1. A Review of European development

This section introduces and summarises the current situation and ongoing development regarding European regulations that aim at the common understanding and harmonisation of rules and principles applied towards the environmental LCA-based aspects related to buildings during their life cycle. These rules and principles may concern the assessment methods, quality of assessed and/or reported data, and regulations planned or set for reporting data or limit values. Other aspects to consider include requirements for typical GWP data and that their interoperability with relevant services, systems, and software can be ensured. In addition, the aim is also to consider how Nordic data can contribute to a potential EU-wide database if that will be asked for by the European Commission. The status of different initiatives, standards, and proposed regulations, as well as the needs and ways to implement a climate declaration for buildings in the Nordic countries, and potentially needed additional requirements are discussed and suggested in this report. Furthermore, the possibilities of contributing to a potential EU-wide database and thereby influencing EC are discussed.

European level
The new energy performance of buildings directive (EPBD) will set out a common methodology for the reporting of a so-called life cycle GWP indicator, expressed as kg CO₂e/m² (of the useful floor area) and averaged for one year of a reference study period of 50 years. The data selection, scenario definition, and calculations shall be carried out in accordance with the latest version of the rules outlined for a building LCA-based declaration (EN 15978) and the delegated act to be launched in 2025. The life cycle GWP indicator result for the building is, in the future, reported as part of the energy performance certificate that will be in force for all new buildings in 2027, and then in 2030, complemented by a limit value.

Besides the single life-cycle GWP indicator as part of the energy performance certificate, there is a mandatory ‘digital building logbook’ that asks for “all relevant building data, including data related to energy performance, such as energy performance certificates, … … , as well as on the life-cycle GWP and indoor environmental quality which facilitates informed decision making and information sharing within the construction sector, among building owners and occupants, financial institutions and public authorities.”

These legally noticed requirements and references given above should be followed when any methodology or scenario setting is suggested in this report. All such specifications developed in the overarching project “Nordic Harmonisation of Life Cycle Assessment” can then be seen as a Nordic contribution when the delegated act will be developed based on the suggested “inclusive stakeholder process”.

National level
It will be possible for an individual country to have complimentary requirements. The implementation of the directive in national laws, as for the current EPBD, needs interpretation and must be notified before it becomes law. Also, reporting the national progress is required by the directive and outlined in the EPBD for all Member States.

The calculation rules for environmental data based on a Life Cycle Assessment (LCA) for construction products are defined in the international standard ISO 21930 and its implementation in the European context in EN 15804. EN 15804 relates to the ISO family of standards of LCA, such as ISO 14044, providing general principals and requirements for life cycle assessments and ISO 14025 that provides the framework for Type III environmental declarations including EPDs. These standards are used to develop environmental product declarations (EPD) that include a third-party verified LCA used for market communication valid for products and services. Additionally, EN 15804 describes the so-called product category rules (PCR) for all construction products and services that are supplied to any building works during its life cycle. One important rule in an LCA is that the same calculation rules/methodology must be used in all parts of the assessed system. Nevertheless, it is noticed that the EN 15804 is also used for other product groups, especially in the programme operator systems held by EPD International and EPD Norway. Thus, the potential use of the methodology is, in practice, larger than construction products as such.

EN 15804 is developed based on a mandate for European standardisation (CEN TC350) from EC DG GROW.

European Commission DG Internal Market, Industry, Entrepreneurship, and SMEs (DG GROW).

In parallel, DG Environment has developed a likewise declaration called Product Environmental Footprint (PEF). This is a life cycle approach assessment methodology defined by EC Joint Research Centre (JRC). PEF methodology differs from EN 15804 with some respects. For example, a consequential allocation approach is used for process allocation (called direct substitution). Also, the circular footprint formula (CFF) is an integrated part of the LCA result in PEF, while in EN 15804, it is part of module D that shall be reported separately. Moreover, there is currently no published official PEF declared for any product. However, the PEF methodology is mandatory for climate declarations of batteries (Battery regulation); it has also been suggested as mandatory for limit values for solar photovoltaics (Ecodesign directive) and is planned to be used in future eco-design regulations. The idea that it shall be one common basis for the methodology setting is handled with the core product rules (EN 15804) in the EPD system and the PEF guidance document. To support further specification on individual products groups, the cPCR is developed in the EPD system and the PFCR in the PEF system. The lesson learned from applying the EPD system is that those methodology settings are sometimes not precise enough, and the cPCRs do not cover all matters needed to sort out for an individual product group. Another known drawback from the EPD system is that an individual programme operator may introduce methodology settings in their so-called general programme instruction (GPI), resulting in diverging calculation rules. It should be noticed that there is only one commission recommendation on the EF method resulting in one set of basic calculation rules valid for all EPD PEF-studies, where version EF 3.1 is the most current (see below).

To achieve more harmonisation between the two methods, a new mandate was given to CEN TC 350, and EN 15804 was updated and is now published as EN 15804:2012+A2:2019. As a result of this revision, the major change to EN 15804 was to use the same life cycle impact assessment (LCIA) categories as listed in PEF. Consequently, the environmental impact category indicators originally used in EN 15804 were replaced by the environmental indicators developed by PEF. This creates a similar likeness between the updated EN 15804 (amendment 2) and PEF since the same indicator result appears. However, the LCA result is not comparable since the same underlying inventory method is not used.

The characterisation methods and factors used for the LCA result in EN 15804 shall follow the latest version of the characterisation factors defined by EC JRC (see EN 15804 A2 section 6.5.2 Core environmental impact indicators). In practice, this implies that the characterisation methods and factors used for the LCA result can change whenever EC JRC decides, and is not decided by the CEN TC 350 standardisation working group that is responsible for the revision of all other parts of the standard EN 15804. Such frequent updates hinder full comparability between EPDs, and should therefore be limited as much as possible. The characterisation factors, valid by PEF in 2019 and updated in 2023, will be mandatory. As a consequence, EPDs from 2023 will be based on other characterisation factors for GWP than the EPDs used up to 2019 and the ones used between 2019 and 2023. The most up-to-date characterisation factor will be more in line with the original one used. The difference in the LCA result on a product level is just a few percentages.

In practice, there is a standstill in the development and potential revision of EN 15804 and DG Growth, as the CPR Acquis process is currently in the lead and needs to be finalised first (read more about CPR Acquis below). However, there is a complementary standard EN 15941 on data quality, which regulates data quality aspects concerning the LCA calculations and affects both the EPD for construction products (EN 15804) and on a building level (EN 15978).

On a general level, EC concludes that the “…existing harmonized technical specifications are mostly incomplete, as they are CPD-based (precursor to CPR) and fail to address the specificities of the CPR. To a large extent, they do not even cover most of the basic work requirements (BWR) set out in Annex I to the CPR”.

https://single-market-economy.ec.europa.eu/sectors/construction/construction-products-regulation-cpr/acquis_en

The ongoing CPR Acquis process can be seen in the light of this background, and to deal with some of the improvements already identified based in the existing legislation. Based on the current CPR, the CPR Acquis process will support the implementation of the forthcoming CPR. The CPR Acquis process has ranked all construction product families and started to develop new standardisation requests identifying all relevant essential requirements to be assessed for the declaration of performance, as part of the CE marking process. This work will define the requirements for a future generation of declarations of performance in accordance with the forthcoming CPR, taking into account all essential information required by the Member States, including a mandatory EPD for all harmonised constructions products. 

The CPR Acquis process will redefine the standardisation request that EN 15804 was based on, possibly leading to changes in the standard. Also, the revised and renewed harmonised product standards resulting from the CPR Acquis will be streamlined with this work. It may result in the future common mandatory EPDs restricting the use of some aspects that are currently used, or forbidding some aspect that is only allowed by some programme operators, such as biomass balancing approach and the use of green electricity certificates (or not). Per the timetable, most of the EPD specifications have been done in 2023 and the results will be presented in 2024. The so-called essential requirements that are mandated to be declared in an EPD are already set in the CPR Acquis process. Other aspects defined are, e.g. the modular approach for end-of-life scenarios, in order to create a flexible scenario setting on the building level. This approach is outlined in the 'Introduction to life-cycle scenario settings' section.

The proposal for the Ecodesign for Sustainable Products Regulation (ESPR) is an ambitious document that is part of a series of European Commission proposals seeking to redefine the business. This is in line with the European Union's vision for a more sustainable future as part of the European Sustainability Initiative. The ESPR broadens the scope of the current Ecodesign Directive by being applicable to all products, apart from food, feed, pharmaceuticals, and living things. The ESPR (COM(2022) 142 final) was proposed by the European Commission in March 2022, accompanied by a communication “on making sustainable products the norm” (COM(2022) 140 final). The ESPR proposal has been modified through the negotiation processes and is still to be adopted by the co-legislators, and the final text is not yet available. According to the ESPR, the design and content of the digital product passport (DPP) will be decided in delegated acts. The ESPR does not contain detailed information about indicators in the DPP – this is something that will be given by the delegated acts. 

For construction products, the new CPR will contain the elements of the ESPR and will therefore be considered lex specialis and the main legislation act. The ESPR will function as a safety net to ensure that the product information is required by ESPR. Both legislations require product information to be transmitted digitally in the form of a Digital Product Passport (DPP), which will be first developed within the context of the ESPR. The digital product passport (DPP) will include relevant information to improve products' circularity, energy performance, and other environmental sustainability aspects throughout the product life cycle. In practice, if the DPP in the future introduces a GWP indicator (or several LCA indicators) or any other essential information to be reported in the DPP (see list of items in Annex I), it must be followed by an amendment of the CPR and its EPD. If the building product EPD do not declare the essential information given in the ESPR, the construction material industry will have to declare both an EPD and the missing indicators in a DPP. It is important to note that according to the ESPR, it is enough to have the same LCA indicators as such, but not necessary based on the same underlying characterisation method/factors or inventory methodology. Thus, EN 15804 can still be used for construction products in the future, but the methodology for other product groups is undecided.

By this construction in the ESPR described above, it is still possible for CPR to use the LCI methodology that is based on international LCA standardisation in the future. However, this also means that the LCA indicator reported by the DPP will not necessarily be comparable with the same indicator used in the CPR EPD since the underlying inventory methodology including aspects, such as the allocation of an environmental impact, from a process differs. It should also be noted that it is most likely that the LCA methods used for DPPs will be found in the PEF (product environmental footprint), an approach that is only used within the regulatory context; no official declarations have been published, nor do they exist.

In regard to regulations including LCA-based information on any construction works, it will be problematic in the future that not all products used in the construction phase or during the rest of the building’s life cycle fall under the scope of the CPR and its EPD. For instance, the ESPR always applies to all energy-related construction products, fuels and energy wares are handled within other regulations, and likely when using PEF methodology to calculate the GWP indicator for such products. From a user's perspective, a question remains: can this be solved by the double reporting of indicator results for this kind of product that has an intended use related to several regulations?

The product category rules for buildings are defined in EN 15978, which is under revision. The extended revised standard will, to a great extent, be more precise and cover more aspects. The new standard is based on the experiences learned since the first version of the standard was published in 2011. As the updated EN 15978 standard is significantly improved, it is intended to provide the guidance requested by the market. Nevertheless, it is not published and therefore not potentially a source to refer to. However, the new version of the standard is supposed to impact methodology settings.

It should be noted that both the climate declaration, according to the forthcoming new EPBD directive, and Taxonomy refer to EN 15978 as a major reference. The reference to Level(s) is very limited and restricted to describe the scope of the inventory by listing the mandatory building parts to be considered in the calculations, as well as requirements for the approval of national calculation tools. Since the forthcoming version of EN 15978 will likely overrule the specifications made in Level(s), this system needs to be updated when EN 15978 is published to avoid conflict with the updated standard. Finally, it shall be recognised that the delegated act will specify the final details.

Level(s) is a common EU framework for buildings, aiming at creating “a common language creating a shared understanding of sustainability performance in buildings”. The Level(s) framework consists of six macro-objectives regarding sustainability, where the first objective addresses greenhouse gas emissions along a building’s life cycle. The indicators for this macro-objective are: 1.1 use stage energy, measured in kWh/m²/yr., and 1.2 life cycle global warming potential, measured in CO₂eq/m²/yr.

Nicholas Dodd, Shane Donatello, Mauro Cordella. 2021.  Level(s) indicator 1.2: Life cycle Global Warming Potential (GWP). JRC Technical Report. https://susproc.jrc.ec.europa.eu/product-bureau//sites/default/files/2021-01/UM3_Indicator_1.2_v1.1_37pp.pdf

The Level(s) indicator ‘1.2 life cycle global warming potential’ refers to the standard EN 15978:2011 and EN 15804 for LCA methodology settings when calculating the life cycle GWP of a building. In the EU Taxonomy, Level(s) refers to the scope of the building elements to account for in the inventory, as well as the requirements on calculation tools when a national calculation tool is unavailable. Other calculation tools may be used if they fulfil the minimum criteria laid down by the Level(s) common EU framework. It shall be noted that in all the Nordic countries (Denmark, Sweden, Norway, Finland, and Iceland), different tools can be used to calculate the GWP indicator, although specific calculations rules must be followed.

The included GWP indicators in Level(s) are: GWP fossil (1), GWP Biogenic (2), GWP-GHG (1+2), GWP-luluc (3), and GWP- Overall (1+2+3). The result should be presented as CO₂eq per m² useful internal floor area per year, the reference period being 50 years. It is permitted to omit the GWP-luluc as separate information if its contribution is <5 % of the GWP-total over the declared modules, excluding module D.

Initially, indicator 1.2 states that all the stages of a building’s life cycle should be included in the calculation (A1-A3, A4-A5, B1-B7, C1-C4, and D). However, two simplified options for calculating the life cycle GWP are also presented. The first option includes A1-A3, B4, B5, and-B6, whereas the second option includes A1-A3, B6, C3-C4, and D.

For a construction and real estate company to be aligned with the Taxonomy indicator “Climate mitigation”, a climate declaration for the whole life cycle for a building needs to be made. The activity applies to both construction companies and entities that commission a new building, meaning both residential and non-residential buildings. The requirement is part of the EU taxonomy technical screening criteria (‘TSC’) that are set out for certain economic activities to be considered as a substantial contribution to the objectives of climate change mitigation and climate change adaptation (referred to as Taxonomy-aligned activities). The economic activities should also do no significant harm to any other environmental objectives.

According to the taxonomy substantial contribution criteria for climate mitigation, in terms of GWP, the indicator needs to be calculated for buildings larger than 5,000 m². The calculation includes all stages in the life cycle and is disclosed to investors and clients on demand. This implies that the GWP is communicated as a numeric indicator for each life cycle stage. It is expressed as kg CO₂e/m² (of the useful internal floor area), averaged for one year of a reference study period of 50 years (the same as the draft EPBD directive climate declaration; see below).

For data collections, scenario definitions, and calculations, the taxonomy refers to EN 15978:2011. The scope of the building elements and technical equipment, as defined in Level(s), shall be applied (see list of building elements in Table 2). Moreover, the taxonomy states: “where a national calculation tool exists or is required for making disclosures or for obtaining building permits, the respective tool may be used to provide the required disclosure. Other calculation tools may be used if they fulfil the minimum criteria laid down by the Level(s)". The approach is thereby the same as the EPBD directive.

In 2022, it was required to report “eligibility” to the Taxonomy requirement. In practice, this means that it was enough to state if the knowledge to perform a climate declaration exists. From this year (2023), it is needed to show “alignment” to all technical requirements. For affected companies, this means, according to the authors’ understanding, that the GWP indicator required in Taxonomy Section 7 needs to be calculated.

In December 2021, the European Commission published a proposal for a revised Energy Performance of Buildings Directive (EPBD), as part of the ‘Fit for 55’ package.

The Council made its decision on the general direction in October 2022 (‘Fit for 55’: Council agrees on stricter rules for energy performance of buildings - Concilium (europa.eu).

The latter consists of several legislative proposals to meet the new EU objective of a minimum 55% reduction in greenhouse gas (GHG) emissions by 2030 compared to 1990. It is a core part of the European Green Deal, which aims to set the EU firmly on the path towards net zero GHG emissions (climate neutrality) by 2050.

In 2023, a final agreement was reached in the new EPBD directive, and the following aspects were added:

The EPBD climate declaration GWP indicator for the building is defined as: 1) life cycle GWP indicator, expressed as kg CO₂e/m² (of the useful floor area) and averaged for one year of a reference study period of 50 years. It is mentioned in the new EPBD directive that a public database including the performance of buildings will be established. Moreover, it is explained that “in order to populate the database, building typologies may also be gathered. Data may also be gathered and stored on both operational and embodied emissions and overall life cycle GWP". Besides the life cycle GWP indicator, the yearly GWP indicator result for the operational energy shall also be reported in the declaration expressed as: 2) “operational greenhouse gas emissions (kg CO₂e/(m² y)”. See EPBD, Annex V.

Another indicator result that may be reported is: 3) “information on carbon removals associated to the temporary storage of carbon in or on buildings”. The new EPBD also addresses: 4) a ‘digital building logbook’ that means “… a common repository for all relevant building data, including data related to energy performance, such as energy performance certificates, renovation passports and smart readiness indicators, as well as on the life cycle GWP, which facilitates informed decision-making and information-sharing within the construction sector, among building owners and occupants, financial institutions and public bodies”.

In the new EPBD directive (see Annex III in the directive), it mentions that EN 15978 is the core LCA methodology to be applied for the building life cycle GWP indicator:

“The data selection, scenario definition and calculations shall be carried out in accordance with EN 15978 (EN 15978:2011) and taking into account any subsequent standard relating to the sustainability of construction works and the calculation method for the assessment of environmental performance of buildings”.

For two specific matters, Level(s) is also addressed in Annex III. The first reference concerns the scope of the building elements to be accounted for in the inventory of a building as a whole. The second matter in reference to Level(s) on the new EPBD directive is: “…where a national calculation tool exists, or is required for making disclosures, or for obtaining building permits, that tool may be used to provide the required disclosure. Other calculation tools may be used if they fulfil the minimum criteria laid down by the Level(s) common EU framework”.

Another take from the new EPBD is that a window of opportunity exists, now before the delegated act is published, to influence how the common calculation rules for the climate declaration shall be defined on information asked for on a product level, as outlined below (the EPBD Annex I):

“Where product-specific regulations for energy-related products adopted under Regulation 2009/125/EC include specific product information requirements for the purpose of the calculation of energy performance and life cycle GWP under this Directive, national calculation methods shall not require additional information”.