The Nordic region has long been a pioneer for life-cycle-oriented building assessments. A legal framework for disclosing life-cycle GHG emissions, with or without limit values, is planned to be introduced in all Nordic countries by the beginning of 2025. This means that all Nordic countries will probably have had at least two years of experience with mandatory national life-cycle regulation before the expected implementation of the revised Energy Performance of Building Directive (EPBD) with mandatory assessments for buildings greater than 1000 m2 in 2028, and all buildings in 2030. By 2027, EU member states must publish a roadmap for progressive carbon limit values for new buildings towards the EU climate neutrality goal in 2050. By 2030, binding carbon limits have to be introduced. With Denmark issuing the earliest limit values in 2023, and Sweden and Finland with plans to follow in 2025, all Nordic countries are preparing themselves to take the next step in order to exploit the climate protection potential of the building sector and initiate innovations.
Nordic countries currently exhibit different approaches to limit values. Harmonising methods is crucial for fair competition to mobilise the market to develop the most efficient low carbon solutions. Therefore, the following recommendations are proposed:
A cost-effective implementation strategy
There is an urgent need to reduce greenhouse gas emissions drastically in the Nordic countries if the countries are to reach the Paris Agreement. Limit values for the climate impact of buildings need to combine a high ambition level with a smooth adoption by the industry.
Currently, Denmark and Sweden are the Nordic countries with an implemented plan for how and when limit values are introduced into regulation and tightened progressively. Two distinct strategies are observed in order to facilitate the adoption of climate declarations and limit values at the time of their introduction. (a) First introduce a declaration without limit value, and then introduce a somewhat ambitious limit value a few years later (i.e. Swedish approach), or (b) introduce a limit value from the beginning alongside the climate declaration, but ensure that the limit value initially can be met by most "regular" building projects without particular efforts. Then, tighten the limit value over time (i.e. Danish approach).
Either way, it is particularly important for politicians to send a clear signal about future milestones of the building stock decarbonisation pathway (e.g. timeline and ambition level for future updates to the limit values). A cost-effective process of tightening the limit values should be established. If countries start with a limited scope (in terms of life cycle modules and building elements covered) and/or a limited number of building types and sizes, countries should also include milestones related to the expansion of the scope for the limit value, as in Sweden, for example.
Although Nordic countries serve as positive examples in the EU with respect to proactive and coordinated development of climate regulation for buildings to be consistent with the Paris Agreement, building stock decarbonisation pathways need to show a higher level of ambition than what is currently implemented or planned. In addition, limit values need to be tightened rapidly in order to mitigate climate impacts in the building sector.
Carbon limit differentiation per building type
Although Denmark so far has introduced one limit value for all building types, most recent limit value studies in both Sweden and Denmark show more obvious differences between several building categories. Nonetheless, it is expected that differentiation will be necessary at the point where limit values begin to put pressure on the way we build. It would be unreasonable to set the same limit value for building types that are already optimised and the types presenting a higher decarbonisation potential.
Carbon regulation of renovations
A great interest in learning more about the climate impact of deep renovations is observed in Nordic countries, with The Swedish National Board of Housing, Building and Planning (Swedish name: Boverket) proposing to include renovation projects in the climate declaration in Sweden from 2027. A stakeholder panel in Denmark has recommended a pathway for carbon regulation starting with climate declarations of larger renovations in 2025 and eventually leading to limit values by 2027. However, discussions and analyses are ongoing and no official policy for additional carbon regulation of renovations has been issued.
Building reference area
While Denmark, Norway and Sweden consider the gross floor area (GFA) as the reference area unit of climate declarations, with differences in how common facilities in multi-units and external spaces are considered, Finland and Estonia are applying the heated floor area (HFA). For uniformity with Level(s) and EPBD, the reference unit per m2 useful floor area should ideally be used in addition to the units currently determined in the various Nordic methods. Whether the definition of the useful floor area will be common among all EU countries, or there will be freedom in how to define it nationally is expected to be clarified by 2025 as part of the Delegated Act to be adopted by the European Commission. It is recommended that, in any case, the Nordics work towards harmonising this aspect by 2025, to be ready for an implementation by 2027 according to the EPBD.
Upfront carbon
The rationale for special attention to upfront emissions is firstly that this is the part of the life cycle that can be confirmed with real values at the building delivery. Second, it places the emphasis on reducing emissions today, not far in the future. Third, the ongoing transition of energy systems and industry towards low emissions means that future emissions are likely to be comparatively low. At the moment, Nordic countries use varying approaches for upfront carbon emissions. Sweden is the only country restricting the limit value scope to upfront carbon. As the Swedish limit value report proposes an extended declaration of remaining modules in 2027, the remaining Nordic countries could increase harmonisation by a separate declaration of upfront embodied carbon emissions in addition to the planned whole life carbon limit value. Upfront carbon declaration requires data developed after the latest EN 15804:2012+A2:2019 EPD standard. For those products, where updated data is not available, a temporary solution has to be developed for the remaining products declared after the old standard, where biogenic carbon is not declared separately.