EU Buildings Directive (EPBD recast, 2024/1275)

What is it?

Directive (EU) 2024/1275, the EPBD recast, entered into force on 28 May 2024 and replaces the previous Energy Performance of Buildings Directive. The core rule that affects the construction products market is this: the life cycle global warming potential (GWP) of every newly erected building has to be calculated, disclosed and documented in the energy performance certificate (EPC). The method is based on EN 15978 (whole-life carbon at building level), extended by the calculation of PENRT (total non-renewable primary energy).

The EPBD does not act directly on individual products but on the balance in which those products are counted. That is exactly what makes it decisive for manufacturers in market terms. Without product-specific EPDs to EN 15804+A2, the building LCA is calculated with generic background data sets, which are usually calibrated conservatively. Innovative or optimised products therefore appear worse in the balance than they actually are. Member states have to submit national GWP limit roadmaps by 1 January 2027, so the step from pure disclosure to binding limits is already foreseeable.

Who is affected?

Directly addressed are building owners, property owners, architects and developers, through the reporting obligation in the EPC. Indirectly, and decisively for market reality, every manufacturer whose products feed into a building’s GWP balance is affected: the building envelope (wall, roof and floor assemblies), insulation materials, windows and doors, load-bearing elements, building services components and building-integrated energy generation.

Anyone supplying public sector clients or active in certification-oriented segments (QNG, BNB, DGNB, BREEAM, LEED) has to make the EPBD requirements satisfiable at product level right away. The GWP calculation applies first to larger new buildings and extends to all new buildings in the following years. Manufacturers therefore have to build their data basis early. The typical chain from product LCA through verification and ÖKOBAUDAT listing to specification entry needs several months of lead time.

Which deadline applies?

The EPBD takes effect in stages.

• 28 May 2024: the directive enters into force at EU level.
• German implementation by May 2026: in Germany this runs through the GEG (building energy act) and the building modernisation act.
• By 1 January 2027: member states have to submit national GWP limit roadmaps.
• 1 January 2028: GWP calculation and disclosure become mandatory for new buildings over 1,000 m².
• 1 January 2030: mandatory for all new buildings.

The exact thresholds and calculation rules per member state follow from national implementation. In Germany the GEG is the decisive instrument that manufacturers should align their market strategy with. In parallel the obligations are made concrete in the national roadmaps: disclosure first, limits later.

What has to be done?

From a construction product manufacturer’s perspective four workstreams come first.

• Make EPDs to EN 15804+A2 available, with all the modules needed for a whole-life carbon calculation of the building, so not only A1-A3 (production) but also the B modules (use phase) and the C and D modules (end of life and recovery).
• Think about the EN 15978 connection: product-specific values have to integrate cleanly into the building-level balance. For multi-layer products or composites, show the data chain back into the upstream supply chain.
• Secure the link to certification systems: prepare data so it can feed into QNG, BNB, DGNB, BREEAM and LEED calculations without conversion losses. That normally runs through the relevant database formats, either ÖKOBAUDAT or EN 15804+A2 compliant EPD programmes such as IBU.
• Communicate for specification: actively supply planners and tendering bodies with the EPD values. The competitive advantage only materialises if planners know specific values are available. Extend data sheets, BIM objects and tender documents accordingly.

What happens if you do not?

Building owners will meet the EPBD obligation either way, simply by falling back on generic data sets. For manufacturers that means the product-specific advantages, lower GWP, higher recycled content, optimised end-of-life routes, never appear in the balance. The product is counted against the category average in the specification and loses the differentiation it paid for through its own optimisation. Where building owners have promised sustainability figures in their planning, a missing specific record can mean the product is dropped.

In certification-driven projects (BNB, QNG, DGNB) the effect is immediate. In regular tendered building projects it starts with the national roadmaps and by 2028 at the latest. Breaches of the national implementing laws can bring fines, work stoppages and clawback of funding, though those direct sanctions hit the building owner side. For manufacturers the relevant effect is the gradual loss of market share to competitors with a better EPD position, and that effect typically starts before the regulatory deadline, as soon as planners and building owners change their routines.