Roadmap to climate-proof buildings and construction – How to embed whole-life carbon in the EPBD

This policy roadmap argues that the EPBD recast should ensure a comprehensive vision of a carbon neutral building and construction sector, and set the requirements and clear triggers to reduce whole-life carbon emissions of the building stock. It sets out the necessary steps to introduce whole-life carbon considerations and align the provisions of the EPBD with climate-neutrality goals.


Despite an array of national initiatives, voluntary schemes and regulations, EU legislation is not designed to address all sources of carbon emissions from buildings and construction. Most existing policies focus on curtailing carbon emissions by managing and reducing operational emissions (energy consumption in buildings’ use phase), leaving out the significant mitigation potential of embodied emissions (those resulting from the production, installation, maintenance and disposal of building materials). Embodied emissions in buildings need to be tackled in order for them not to undermine the carbon reductions achieved from the energy saving measures in the building sector. In the EU alone, embodied carbon contributes to around 10-20% of buildings’ total CO2 emission footprint.

The Energy Performance of Buildings Directive (EPBD) is the single most important legislation targeting the building sector. It requires Member States to set performance levels for their buildings, strategically plan the decarbonisation of the building stock through the long-term renovation strategies and implement additional measures – both financing and advisory tools. The EPBD is thus the obvious policy tool to set out requirements and clear triggers for reducing the WLC emission of the building stock.  

About this roadmap

This policy roadmap sets out the necessary steps to introduce whole-life carbon considerations and align the provisions of the EPBD with climate-neutrality goals, mapping out the most relevant and urgent actions to take from now to 2050. The roadmap sends a long-term market signal by setting out a clear vision that provides the rationale and sets the level of ambition for further measures, zeroing in on how to integrate whole-life carbon in the policy framework.

While it is important to improve the energy efficiency of buildings, the measures risk being suboptimal without a clear understanding of the embodied carbon footprint of buildings. A first step to regulate whole-life carbon is to measure it. Additionally, it is necessary to set voluntary targets based on common standards, agreed methodologies and consistent carbon data sources. New construction should be required to assess and disclose information on embodied carbon emissions. 

Making whole-life carbon reporting mandatory will facilitate data collection and benchmarking and will allow the construction sector to develop the necessary skills and capacity. Mandatory minimum whole-life carbon standards will have to be introduced and strengthened over time. 

However, a lack of synchronisation in the EU policy timeline runs the risk that policies addressing and affecting the different stages of the construction value chain will not be coordinated. The EPBD recast, for example, takes place before carbon benchmarks and before an EU-wide whole-life carbon trajectory will be available to guide how all emissions related to buildings can and should be reduced.

At minimum, the EPBD must now set out a strong vision for whole-life cycle carbon of buildings and construction, that ensures a consistent, step-wise approach and timely implementation of the sequences of recommended actions. Waiting until the next EPBD revision in 2027 to integrate a plan for whole-life carbon will be too late.

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