• Yesterday’s proposal fails to fully address environmental impacts from buildings, warn ECOS and the EEB.
• New rules will not be enough to decarbonise the buildings sector at the rate required to reach 2050 climate objectives
• The EPBD should contribute to the success of the Renovation Wave, but is missing thresholds on whole life carbon emissions. Embodied impacts from building materials and renovation solutions have been overlooked.
The European Commission presented yesterday its proposal for a revised Energy Performance of Buildings Directive (EPBD) , which will drive renovation and improvements in buildings’ energy performance.
With this proposal, the Commission is stepping up its ambition regarding the energy performance of buildings under the Renovation Wave with an increase of scope to include CO2 emissions. However, despite the target of achieving ‘zero emissions buildings’, the proposal only sets minimum requirements for emissions from the use phase of buildings, ignoring the other life cycle stages. Revision or expansion of this definition is needed to ensure clarity and credibility of the EPBD.
By 2030, member states will need to introduce requirements for new buildings to incorporate the measurement of lifecycle emissions – but no EU-limits on these emissions were set. This means the Renovation Wave will be implemented without considering embodied emissions originating from the construction, demolition and wider supply chain  in its quest for net-zero by 2050.
The current proposal favours quick and cost-effective renovation in the short-term, rather than setting a path for long-term sustainability looking at whole life carbon impacts. The legislative text is also missing requirements relating to strategies for tackling embodied carbon, only briefly mentioning circularity and resource efficiency, which should be assessed in the same vein as energy efficiency technologies. Overall, greater structure and a clear timeline for regulating and limiting Whole Life Carbon is needed today.
Measuring impacts and taking action now
In terms of measuring lifecycle carbon emissions, ECOS and EEB welcome the use of LEVEL(s) to measure lifecycle Global Warming Potential (carbon emissions), but more is needed in terms of EU principles on carbon accounting for buildings which should be enshrined in legislation. For example, the EU should establish a mandate and approach to measure, report, limit, and drive down lifecycle carbon emissions of all buildings. As a result, evaluating and capping lifecycle emissions of existing buildings will be left to member states to prioritise, with only a handful considering lifecycle carbon measures domestically.
In Europe, the use of buildings accounts for around 40% of energy consumption and 36% of CO2 emissions . And this is just the operational impact of buildings: globally, 11% of emissions come from embodied carbon . Total lifecycle emissions of buildings need to be halved by 2030 to keep us on track  for 2050.
ECOS and the EEB call on policymakers to bolster the current legislative proposal in the co-decision process by putting whole life carbon impacts front and centre in this revision, including key strategies to cut emissions such as circularity and resource efficiency, and establishing whole life carbon emissions thresholds on the way to 2050.
Michael Neaves, Programme Manager at ECOS – Environmental Coalition on Standards, said:
‘The Commission has given carte blanche to CO2 emissions from non-use stages of a building’s life cycle. The EU should look at the life cycle as a whole, and set requirements for clear limits to be set on its carbon levels this decade. The time is now to couple energy-efficiency and lifecycle to maximise the environmental benefits of renovation´.
Gonzalo Sanchez, Policy Officer for Circular economy and Carbon neutrality in the Building sector at the European Environmental Bureau (EEB), said:
‘Circularity is an essential tool to decarbonise our built environment, and a principle of the Renovation Wave which must be effectively included in the EPBD with no further delay. The renovation of European buildings is a once in a lifetime opportunity that we cannot miss. It is already happening, and it involves a huge amount of construction materials: if we don’t consider circularity now, we’ll have a huge increase in product related emissions today, and a waste problem in the future’.
 Meanwhile, the forthcoming Construction Products Regulation is expected to rely upon building policies to create demand for lower-carbon solutions. The policy gap here is striking and may only be tackled in 2030 following the next revision of the EPBD.
 Own calculation based on UNEP GlobalABC 2021 status report. https://www.unep.org/resources/report/2021-global-status-report-buildings-and-construction
 The UNEP GlobalABC 2021 status report stated that by 2030 the total CO2 figure needs to be halved, with at least a 40% reduction in embodied emissions. This will be impossible without a unilateral requirement for Member States to limit this figure.