The European construction sector is moving rapidly toward a reality in which material use is just as important as energy efficiency and construction cost in determining a building's value. Delegated Regulation (EU) 2026/52[1], which entered into force at the start of this year (2026), requires that the life-cycle global warming potential (GWP) indicator be calculated for every new building, and this will also be reflected on the energy performance certificate. As a result, measuring the CO₂ impact of construction materials is becoming essentially unavoidable. Until now, carbon footprint has been treated as a voluntary environmental topic, but with the entry into force of the Delegated Regulation, having such calculations in place becomes a success criterion for construction projects and procurements.
The aim of the new regulation is to make the calculation of buildings' climate impact comparable and transparent across the entire European Union. Under the common framework established for this purpose, a building's climate impact must now be assessed across its entire life cycle. We are used to assessing a building's operational energy consumption when obtaining its energy performance certificate. To this is now added the impact of producing, transporting, constructing, maintaining, and renovating construction materials, and ultimately also the impact of demolition and material reuse. The new approach introduced by the Delegated Regulation makes construction materials one of the most significant factors in a building's overall CO₂ accounting. Concrete, steel, timber, insulation, technical systems, windows, ventilation solutions, and even outdoor installations – all of these components of the building's infrastructure must be taken into account when calculating the building's final carbon indicator. The regulation describes in great detail exactly which components must be included in the calculation.
I consider this Delegated Regulation to be a fundamental game-changer for the market, especially in Estonia, where Environmental Product Declarations are not particularly widespread among construction material manufacturers. Going forward, however, it is clear that manufacturers can no longer limit themselves to declaring technical properties alone, since designers and developers are being steered toward choosing materials whose environmental impact is verified and as low as possible.
In my master's thesis in industrial ecology on quantifying circularity, I demonstrated through calculations that reliable CO₂ calculations are not possible without high-quality material data. In this respect, it is worth noting that the Delegated Regulation itself also stipulates that official product-specific environmental data declared through EPDs should be used as the first option, and preferred over generic default values. Where precise data on a product are not available, conservative generic values are used instead. However, these can increase the overall carbon footprint of a building and reduce a project's competitiveness. This is exactly what my master's thesis, completed a year ago, also showed. Estonia's database of construction material emission factors (EHEA) is based on conservative generic values, and it has been demonstrated that a building's GWP calculated on this basis is always higher than the GWP calculated using actual, EPD-based data.
In summary, the construction sector is currently moving rapidly toward carbon-based competition. Verified climate impact is now being added to the primary competitive advantage that has existed so far (in practice, price advantage). Construction material manufacturers who are able to verify their product's CO₂ footprint and invest in reducing it will gain an advantage in procurements, in export markets, and in the eyes of developers and investors who follow ESG requirements.
As is well known, Estonia has its own national methodology for calculating the life-cycle carbon footprint of buildings[2]. How should we proceed with this? The entry into force of the Delegated Regulation does not, in itself, mean that we must throw out the existing methodology. The Commission expects that Member States, including Estonia, will bring their methodologies into line with the EU's common framework. After all, the primary purpose of the Delegated Regulation is to establish common minimum requirements and a common framework, so that calculations made in different Member States are comparable with one another for the internal market policymaker. Member States may continue to use their existing national tools and methods, provided that these are integrated with the new common approach.
Just like the now-outdated methodology, its update will also be based on the EVS-EN 15978 calculation method for assessing the environmental performance of buildings, but Member States can decide for themselves which default values and which national databases to use, which simplifications to allow, and how to technically apply certain modules in the calculations. It is therefore likely that the Ministry of Climate will soon commission an update of the existing Estonian methodology to bring it into compliance with the requirements of EU 2026/52.
It is worth noting separately that, in parallel with the entry into force of the Delegated Regulation, the Commission has also commissioned a thorough update of the calculation method. The now-superseded standard EVS-EN 15978:2011 was a slim 60 pages; the new EVS-EN 15978:2026 Sustainability of construction works. Assessment of environmental performance of buildings. Requirements and guidelines, runs to a hefty 124 pages, and is correspondingly more substantial in content.
My suggestion to officials at the Ministry of Climate is that Estonia should not spend time, in its updated methodology, on interpreting the standard or adapting it to the Estonian context. It would be far more useful to agree on realistic default values and to work on the emission factors for construction materials used in Estonia, so that the actual impact of the materials actually used can genuinely be taken into account in GWP calculations.
[1] Commission Delegated Regulation (EU) 2026/52 of 16 December 2025 amending the part of Annex III to Directive (EU) 2024/1275 of the European Parliament and of the Council concerning the Union framework used for the national calculation of life-cycle global warming potential
[2] Methodology for calculating the life-cycle carbon footprint of buildings. Technical document describing Estonia's national carbon footprint calculation methodology. Tallinn, 2024