The Kimchi Principle

IN 2013, Seoul had a kimchi problem. Or rather, a food waste problem, of which kimchi formed a considerable part. The South Korean capital was dumping 3,800 tonnes of food waste liquids into the sea every day. Landfill was banned. And so something had to change.

The city’s solution was to make residents pay for food waste by weight. Seoul installed 6,000 automated bins fitted with scales and radio-frequency identification readers. Each household received an electronic ID card. Every deposit was weighed, timestamped, and billed. Within six years, the system had cut food waste by 47,000 tonnes. Recycling rates went from 2% to 95%.

But here is what nobody planned. To charge citizens by the gram, Seoul had to build a city-wide digital tracking infrastructure: unique identifiers for every household, real-time weight data at point of disposal, automated billing, and a complete chain of custody from kitchen to processing facility. The city set out to reduce food waste. What it actually built was a material passport system for an entire urban waste stream. Every kilogram traceable, documented, and digitally accounted for.

The infrastructure was the unintended consequence. And it turned out to be more valuable than the policy that created it.

Regulation as accidental industrial policy

Seoul’s experience illustrates something that repeatedly plays out in cities around the world. Regulation designed for one purpose creates the institutional infrastructure for something entirely different. The policy intent and the structural consequence diverge. And the consequence, because it was never the subject of political debate, arrives without opposition. The mechanism is consistent: specify an outcome, leave the method open, and watch which production system finds compliance easiest.

We see this happening right now in construction. In multiple locations, policies designed for environmental, safety, or labour welfare purposes are creating conditions that structurally favour factory-produced buildings. Not because anyone intended it. Because the compliance requirements, the precision, the documentation, the traceability, are things that factory production delivers naturally and that traditional site-based construction struggles to provide.

For example, in Oslo, the city mandated zero-emission construction machinery on all municipal sites from January 2025. The policy was about air quality, recognising that construction equipment accounted for nearly 14% of the city’s total emissions. By 2023, 77% of machinery on municipal sites was electric.

The unstated consequence was to push work offsite. A temporary construction site with limited grid capacity faces a fundamentally harder problem electrifying its equipment than a permanent factory with a grid connection. The site has to fight for a connection. An existing factory however can comply overnight. Oslo’s air quality policy was, in effect, a subsidy for offsite manufacturing. Nobody designed it that way. Nobody noticed, either.

The Netherlands tells a similar story through different machinery. The MPG system, mandatory since 2018 for all new residential buildings, expresses environmental performance as a shadow cost per square metre over 75 years. The limit is tightening from 1.0 toward 0.5. Factory-produced components with verified Environmental Product Declarations hold a structural scoring advantage that widens every time the threshold drops. When the government layers on tax incentives requiring materials to be registered on Madaster, a digital platform that tracks the composition and reuse potential of building materials, an environmental performance standard becomes, in practice, industrial policy for factories.

The countries that have successfully industrialised construction have more than often not directly set out to do so. They set standards for intended outcomes that lead factory production to become the only rational compliance pathway.

The UK’s Seoul moment

The Construction Products Reform White Paper, published in February 2026 with a consultation running until 20 May, is a significant piece of construction regulation. It proposes to bring all construction products within the regulatory regime, tripling the number currently covered. It mandates digital product information via unique identifiers and QR codes. It proposes a construction product library as a central repository and explicitly commits to aligning with the EU’s revised Construction Products Regulation, which mandates Digital Product Passports from 2026 onward, with full coverage by 2032.

The White Paper is focused on safety. It is a response to Grenfell, to the Hackitt Review, to the Morrell-Day Review.

The policy intent is clear but it has implications upon how the sector managed information.

It requires unique digital identifiers for every construction product. Machine-readable data on composition, performance, and provenance. A national product library linking manufacturer data to regulatory records. Alignment with an EU framework that demands lifecycle environmental data alongside safety data. The General Safety Requirement, expected to be in force by late 2027, will apply to products that currently sit entirely outside the regulatory perimeter.

This is Seoul’s food waste bins for construction products. The government is building a digital tracking infrastructure for the built environment, not directly to enable industrialised construction, but because the safety accountability system demands it. And just as Seoul’s billing mechanism accidentally created a material passport system, the CPR reform’s traceability requirements might accidentally create the data architecture that factory production needs to scale.

The reforms specify what a product must prove about itself, not how it should be made. However when a product is manufactured in controlled conditions, its composition should be known. For a product assembled on a traditional construction site from multiple sources, with fragmented documentation, creating the same data trail is an additional cost.

The CPR reform doesn’t mention industrialised construction. It doesn’t need to. The data infrastructure it demands is one that factory production generates for free and site production has to pay for.

Sealed cans without a can opener

We have previously written about how digital Kit of Parts, the Building Safety Act’s Golden Thread, digital planning reforms, are being built in isolation from the others. Digital planning currently doesn’t feed Building Control. The Kit of Parts templates aren’t connected to the Golden Thread. Product data often sit outside BIM models and BSR portals.

However the CPR reform could change this. If every construction product must carry a digital identity with machine-readable performance, composition, and provenance data, then the CPR’s product library could begin to connect the Kit of Parts (which defines what the components are), the Golden Thread (which tracks them through life), digital planning (which approves their use), and demand aggregation models (which create the order volumes to justify manufacturing investment).

The interface layer we have argued is missing may indirectly be about to arrive. Not from the industrialised construction community. From the building safety regulators.

The quiet convergence

Before we get too far ahead of ourselves, we are conscious that data infrastructure will only shift the sector so far. The historic failure of volumetric manufacturers  for example was not caused by a lack of digital systems but by a combination of business issues, not least a lack of demand certainty.

That said, the regulatory preconditions for industrialised construction are assembling themselves, without anyone having to win the political argument for factory-built housing directly. The Future Homes Standard tightens fabric performance. The Building Safety Act demands design fixity and information management. Part Z, or something like it, will eventually mandate embodied carbon assessment. The CPR reform will require digital product traceability. Each of these, independently, creates competitive advantage for manufactured precision over site-based variability.

The trouble is that these policies are being developed in silos,, with no overarching recognition that their cumulative effect is to create the conditions for a fundamentally different construction industry. Seoul didn’t realise it was building a material passport system. Oslo didn’t realise it was subsidising offsite manufacturing. The UK may not yet realise that its post-Grenfell safety reforms are assembling the data backbone for industrialised, circular housebuilding.

The CPR consultation is open until 20 May. The questions it asks are about safety accountability, testing regimes, and regulatory alignment with the EU. They are not about industrialised construction. But the industrialised construction community should be ensuring that the infrastructure being designed is compatible with manufactured production: open enough to serve safety, sustainability, and productivity simultaneously, and flexible enough to connect to the Kit of Parts, the Golden Thread, and the material passport systems that circular economy regulation will demand within the decade. The can opener is being designed right now. The people who make the cans need to be in the room.

The countries that industrialised construction did not mandate factories. They mandated outcomes that factories were best placed to deliver. That is the kimchi principle: specify what you want to achieve, not how to build it, and the production system reorganises itself.

Seoul built its tracking infrastructure to weigh leftover kimchi. It turned out to be worth far more than that. The UK is building its to trace fire doors and cladding panels. It could be worth far more too.

But kimchi ferments on its own. Policy infrastructure does not.