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WorldGBC reacts to the revision of the Energy Performance of Buildings Directive

Last year, the European Commission proposed an update to the Energy Performance of Buildings Directive (EPBD) which is being revised as part of the ‘fit for 55’ package. 

On 31 March, WorldGBC submitted feedback to the recast EPBD, outlining how our network of over 20 GBCs across Europe representing almost 5,000 members strongly support the fact that the focus of the EPBD has started to take into account embodied as well as operational energy – a shift that our network has supported for a number of years.

In particular, we welcome the introduction of Minimum Energy Performance Standards (MEPS), the introduction of Whole Life Carbon reporting, the harmonisation of Energy Performance Certificates and the introduction of Building Renovation Passports.

Despite this much-welcomed progress, the level of ambition is still not enough to meet the goals of the EU Green Deal. Much more needs to be done to accelerate the rate and depth of ambition, particularly in relation to MEPS and Whole Life Carbon.

We’ve summarised WorldGBC’s positions below on key topics in the EPBD revision:

Minimum Energy Performance Standards

WorldGBC supports the introduction of MEPS, but the ambition of EPC classes and dates should be strengthened if the Commission wishes to deliver on the goal of the  Renovation Wave. A goal of residential buildings achieving class E after 2033 is disappointingly unambitious, especially given the European Commission’s drive to tackle energy poverty. The Commission should also commit to assessing the feasibility of adding whole life carbon metrics to MEPS.

Zero Emissions Buildings

WorldGBC supports the introduction of Zero Emissions Buildings as a welcome upgrade of the existing ‘NZEB’ concept, and it is good to see a specific set of requirements laid out in Annex III, as well as the connection established between Deep Renovation and NZEBs and ZEBs. However, the ZEB definition needs to evolve to take into account WLC.

Energy Performance Certificates

The harmonisation of EPCs against a common template by 2025 is an encouraging development, as is the fact that the performance classes will be rescaled towards achieving a zero-emission building stock by 2050″. In order to achieve this, however, WLC disclosure should be a mandatory indicator, not just an optional extra.

Building Renovation Passports

WorldGBC supports the introduction of BRPs, especially with the specification that the BRPs are roadmaps towards zero emission buildings by 2050. It is also welcome that BRPs will include information on the holistic benefits of renovation, including improvements to the health and comfort of occupants. However, as with EPCs, clarity is needed on how BRPs can feed into WLC building databases and facilitate the development of WLC benchmarking and targets in the future.

Mortgage Portfolio Standards

The introduction of MPS is a smart move that recognises the key role that banks and financial institutions can play in the Renovation Wave. WorldGBC has been supporting the implementation of the EU’s Green Taxonomy since 2020 as a member of the EU Sustainable Finance Platform. However, we would like to see the Commission go further and make it mandatory for member states to promote the rollout of MPS.

Whole Life Carbon

While the inclusion of Whole Life Carbon reporting in the EPBD is an important step, we need to start reporting on it now. Waiting until 2030 means that WLC targets will not come into place until at least the mid-2030s, delaying action and rendering the 2050 net zero building stock target impossible. The revised Directive also gives no roadmap towards eventually setting WLC limits.

WorldGBC will now work with Members of the European Parliament and national government to advocate for increased ambition levels on key aspects of the EPBD review including MEPS and WLC reporting requirements.

Read WorldGBC’s full EPBD feedback here.