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The recast Energy Performance of Buildings Directive (EPBD) (EU 2024/1275) continues to drive a fundamental shift in EU building policy by extending performance criteria beyond operational energy to a whole-life carbon metric.
For the first time, buildings’ life-cycle Global Warming Potential (GWP) – reflecting greenhouse gas emissions from material production, transport, use, maintenance and end-of-life – must be calculated and disclosed in energy performance certificates. This disclosure applies to new buildings over 1,000 m² from 1 January 2028, and to all new buildings from 1 January 2030. Member States are also required to develop and notify roadmaps (Renovation roadmap & Lifecycle GWP roadmap) by 1 January 2027, outlining the introduction of national limit values on life-cycle GWP for new buildings under Article 7(5) of the Directive.
A key development in December 2025 was the adoption of the Commission Delegated Regulation C(2025) 8723, establishing a Union framework for national life-cycle GWP calculation. The Delegated Act provides a harmonised methodological baseline aligned with EN 15978, while allowing flexibility in national implementation.
Importantly, the final text confirms a tiered approach to the scope of building elements. Tier 1 (core structural elements) and Tier 2 (shell, core and essential technical systems) are mandatory and define the minimum EU-wide boundary for life-cycle GWP calculation. Tier 3 and Tier 4 elements – including extended building components and fit-out items – are illustrative and may be adopted by Member States as practice matures. This phased structure reduces initial compliance burden while signalling likely future scope expansion.
The Delegated Act also introduces explicit flexibility for Member States to weight or exclude certain life-cycle stages when setting national limit values, supporting a pragmatic rollout ahead of the 2028 and 2030 milestones. The Regulation is now in the scrutiny phase before formal entry into force, after which Member States will transpose the framework into their national building regulations.