Introducing embodied carbon regulation across the EU
The European Parliament Committee on Industry, Research and Energy (ITRE) voted in favour of the draft text of the Energy Performance of Buildings Directive recast on the 15th January, which includes requirements around whole life carbon assessments and limits. This blog post summarises the key points of the proposal, which is closely aligned with the requirements set out in Part Z.
The proposed directive recognises that to decarbonise the built environment by 2050, “whole life-cycle emissions of buildings should […] be taken into account, starting with new buildings”. For these, it sets out the following requirements in Article 7:
WLC assessments shall be conducted, “as of 1 January 2028, for all new buildings with a useful floor area larger than 1000m2” and “as of 1 January 2030, for all new buildings”.
National methodologies for calculating WLC shall be permitted pursuant to Annex III, however the Commission reserves the right “to set out a Union framework for the national calculation of [WLC…] by 31 December 2025”.
“By 1 January 2027, Member States shall publish and notify to the Commission a roadmap detailing the introduction of limit values on [WLC for new buildings] from 2030, considering a progressive downward trend”. Article 25 further indicates that the Commission will review these submissions in 2028 to check that they are sufficiently ambitious.
While the directive would limit these requirements to new-build projects, it emphasises the importance of curbing the carbon emissions of renovation projects too “through the inclusion of policies for the reduction of whole life-cycle greenhouse gas emissions in Member States’ building renovation plans”. However, this remains an optional measure for implementation by each Member State.
The vote follows the European Commission submitting the proposal to, and it being provisionally approved by, both EU law-making bodies (the Council of the European Union and the European Parliament) in December 2023. If approved, the EPBD recast would represent a clear policy signal for the EU construction industry and Member States would need to draw up a plan for compliance with the directive by 1st January 2025.
It would also serve as a wakeup call to the UK construction industry, whose equivalent proposal - Part Z - pushes for a more ambitious timeframe (2 years’ earlier adoption than EPBD) but is yet to be adopted by the Government (see Part Z blog post on LURB). The Part Z authors remain available to advise and support UK policymakers in advancing embodied carbon regulation.
