if you were wondering, apparently the answer is
if test ! -f build/.mtime; then printf '%b' '\n' > build/.mtime; fi; touch -r "$FILE" build/.mtime; TZ=UTC0 diff -u build/.mtime /dev/null | sed '1!d;s/.*\t\([^ ]\) \([^ ]\).*/\1T\2Z/'
(replacing \t with a tab character)
BUT this requires version 7 of POSIX
BUT it should still work in e·g Macintosh even tho they’re not strictly conformant