growing partners

Beyond Greenwashing: Protecting Fair Competition and Ethical Supply Chains in the Transition to Net-Zero

Why Energy Efficiency Must Be Central to Decarbonising Diesel-Dependent Equipment Sectors

Why Energy Efficiency Must Be Central to Decarbonising Diesel-Dependent Equipment Sectors

Global Benchmarks: Efficiency as a Core Strategy Elsewhere

Australia’s Missed Opportunity

Overcoming Barriers and Moving Forward

Timber Needs Its Biobased Bedfellows: Why the Fastest Path to Decarbonising Construction is a Family Affair

Timber Needs Its Biobased Bedfellows: Why the Fastest Path to Decarbonising Construction is a Family Affair

The legitimate concerns remain

The risk of throwing the baby out with the bathwater

A constructive way forward

The market sees the opportunity

Hybrids are already outperforming single-material designs

Why “more of the same” won’t close the gap in Australia

﻿

Carbon speed matters too

Time to work as a family

References

Unseen and Unaccounted For: Closing the Refrigerant Gap in Decarbonisation / Net Zero Strategies

Unseen and Unaccounted For: Closing the Refrigerant Gap in Decarbonisation / Net Zero Strategies

The Refrigerant Challenge: A Growing Threat

PFAS Risks: An Emerging Liability

Gaps in Current Strategies

What Needs to Be Acknowledged and Addressed

A Call to Action

REFERENCES

Bamboo: Unlocking Climate Solutions with Australia’s Sustainable Finance Taxonomy

Bamboo: Unlocking Climate Solutions with Australia’s Sustainable Finance Taxonomy

Call to Action (Executive Summary)

Introduction

﻿

Bamboo’s Alignment with the Australian Sustainable Finance Taxonomy

International precedents underscore bamboo’s alignment with sustainable finance frameworks.

Policy and Technical Gaps

Utilising Bamboo as a Structural Engineered System

﻿

Investment Opportunities

Alignment with Future Made in Australia

Strategic Alignment with the Forest Products Industry

Roadmap to Action

﻿

UNEP FIT Post-Summit Insights

Australian Sustainable Finance Taxonomy Alignment Note

Accelerating the Transition to Fossil Fuel-Free Construction

Accelerating the Transition to Fossil Fuel-Free Construction

Why It Matters

Barriers to Overcome

Solutions and Policy Recommendations

Leading by Example

﻿

Global Leaders in Fossil Fuel-Free Construction

The Power of Consistent Data: Reporting Emissions Accurately

Conclusion

References

Could Australia Become A Dumping Ground for Refrigerants?

The Emerging Fourth Green Shade: Beyond Greenwashing

Three Shades Of Green You Don't Want To Be Tarnished With

NZ Seize the Day: Lessons from New Zealand's Refrigerant Management for Australia.

Bamboo: Australia’s Untapped Ally for Sustainable Growth and Innovation

Blind Spots on the Road to Net-Zero