This chapter takes a deep dive into four countries that have adopted a step-by-step approach to address whole life carbon of buildings: Denmark, Finland, France, and Sweden. It highlights lessons from each country’s strategy in terms of system boundaries, types of regulated buildings, and policy instruments. A common pattern includes the fact that each country set the reduction of whole life carbon as a priority, considered the degree of feasibility in light of its specific conditions, and supported these regulatory changes through overarching climate acts.
Zero-Carbon Buildings in Cities

3. Spotlight on step-by-step whole life carbon policies at national level
Copy link to 3. Spotlight on step-by-step whole life carbon policies at national levelAbstract
Introduction
Copy link to IntroductionAs highlighted in the OECD report Global Monitoring of Policies for Decarbonising Buildings: A Multi-level Approach (2024), a step-by-step approach to decarbonising buildings consists in pursuing long-term transformations by breaking down complex challenges into manageable steps. As opposed to sudden overhauls or inaction, this incremental approach offers the flexibility to adapt to new developments and introduces regulatory measures progressively, allowing each phase to build momentum, refine strategies, and expand efforts. Clear, ambitious goals with measurable targets should guide this process, starting with simpler tasks.
The OECD Global Survey on Whole Life Carbon of Buildings identified the development of databases as the most resource-intensive task in implementing whole life carbon policies, followed by the development of methodologies, development of regulations, as well as research and data collection, as shown in Figure 3.1. This suggests that the primary challenges associated with whole life carbon policies are concentrated in the preparatory phase, particularly during the policy development stage. For example, France required approximately six years to implement limit value regulations after initiating the preparatory phase with E+C- in 2016, a state-funded voluntary certification label that marked the first introduction of LCA. Similarly, Finland's initial step began in 2019 by drafting LCA methodology, and it plans to introduce mandatory reporting and limit value regulations by 2025, marking a preparatory phase of approximately six years (Nordic Sustainable Construction, 2024[1]). The duration of the preparatory phase varies by country, however, the majority require several years before the implementation of regulatory measures to develop methodologies and database, collect necessary data for assessment, as well as test industry’s capacity for the coming regulations.
Figure 3.1. Resource-intensive tasks in WLC policy development and implementation
Copy link to Figure 3.1. Resource-intensive tasks in WLC policy development and implementation
Note: Question from the survey: “Which of the following do you think would be the essential tasks in the development and implementation of whole life carbon policies for buildings that requires more resources (e.g. cost, time and efforts)?” The responding countries and cities could select three applicable options.
Source: OECD Global Survey on Whole Life Carbon of Buildings (2024)
A long-term roadmap with milestones, timelines, and monitoring mechanisms ensures that progress is tracked, and adjustments are made as needed. This approach also fosters more effective stakeholder engagement by delivering tangible results and incorporating feedback at each stage. By setting measurable benchmarks and timelines for implementing regulations such as climate reporting and emissions limits, the roadmap fosters co‑ordinated action and accountability among stakeholders, reduces uncertainty, and encourages investment in sustainable practices. It serves as a clear guide for policy makers, developers, architects, contractors, and suppliers, aligning industry efforts and building confidence to achieve WLC reduction in buildings. Its adaptability allows stakeholders to respond to new challenges and innovations, making it an effective tool for aligning industry efforts toward achieving long-term carbon reduction goals in buildings. This is why several countries have been developing a roadmap for WLC policies, as illustrated in Figure 3.2.
Figure 3.2. Roadmaps to reduce whole life carbon in leading countries and cities
Copy link to Figure 3.2. Roadmaps to reduce whole life carbon in leading countries and cities
Note: Adapted from “Timeline of climate declaration and limit values integration (as of June 2024)” by Nordic Sustainable Construction. ‘Leading countries’ are defined as countries and cities that have already implemented whole life carbon regulations, drawn from the OECD report on Global Monitoring of Policies for Decarbonising Buildings.
Source: OECD Global Survey on Whole Life Carbon of Buildings (2024); OECD Global Monitoring of Policies for Decarbonising Buildings, https://www.oecd.org/en/publications/global-monitoring-of-policies-for-decarbonising-buildings_d662fdcb-en.html; Nordic Sustainable Construction (2024), https://www.nordicsustainableconstruction.com/Media/638530156105505088/Nordic%20Timeline%20regulations%20updated.pdf
The benefits of such a stepbystep approach apply directly to policies addressing WLC of buildings. When adopting a roadmap to tackle emissions across a building’s entire life-cycle, identifying the first step is an essential foundational decision that shapes the rest of the decarbonisation journey.
The OECD Global Survey on Whole Life Carbon suggests that three key elements are critical in defining the first step of WLC policies: system boundaries, types of regulated buildings, and policy instruments. Table 3.1 categorises various step-by-step approaches into four distinct groups and provides a mapping of associated countries and cities.
System boundaries refer to each phase of a building’s life-cycle, including raw material extraction (A1-A3), transportation (A4), construction (A5), operation (B1-B7) and eventual demolition and disposal (C1-C4).
Types of regulated buildings categorise buildings into groups such as residential, commercial, office, public buildings, etc.
Policy instruments include measures such as climate declarations (climate impact reporting) and limit values for carbon emissions.
Table 3.1. Categorisation of the first step in step-by-step WLC approaches
Copy link to Table 3.1. Categorisation of the first step in step-by-step WLC approaches
Country/City |
Denmark |
France |
Greater London (the United Kingdom) |
Sweden |
---|---|---|---|---|
System boundaries |
Whole life carbon |
Whole life carbon |
Whole life carbon |
Upfront carbon only |
Policy instruments |
Mandatory reporting + limit values |
Mandatory reporting + limit values |
Mandatory reporting only |
Mandatory reporting only |
Types of regulated buildings |
Limit values for buildings above 1 000m2 and mandatory reporting for buildings below 1 000m2 were introduced in 2022, |
Limit values were first introduced for housing, office and school buildings in 2022. |
The Greater London Authority introduced mandatory reporting on the mayor’s referable development projects since 2021. |
Mandatory climate reporting was introduced in 2022 for all new buildings, excluding industrial facilities and workshops, agricultural buildings for farming, forestry or other similar enterprises, buildings that do not have a gross floor area larger than 100 square metres. |
Countries and cities with similar approaches |
Finland |
Helsinki (Finland), Vancouver (Canada) |
Source: Boverket (2020), “Regulation on climate declarations for buildings”, https://www.boverket.se/globalassets/publikationer/dokument/2020/regulation-on-climate-declarations-for-buildings.pdf; Danish Authority of Social Services and Housing (2024), “National strategi for bæredygtigt byggeri”, https://www.sbst.dk/byggeri/baeredygtigt-byggeri/national-strategi-for-baeredygtigt-byggeri; Greater London Authority (2022), https://www.london.gov.uk/sites/default/files/lpg_-_wlca_guidance.pdf; Ministry of Ecological Transition and Territorial Cohesion (2021), “Règles générales pour le calcul de la performance”, https://rt-re-batiment.developpement-durable.gouv.fr/IMG/pdf/annexeii_arrete_4_aout_2021.pdf; Ministry of the Environment of Finland (2019) Method for the whole life carbon assessment of buildings; City of Vancouver (2023), https://vancouver.ca/files/cov/embodied-carbon-guidelines.pdf
This chapter takes a deep dive into four countries that have adopted a step-by-step approach to address WLC of buildings: Denmark, Finland, France, and Sweden. It highlights how each country’s unique context, including existing laws and available resources, has shaped its strategy to reduce the environmental impact of the building sector (Table 3.2). In each case, an overarching climate act has served as a critical foundation for implementing new regulations. Each country has then identified feasible, high-impact first steps and established phased plans for continued progress.
Table 3.2. Overview of step-by-step whole life carbon policies in Denmark, Finland, France, and Sweden
Copy link to Table 3.2. Overview of step-by-step whole life carbon policies in Denmark, Finland, France, and Sweden
Denmark |
Finland |
France |
Sweden |
|
---|---|---|---|---|
System boundaries |
A1-A3, B4, B6, C3, C4 and D |
A1-A5, B3-B4, B6, C1-C4, D (handprint separately) |
Entire module except for B8 |
Upfront carbon (A1-A5) only |
Types of regulated buildings |
All new buildings |
New buildings of the following: (1) terraced houses; (2) apartment blocks; (3) office buildings and health centres; (4) commercial buildings, department stores, shopping centres, wholesale and retail trade buildings, market halls, theatres, opera, concert and conference buildings, cinemas, libraries, archives, museums, art galleries and exhibition venues; (5) tourist accommodation buildings, hotels, residential homes, senior housing, residential care homes and medical care institutions; (6) educational buildings and kindergartens; (7) sports halls; (8) hospitals; (9) storage buildings, transport buildings, swimming pools and ice rinks with a net heated area of more than 1 000 square metres. |
New Housing, office and school buildings |
All new buildings excluding: (1) buildings with temporary building permits (2) buildings used for industrial facilities and workshops (3) agricultural buildings for farming, forestry, or similar enterprises (4) buildings with a gross floor area not exceeding 100 square metres (5) buildings intended for total defense purposes and those critical to Swedish security (6) buildings developed by private individuals not constructing as part of a business (7) buildings where the developer is a designated public authority |
Policy instruments |
1,000 m²<: limit values (2022~), <1,000 m²: mandatory reporting (2022) *limit values in 2025 |
Climate reporting, limit value (2026 ~) |
Limit values (2022~) |
Mandatory reporting (2022~) *limit values planned in 2027 |
Source: Boverket (2020), “Regulation on climate declarations for buildings”, https://www.boverket.se/globalassets/publikationer/dokument/2020/regulation-on-climate-declarations-for-buildings.pdf; Danish Authority of Social Services and Housing (2024), “National strategi for bæredygtigt byggeri”, https://www.sbst.dk/byggeri/baeredygtigt-byggeri/national-strategi-for-baeredygtigt-byggeri; Ministry of Ecological Transition and Territorial Cohesion (2021), “Règles générales pour le calcul de la performance”, https://rt-re-batiment.developpement-durable.gouv.fr/IMG/pdf/annexeii_arrete_4_aout_2021.pdf; Ministry of the Environment of Finland (2019) Method for the whole life carbon assessment of buildings; EDUSKUNTA RIKSDAGEN (2024) https://www.eduskunta.fi/FI/vaski/HallituksenEsitys/Sivut/HE_101+2024.aspx;
A shared vision: Denmark’s multi-stakeholder model
Copy link to A shared vision: Denmark’s multi-stakeholder modelRelevant law
In 2019, the Danish parliament passed a new climate law, which came into effect in 2020 and set an ambitious goal of reducing GHG emissions by 70 % from 1990 levels by 2030, with the broader aim of reaching carbon neutrality by 2050 (Danish Ministry of Climate, Energy and Utilities, n.d.[2]). The law mandates regular updates to achieve this target. This includes notably setting legally binding emission reduction targets every five years, with each new target looking ahead to the next ten years. Moreover, each new target must be at least as ambitious as the previous one, ensuring a continuous push towards lower emissions. These targets will be advised by the Danish Council on Climate Change, an independent body of experts from fields relevant to climate policy, including energy, transport, agriculture, environmental sciences, and behavioural research. This Council provides impartial, expert recommendations to guide Denmark’s ongoing climate efforts and ensure compliance with its long-term climate objectives (Danish Ministry of Climate, Energy and Utilities, 2020[3]).
In response to the targets, the Danish government has to develop annual Climate Action Plans that outline concrete policies to reduce emissions for each sector: energy, housing, industry, transportation, energy efficiency, agriculture and land use change and forestry (Danish Ministry of Climate, Energy and Utilities, n.d.[2]).
Public-private climate partnerships
In spring 2020, 13 climate partnerships, each composed of companies within a specific sector in Denmark, submitted reports outlining their ambitions for a green transition. The reports also included recommendations for political actions to support companies in their efforts to mitigate climate change. The government has then worked with businesses to develop sectoral roadmaps for each climate partnership, combining government initiatives and private sector strategies into a unified plan.
In 2021, the climate partnership for building and construction released a sector-specific proposal to reduce CO2 emissions by 2030. Among its recommendations, the report notably proposed mandatory CO2 accounting for buildings. All new buildings should have a calculated CO2 footprint per square meter, with specific requirements introduced in the building regulations by 2023 and regularly updated until 2030. Additionally, it suggests a voluntary, more ambitious standard for construction companies that wish to exceed the regulatory requirement set for 2023 (Regeringens Klimapartnerskaber, 2021[4]).
Reference value study
The Danish Department of the Built Environment (BUILD) prepared a study report in 2019 as it was commissioned by the Danish Transport, Construction, and Housing Authority to research WLC assessments of buildings. The goal of the study was to establish a knowledge base to set benchmark values for building emissions. The research analysed 60 buildings constructed between 2013 and 2021 from DGNB-certified projects – buildings that met rigorous sustainability standards set by the Deutsche Gesellschaft für Nachhaltiges Bauen (DGNB), or German Sustainable Building Council – as well as LCAs conducted by BUILD. The study examined reference lifespans of 50 years and 80 years.
For the 50-year period, the analysis revealed significant variation in Danish buildings’ GWP, with impacts ranging from 6.45 to 14.52 kg CO2 eq/m²/year, as some buildings had up to 2.25 times greater emissions than others. Construction material impacts were consistently higher than operational energy impacts. While material emissions ranged from 3.67 to 10.84 kg CO2 eq/m²/year, operational emissions were typically 2-4 times lower, ranging from 0.22 to 4.58 kg CO2 eq/m²/year. Actual energy use may be higher than estimates, as the energy performance calculations used standard assumptions and did not capture all consumption.
For the 80-year period, the findings were similar, with GWP values ranging from 4.92 to 12.39 kg CO2 eq/m²/year – some buildings had up to 2.5 times higher impacts than others. Material impacts again exceeded operational impacts, with material emissions ranging from 3.11 to 9.50 kg CO2 eq/m²/year and operational emissions from 0.17 to 4.30 kg CO2 eq/m²/year (Zimmermann et al., 2021[5])
This research contributed to setting an initial carbon limit of 12 kg CO2 per m² per year for buildings over 1 000 m² in Denmark (Bolig og planstyrelsen, 2022[6]; Nordic Sustainable Construction, 2024[7])
Regulatory response
In 2021, Denmark introduced a National Strategy for Sustainable Construction, which established limit values for new constructions. The initial carbon limit was set at 12 kg CO2e/m2/year and applied to buildings over 1 000 m². The limit value was set based on feasibility as it was estimated that approximately 90% of buildings could meet the limit without needing substantial modifications. As a result, carbon limit values for new buildings came into effect in January 2023, making Denmark the first country among the Nordics to introduce such a requirement (Nordic Sustainable Construction, 2024[1]).
The Danish approach consisted in implementing a starting limit value alongside the mandatory climate declaration, ensuring that typical building projects could initially comply without significant additional effort. An additional defining feature of the Danish approach is the frequency of adjustments: regulations are reviewed and updated every two years to ensure that they stay aligned with climate goals (Nordic Sustainable Construction, 2024[7]).
In 2024, the Danish government and a broad political coalition agreed to tighten CO2 emission limits for new buildings starting from July 2025. The new agreement aims to tighten the CO2e limit value to reduce the climate impact of buildings, setting differentiated limits based on building type to expand the range of new construction subject to these standards. With an average limit of 7.1 kg CO2e/m²/year, this target exceeds those outlined in the 2021 National Strategy for Sustainable Construction. The parties to the agreement have also committed to raising the ambition by broadening the scope of buildings covered under the CO2e limit, including holiday homes and unheated buildings over 50 m² starting in 2025 (Table 3.3) (Nordic Sustainable Construction, 2024[7]).
Table 3.3. Timeline of limit values in Denmark
Copy link to Table 3.3. Timeline of limit values in DenmarkKg CO2e/m2/year
2025 |
2027 |
2029 |
|
---|---|---|---|
Average limit value of m2 excuding A4 and A5 |
7.1 |
6.4 |
5.8 |
Holiday homes under 150 m2 |
4.0 |
3.6 |
3.2 |
Single-family houses, row houses, tiny houses, and holiday homes above 150 m2* |
6.7 |
6.0 |
5.4 |
Apartment buildings |
7.5 |
6.8 |
6.1 |
Office buildings |
7.5 |
6.8 |
6.1 |
Institutions |
8.0 |
7.2 |
6.4 |
Other new constructions |
8.0 |
7.2 |
6.4 |
Independent limit value for the construction process |
1.5 |
1.3 |
1.1 |
Total limit including construction process |
8.6 |
7.7 |
6.9 |
Note: *The 150 m2 limit only applies to holiday homes.
Expansion of limit values to further system boundaries
Under Denmark’s 2023 limit value, climate impacts from production, parts of the use phase, and waste management and disposal (modules A1-A3, B4, B6, C3, C4) were included. In addition, as of 1 January 2024, reused building materials are assigned a value of 0 kg CO2 in climate impact calculations to encourage the use of reused components and materials (Social- og Boligstyrelsen, 2024[9]).
With the 2025 adjustment, the limit value requirements will expand to cover climate impacts from the construction process itself (modules A4 and A5) to reduce energy and fuel use from transporting building materials to the site, on-site transportation, and material waste. A specific limit of 1.5 kg CO2e/m²/year has been introduced for emissions from transport and energy use on construction sites, aiming to set standards so that around half of construction sites will need to improve upon the 2021 baseline (Nordic Sustainable Construction, 2024[1]).
Adjusting for success: Finland’s flexible approach to progress
Copy link to Adjusting for success: Finland’s flexible approach to progressRelevant law
In 2017, the Finnish Ministry of Environment developed a comprehensive roadmap to reduce the carbon footprint of construction, with a particular focus on building materials. This roadmap aligned the building sector with national climate goals and outlined measures such as assessing the emissions and carbon stocks of existing building stock, exploring economic incentives for low-carbon construction, and identifying information gaps and timelines necessary for implementation. The roadmap was created under the guidance of the Ministry of Environment and a steering group that included broad industry representation. To gather input, three industry workshops were organised with approximately 100 participants, alongside a competence survey that received about 60 responses. The initial roadmap set ambitious targets, including the introduction of carbon footprint limit values for apartment buildings by 2022 and for all building types by 2024 (Bionova, 2017[10]).
These efforts culminated in the enactment of the Construction Act in 2023, which marked a significant step forward by integrating climate change mitigation into regulatory guidance for the construction sector. This new law mandated climate declarations and CO2 limit values for buildings, reflecting Finland’s commitment to embedding sustainability in construction practices. It required that the main designer, building designer, or special designer prepare climate and material statements in two stages, including small houses and large-scale repairs for these requirements (Eduskunta Riksdagen, 2024[11]).
Before the Construction Act took effect, however, the Finnish Government, formed in June 2023, proposed key amendments to refine its provisions. These amendments, outlined in a government proposal published on 19 September 2024, aim to ease some of the requirements and postpone their enforcement until 2026. For example, unlike the original plan, the revised Act exempts small houses and large-scale repair sites from preparing climate reports. This adjustment reflects Finland’s flexible and adaptive approach to balancing regulatory ambitions with practical considerations for implementation (Eduskunta Riksdagen, 2024[11]).
Building a national database
An essential milestone in Finland’s efforts to reduce the carbon footprint of buildings was the development of a national assessment method. The Ministry of Environment, in collaboration with industry experts, researchers, and LCA professionals, created a Finnish method for assessing the low-carbon performance of buildings. The first draft of this method was published in 2018 and has been refined over time. It has also undergone practical testing within the construction industry to ensure its applicability and effectiveness (Ministry of the Environment of Finland, 2019[12]).
Simultaneously, close co-operation with the European Commission was initiated, integrating the Nordic ministers’ goal of harmonising low-carbon assessment methods for buildings. These efforts are aligned with key European standards, further enhancing the method’s credibility and consistency. In 2019, the Ministry of the Environment released an updated draft of the low-carbon assessment method. This revision incorporated feedback from the 2018 review, trial results, Level(s) testing, and Nordic collaboration experiences (Ministry of the Environment of Finland, 2019[12]). The updated method was tested in over 40 construction projects between 2019 and 2020, culminating in a public feedback round in 2020 (Kuittinen and Hakkinen, 2020[13]).
Building on these experiences, draft regulations for the climate assessment of buildings were prepared in 2021 and circulated for feedback during the summer of 2021 and again in 2022. Stakeholders continued to contribute to refining the assessment method in 2023–2024 (Valtionevusto Statsradet, 2024[14]).
Regulatory response
Starting 1 January 2026, Finland will require a climate report and a list of construction products for new buildings under Section 38 of the Construction Act, as per a decree by the Ministry of the Environment. The climate report evaluates a building's carbon footprint across its life-cycle, ensuring it meets forthcoming limit values. A climate report will be used to demonstrate that the carbon footprint of a new building is below the limit value during the final inspection phase. The list of construction products will be required when applying for a building permit and will be updated for any significant changes after the project is completed. The limit value regulation is under preparation and will be open for comment in spring 2025 (Ministry of the Environment of Finland, 2024[15]).
The new rules exempt certain types of buildings, such as small, detached houses, large-scale repairs, and minor alterations or extensions, from the obligation to prepare a climate report. Instead of a material statement, a construction product list will be required, which will be prepared during the construction permit phase and updated for the building’s final inspection. Climate assessments and carbon footprint limit values will only apply to specific building categories, including apartment buildings, commercial facilities, health centers, hotels, theaters, hospitals, and sports facilities. Exemptions are provided for small houses, movable buildings, and storage buildings under 1 000 m².
Climate reporting is no longer required at the construction permit stage but will be reviewed during the final inspection. Similarly, the carbon footprint limit values will be verified at the project’s completion rather than during the permit application phase. Adjustments to limit values may be allowed for special cases where achieving compliance is particularly challenging due to the building’s characteristics, purpose, or location. These refinements aim to reduce costs and streamline the permit process, benefiting both project initiators and building control authorities (Eduskunta Riksdagen, 2024[11]).
As demonstrated by the Finnish example, a step-by-step approach offers flexibility, allowing governments to adapt over time to changing conditions and circumstances.
Testing and scaling: France’s pilot project approach
Copy link to Testing and scaling: France’s pilot project approachFrance’s environmental regulation for new construction (RE2020) came into force on 1 January 2022, gradually replacing the RT2012 thermal regulation. RT2012 aimed to make low-energy buildings the standard by setting strict requirements to manage energy demand and consumption, as well as establishing performance targets to ensure comfort during the summer. Additionally, RT2012 mandated the use of renewable energy in single-family homes and focused primarily on energy use, not taking into account the entire life-cycle of a building. As a new regulation succeeding RT2012, RE2020 expands the focus to include energy efficiency, carbon footprint reduction, and overall environmental impact including life-cycle considerations of buildings (Ministry of Ecological Transition and Territorial Cohesion, 2024[16]).
Pilot projects
In November 2016, France launched the “Positive Energy, Carbon Reduction” (E+C-) experiment to help the construction sector prepare for future regulation. The government has used this pilot project to calibrate between establishing ambitious policies and maintaining the construction industry’s competitiveness. Co-led by the French Construction Council, the initiative aimed to assess high-performance buildings with higher standards of energy efficiency and reduction of GHG emissions.
The E+C- pilot project was based on a collaborative governance model, bringing together key stakeholders from the construction industry. It was organised around two main committees: the Steering Committee (CoPIL), overseeing the experiment, and the Technical Committee (CoTec), responsible for support and monitoring. The two committees also worked on the gradual development of the E+C- pilot project.
The main output of the E+C- project consisted in the development and implementation of a standardised method for calculating a building's environmental impact. As part of the project, the “Energy-Carbon Reference Model” was introduced, detailing key energy and environmental indicators, calculation methods, required data, and relevant life-cycle stages for a comprehensive LCA. The model set performance benchmarks in two primary areas:
The Energy indicator (Bilan BEPOS), measuring the balance between energy consumption and production.
The Carbon indicators (EgesPCE and Eges) focusing respectively on emissions from construction products, and on emissions from both construction products and building operation.
This model has established a framework for advancing sustainable practices and performance standards across France’s construction sector.
To draft environmental regulations for new buildings, a major consultation with construction industry stakeholders began in January 2019. Guided by 16 expert groups and insights from the 2016 E+C- trial, this phase has helped unify industry perspectives, highlighting points of agreement and contention to shape RE2020. This collaborative effort resulting in the government setting objectives was supported by the industry (Ministry of Ecological Transition and Territorial Cohesion, 2024[16]).
Relevant law
RE2020 aligns both with France’s Energy Transition for Green Growth Law from 2015 (in French: loi de transition énergétique pour la croissance verte) and the 2018 ELAN Law (in French: loi Évolution du logement, de l’aménagement et du numérique). RE2020 strives to reduce the impact of buildings on climate, taking into account GHG emissions across the entire life-cycle of a building. Moreover, RE2020 emphasises the need to prepare the building stock for changes in climate, notably the rise of temperatures during summer (Ministry of Ecological Transition and Territorial Cohesion, 2024[16]).
The ELAN Law (2018), although primarily tackling the housing crisis, emphasises the importance of conducting life-cycle analysis for new buildings. The law mandates construction regulations to account for a building’s environmental performance throughout its life-cycle. The environmental impact of construction products and equipment must be assessed through metrics such as GHG emissions, atmospheric carbon storage, and the proportion of recycled materials used. The ELAN Law also requires that these metrics be made public and verified by independent, qualified professionals. According to the law, both environmental and thermal regulations should be integrated in building standards to ensure greater comprehensiveness.
The ELAN Law addresses both the need to improve the environmental performance of the building stock to mitigate climate change and the need for high-quality and affordable housing. To improve occupants’ comfort, the law introduces notably stringent air quality standards. The level of comfort a building provides to its occupant must meet climate-change objectives (Legifrance, n.d.[17]).
Regulatory response
RE2020 is the first French regulation, and one of the first worldwide, to introduce environmental performance into new construction through life-cycle analysis. The regulation was designed to pursue three major government objectives: i) energy sobriety and energy decarbonisation; ii) reduction of the carbon impact of buildings; and iii) indoor comfort during extreme heat (Ministry of Ecological Transition and Territorial Cohesion, 2023[18]).
Starting from 1 January 2022, RE2020 regulations were phased in gradually by building type, beginning with residential buildings due to their significant impact on climate and the availability of reliable data. Residential buildings alone contribute roughly 60% of operational carbon emissions in the building sector, making them a priority target for emissions reductions (Ministry of Ecological Transition and Territorial Cohesion, 2023[18]).
In terms of feasibility, the residential sector has also represented a more practical starting point. Residential building permits are issued in far greater numbers each year than for other building categories, reflecting the scale and uniformity of available data. For instance, 98 300 residential building permits were issued in France in 2023, compared to 40 253 non-residential building permits (Ministry of Ecological Transition and Territorial Cohesion, n.d.[19]). Additionally, the non-residential sector comprises a wide variety of building types, each with unique characteristics and limited data availability, making it more challenging to establish accurate emission limits across the board. By focusing first on the residential sector, RE2020 regulations have implemented meaningful emissions targets supported by sufficient data, setting a strong foundation for gradually expanding to other building types.
A key distinction between RE2020 and its predecessor, RT2012, is the introduction of a limit on carbon emissions specifically for building construction. This approach to controlling and reducing the environmental impact of construction is structured in a phased, step-by-step manner, with limit thresholds that account for diverse building characteristics and constraints. As shown in Table 3.4, each building's construction carbon emissions must remain below a given maximum threshold to achieve compliance.
Table 3.4. RE2020 application dates for different types of buildings
Copy link to Table 3.4. RE2020 application dates for different types of buildings
Type of building |
Application date (RE2020) |
---|---|
Residential buildings |
1 January 2022 |
Offices, primary and secondary schools |
1 July 2022 |
Small residential extensions/buildings, small offices, small schools |
1 January 2023 |
Recreational light housing (HLL) < 50m² (subject to urban planning) |
1 January 2023 |
Temporary residential buildings, offices, primary/secondary schools |
1 July 2023 |
Recreational light housing (HLL) < 35m² (exempt from urban planning) |
1 July 2023 |
Source: Ministry of Ecological Transition and territorial Cohesion (2024), Réglementation Environnementale Des Bâtiments Neufs (RE2020)https://www.ecologie.gouv.fr/sites/default/files/documents/guide_re2020_version_janvier_2024.pdf
These thresholds will be progressively tightened over time, enabling the construction industry to adapt gradually, reduce emissions, and incorporate the LCA methodology into their practices (Table 3.5).
Table 3.5. France’s limit values for construction emissions (excluding operational carbon) in RE2020
Copy link to Table 3.5. France’s limit values for construction emissions (excluding operational carbon) in RE2020kgCO2e/m2
2022-2024 |
2024-2027 |
2028-2030 |
2031 onwards |
|
---|---|---|---|---|
Individual or semi-detached houses |
640 |
530 |
475 |
415 |
Apartment buildings |
740 |
650 |
580 |
490 |
Office buildings |
980 |
810 |
710 |
600 |
Primary or secondary schools |
900 |
770 |
680 |
590 |
Source: Ministry of Ecological Transition and Territorial Cohesion (2022)
Focusing on feasibility: Sweden’s initial steps on upfront carbon
Copy link to Focusing on feasibility: Sweden’s initial steps on upfront carbonRelevant law
Sweden’s WLC strategy is aimed at achieving both a significant and immediate impact. The initial step in this strategy focuses heavily on learning and stakeholder engagement. The Swedish government aimed to involve all relevant stakeholders early on to prepare them for future regulatory changes. Sweden’s Climate Act (2017:20), which came into effect on 1 January 2018, has played a pivotal role in this process. The Act requires the government to work toward reducing GHG emissions, aligning with Sweden’s long-term goal of achieving net-zero emissions by 2045. All sectors, including construction and real estate, must contribute to this national target.
The construction and real estate sector in 2022 accounts for approximately 17.7 million tonnes of CO2 equivalents annually, i.e. about 21 % of Sweden’s total climate impact. Around a third of these emissions stem from the construction of new buildings and demolition of old ones. From a life-cycle perspective, the most significant climate impacts come from material used during construction (modules A1-A3) and energy use during building operation (module B6) (Boverket, 2025[20]).
Regulatory response
Recognising the substantial environmental impact of building construction, the Swedish government saw the need for stronger regulations to drive a faster transition toward lower emissions. As part of this effort, climate declarations were introduced, focusing specifically on upfront carbon, i.e. the emissions tied to material production and use in the early stages of construction (system boundaries A1 to A5). This measure aimed to raise awareness among stakeholders in the construction sector about their contributions to upfront carbon emissions and prompt them to begin calculating and managing their climate impacts (Boverket, 2020[21]).
Sweden’s first step – starting with upfront carbon – was strongly influenced by considerations of its impact, while subsequent steps were gradually planned with added focus on feasibility and international harmonisation. In 2020, Boverket proposed including additional modules in mandatory carbon declarations starting in 2027. These include modules B2, B4 and B6 (use stage), C1 to C4 (end-of-life stage), as well as supplementary environmental information such as biogenic carbon storage and net exports of locally produced electricity.
The inclusion of module B was based on considerations of both feasibility and impact. According to Boverket (2020[21]), the SS-EN 15978 standard – Swedish adaptation of the European standard (EN) for assessing the environmental impact of buildings throughout their life-cycle – does not provide clear distinctions between the modules in the B stage (Use).
The B module (Use) covers impacts associated with the building’s use, including maintenance, repair, and replacement activities, but the boundaries between these activities are often blurry. As a result, this ambiguity has led to varying interpretations in LCA studies and methods across different countries, prompting the exclusion of certain modules (B1, B3, and B5) from mandatory requirements.
Module B1 addresses the environmental impact associated with building use, such as climate emissions from refrigerants in installations or from painted surfaces. However, its inclusion in building LCAs has been limited, both in academia and in industry.
Module B3 pertains to repairing damaged components to restore them to expected performance levels, which is often conflated with maintenance covered in B2. Additionally, creating realistic scenarios for B3 is challenging due to the difficulty of predicting future repair needs.
Module B5 concerns major renovations and refurbishments. Boverket assumes that significant performance-enhancing renovations will take place after the building’s reference study period, initiating a new life-cycle. Predicting the need for other types of refurbishments at the construction stage is equally challenging.
Module C, covering the end-of-life stage, was included to promote circularity in construction and align Sweden’s regulations with those of other Nordic countries and developments across Europe, despite the relatively small share of climate impact attributed to this stage (Boverket, 2020[21]).
Introducing limit values
Sweden is planning to introduce limit values for climate emissions from buildings, balancing both impact and feasibility considerations. In 2020, Boverket proposed to the government that limits for carbon emissions during the construction phase (modules A1 to A5) be implemented in 2027, with subsequent reductions in two phases, in 2035 and 2043. The rationale for focusing on upfront carbon emissions is threefold: i) it directly addresses immediate carbon output; ii) upfront emissions are easier to verify compared to future emissions; and iii) they represent the largest share of climate-impacting emissions over a building’s life-cycle (Boverket, 2020[21]).
In 2023, Boverket further suggested that limit values could be introduced as early as 1 July 2025 for modules A1 to A5. This proposal follows a year of implementing climate declarations for buildings and reflects the urgency of reducing the carbon footprint in the building sector as soon as possible. In addition, Boverket proposed reducing limit values every five years (Boverket, 2023[22]). Table 3.6 summarises the current state of play of WLC policy in Sweden and its next steps.
Table 3.6. Step-by-step whole life carbon policy in Sweden
Copy link to Table 3.6. Step-by-step whole life carbon policy in Sweden
Year |
2022 |
2027 |
---|---|---|
Limit value |
No limit value |
Limit value covering A1-A5 (2025 was proposed by Boverket) |
Modules to be declared |
A1-A5 |
A1-A5, B2, B4, B6, C1-4, supplementary environmental information – biogenic carbon storage and net export of locally produced electricity |
Building elements |
- Load-bearing structures - Building envelope - Interior Walls |
- Load-bearing structures - Building envelopes - Interior walls - Installations - Interior surface finishes - Room fittings |
Reference study period |
50 years |
Notes: Boverket’s initial proposal sets carbon limits in 2027, with subsequent reductions in two phases, in 2035 and 2043.
Source: (Boverket, 2020[21])
References
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