July 15th, 2025

On July 10, UDI submitted a letter to the Canadian Board for Harmonized Construction Codes (CBHCC) as part of engagement on draft policy directions for embodied GHGs for the National Model Codes. 

UDI has recommended that the embodied GHG standards do not move forward as they will only exacerbate the cost of delivery and affordability crisis we are facing in providing new homes to Canadians. They would also make it even more difficult for the Federal Government and the provinces to achieve their ambitious housing objectives.  

Rather than investing in these new requirements, UDI recommends that the CBHCC make substantive improvements to the current National Building Code (NBC) development process, as the Federal Government has prioritized this area. It would also be helpful if more resources could be applied to researching and codifying approaches to cost-effectively implement the new seismic provisions in the NBC. 

June 17th, 2025

The Canadian Board for Harmonized Construction Codes (CBHCC) is seeking input on a draft policy direction to address embodied greenhouse gas (GHG) emissions in new houses and buildings through future updates to the National Model Codes. This consultation is part of the first phase of work that will inform the development of technical requirements for the 2030 Codes. These requirements will be considered in the next BC Codes. 

UDI has previously submitted commentary to the CBHCC on regulating embodied carbon in building codes, recommending that the federal, provincial, and territorial governments look at other approaches to reducing embodied carbon emissions before regulating them through building codes. In the past, UDI has also advocated that the Broader Public Sector lead with improvements in energy efficiency and reducing carbon in new construction. For more information, please refer to UDI’s submissions from March 2023 and June 2023. 

To provide input, review the consultation materials available on the CBHCC website. Comments can be submitted by email to CBHCCSecretary-SecretaireCCHCC@nrc-cnrc.gc.ca. The consultation period is open until July 14, 2025. Comments will be reviewed by the CBHCC Working Group on Climate Change Mitigation, with recommendations forwarded to the CBHCC for consideration.