Cont Why OperationalCarbon Is NoLonger Enough UnderstandingEmbodied Carbonin CommercialReal Estate Scope 3 Emissions:The HiddenMajority StakeholderImpacts: WhyEmbodied Carbonand Scope 3 Matterto Everyone _P.18 _ ents Regulatory andPolicy Direction:The ChineseMainland and GlobalAlignment8 MeasurementFrameworks,Data, andMethodologies57 Market Implicationsfor Leasing,Capital Markets,Asset Value andExit Strategies Strategies toReduce EmbodiedCarbon and Scope3 Emissions EXECUTIVESUMMARY For more than a decade, carbon reduction strategies in the commercial real estate sector havefocused overwhelmingly on operational emissions – energy consumed during a building’s use phase.While this focus has delivered measurable improvements in energy efficiency and operationalperformance, it now represents a carbon blind spot. On the Chinese mainland, where developmentvolumes, capital recycling, and asset repositioning remain structurally significant, embodied carbonand Scope 3 emissions increasingly dominate a building’s total carbon footprint. Embodied carbon – emissions associated with the extraction, manufacture, transport, installation,maintenance, and disposal of building materials – can account for 30–70% of a commercial building’swhole-life carbon emissions, depending on asset type, construction method, and lifespan. Whencombined with Scope 3 emissions across investment portfolios, tenant operations, and supply chains,these “indirect” emissions often exceed operational (Scope 1 and 2) emissions by a substantial margin. On the Chinese mainland, this challenge is amplified by several structural factors, including: A large stock of relatively young but functionally dated commercial buildings – given therapid advancement of construction quality and installed building technology; High levels of demolition and redevelopment, particularly in Tier 1 and core Tier 2 cities; Capital markets increasingly aligned with global environmental, social, and governance (ESG)frameworks, even where some local disclosure requirements remain varied, and; Multinational occupiers applying global net-zero commitments to Chinese mainland-basedportfolios. As a result, on the Chinese mainland, embodied carbon and Scope 3 emissions are rapidly becomingmaterial financial and strategic issues rather than purely environmental considerations. Investors facegrowing scrutiny, operating landlords must respond to tenant demand for low-carbon space whilebalancing refurbishment costs and asset value, and developers are under increasing pressure to justifydemolition-led strategies. At the same time, tenants are recognising that leased space often representstheir largest single source of reported emissions. This report draws on a series of case studies carried out by Cushman & Wakefield, demonstrating howembodied carbon and Scope 3 considerations are being applied in practice across new developments,refurbishments, and asset repositioning projects. These examples provide insight into actionablestrategies that materially influence investment, design, and operational decisions. With this understanding, the commercial property sector on the Chinese mainland has reached acritical inflection point. Managing embodied carbon and Scope 3 emissions is no longer optional. Itis central to: Accessto capitaland greenfinancing Buildingregulatorypreparedness Assetvaluationand liquidity Leasingcompetitiveness Long-termportfolioresilience In conclusion, the most successful market participants will be those who move early – embeddingwhole-life carbon thinking into investment decisions, design choices, leasing strategies, and assetmanagement practices, rather than treating embodied carbon as a future compliance issue. WhyOperationalCarbon Is NoLonger Enough While operational carbon has long been the focus of buildingsustainability efforts, rising awareness of embodied emissionsshows that managing a building’s full lifecycle impact is essentialfor meaningful decarbonisation. THE LIMITS OF THE OPERATIONALCARBON PARADIGM Operational carbon – emissions fromheating, cooling, lighting, and poweruse – has historically been the easiestcomponent of building emissions tomeasure and manage. On the Chinesemainland, policy initiatives such as greenbuilding standards, minimum energyperformance requirements, and buildingenergy disclosure pilots have reinforcedthis focus. Figure 1: Embodied and Operational CarbonEmissions However, this approach is increasinglymisaligned with reality. As operationalefficiency improves through betterbuilding systems, smart technologies,and grid decarbonisation, the relativeshare of embodied carbon rises sharply. Inhighly efficient office buildings, embodiedcarbon can represent the majority of totallifecycle emissions within the first 20–30years of operation (Figures 1 and 2). This shift has profoundimplications for commercialproperty markets on theChinese mainland, where: Buildings areoften redevelopedor substantiallyrefurbished