Assignment on life-cycle GWP and limit values for climate impact from buildings in the EPBD

The recast Energy Performance of Buildings Directive (EPBD) includes new requirements for the calculation and reporting of life-cycle GWP for new buildings. There are also requirements for limit values for the climate impact from new buildings. The Swedish National Board of Housing, Building and Planning (Boverket) has now submitted legislative proposals to implement the requirements in the directive into Swedish law.  

Reporting  

Within the framework of the assignment given to Boverket by the Government to produce the basis for the national building renovation plans, we now present legislative proposals relating to the requirements on life-cycle GWP and limit values in the recast Energy Performance of Buildings Directive (EPBD).  

Link to the report

Government assignment

 In December 2024, the Swedish National Board of Housing, Building and Planning (Boverket) received a government commission to submit legislative proposals for implementing requirements to calculate and report life-cycle GWP for new buildings in accordance with the EPBD. Legislative proposals on limit values for the climate impact from new buildings must also be submitted, while carbon uptake and carbon storage are to be addressed . These assignments are part of the government commission concerning the national building renovation plans. The assignment is to be reported no later than 1 June 2026. Boverket must also develop a proposed roadmap for introducing limit values for cumulative life-cycle GWP for new buildings in accordance with the EPBD. That part of the assignment must be reported no later than 1 October 2026.  

Uppdrag till Boverket att ta fram underlag till den nationella byggnadsrenoveringsplanen enligt direktivet om byggnaders energiprestanda (på Regeringskansliets webbplats)

EU requirements on life-cycle GWP and limit values  

The requirements in the EPBD entail that life-cycle GWP must be calculated and disclosed in the energy performance certificate of the building  

• from 1 January 2028 for all new buildings larger than 1,000 square metres  
• from 1 January 2030 for all new buildings.  

By 2030 at the latest, Member States must also have introduced limit values for the maximum permitted climate impact from buildings.  

What should be included in the calculation of life-cycle GWP is stated in Annex III of the EPBD. However, the European Commission has issued a delegated EU regulation that amends Annex III. The delegated EU regulation on life-cycle GWP came into force on 24 May 2026. It clarifies the requirements to be imposed on the calculation of a building’s climate impact from a life-cycle perspective (life-cycle GWP). Among other things, it specifies which life-cycle modules and building elements must be included. The delegated EU regulation applies directly in all EU Member States and thus affects how Sweden’s regulations need to be amended in order to comply with the EU requirements in the EPBD.  

Commission Delegated Regulation (EU) 2026/52 (on the EU Commission website)

Boverket’s proposals  

In its report to the Government, Boverket proposes that the regulations should be implemented in the Planning and Building Act as a new technical requirement. The requirement includes both calculating and reporting life-cycle GWP and limit values ​​for the building's greenhouse gas emissions for the construction stage. The requirement will apply to all new buildings that are subject to energy performance certification. The current legislation on climate declarations is proposed to be repealed.  

Boverket’s proposal implies that Sweden follows the mandatory requirements of the delegated EU regulation on the calculation and reporting of life-cycle GWP. A few national choices are submitted. Among other things, it is proposed that gross floor area be used and that a method for eliminating data gaps be introduced.

It is proposed that limit values be introduced on 1 January 2030 and differentiated by building type. The limit value is proposed to cover the construction stage (modules A1–A5). The system boundary for which building elements are included in the limit value differs slightly from the boundary used for reporting life-cycle GWP. For buildings for which reference values exist, limit values between 150–250 kg CO2eq/m² GFA are proposed. For the category “other buildings”, where reference values are lacking, a limit value of 295 kg CO2eq/m² GFA is proposed. For buildings with specific climate-driving conditions, there is the possibility of an increase in the limit value in the individual case.

Boverket also describes an indicative emission trajectory for future limit values between 2030 and 2050, intended to contribute to the EU’s objective of climate neutrality.  

The investigation has focused on cost-effective implementation in line with the EU's objective of climate neutrality by 2050, with a particular focus on the conditions for small and medium-sized enterprises.

Boverket has investigated various options for the implementation of EU law. The overall assessment of the socio‑economic analysis is that the legislative proposals are socio‑economically justified and likely to be profitable. The limit values proposed by Boverket are moderately strict and balance ambition with feasibility. This implies some cost increase for developers. The limit value levels are considered to provide incentives for companies to take measures, while the risk of companies being forced out of the market is deemed to be low. Boverket considers that more stringent limit values would entail an excessive risk of companies being forced out of the market, particularly small and medium-sized enterprises. Less stringent limit values are not expected to have any steering effect, as emissions are expected to decrease to that level without limit values.

What happens next  

Boverket’s legislative proposals are part of a government assignment concerning how the recast EPBD can be incorporated into Swedish legislation. After Boverket has submitted its legislative and regulatory proposals to the Government, the matter will be prepared further by the Government Offices. 

Five government assignments within our area of operation  

This government assignment is part of Boverket’s work related to the EPBD. Boverket has five different government assignments where we develop supporting material and propose how the requirements can be introduced in acts and ordinances. In addition to the assignment on life-cycle GWP and the building renovation plans, we are developing supporting material and proposing regulatory requirements in the areas of methods and definitions, energy performance certificates, solar energy and sustainable mobility. Read more about the assignments and our overall work.  

Direktiv för byggnaders energiprestanda