A few weeks ago (March 2026), the European Commission published an analysis indicating that the assessment of buildings' environmental impact will move away from its focus on operational-phase energy consumption, with the future direction instead placing climate impact assessment across a building's entire life cycle — from the production of materials and construction, through use, and finally to demolition [1]. The Commission calls this new policy direction the whole-life carbon approach. I believe it is time for the construction and real estate sector to get used to this new approach. Energy efficiency is yesterday's news. Let me explain.
Traditionally, the greatest attention has been paid to buildings' operational energy use — that is, heating, cooling and ventilation. This is justified, since operational emissions still account for the largest share of a building's total carbon footprint. At the same time, the remaining share — the carbon embodied in materials — is by no means unimportant. Embodied carbon covers the production of construction materials, transport, construction activity, renovation and, eventually, demolition. This is particularly important for new buildings built to be energy-efficient, or renovated to be energy-efficient, since their operational emissions have already been brought down to a very low level. For energy-efficient buildings, the impact of materials and construction can even be greater than the environmental impact generated while the building is in use.
The European Union's building stock as a whole emits around 808 million tonnes of CO₂ equivalent every year. While most of these emissions stem from the use of buildings, it is notable that new construction — which accounts for only around one percent of total building floor area added each year — is responsible for nearly a fifth of the entire sector's emissions. With this example, the Commission is illustrating just how significant an impact the material choices and construction decisions made before a building is put into use can have. Accordingly, it has concluded that improving energy efficiency alone is no longer sufficient, and that the carbon footprint of construction and materials must also be addressed.
The Commission's analysis highlights three main directions for reducing buildings' life-cycle emissions. The first of these is sufficiency (sufficiency), meaning better use of existing buildings. This includes bringing vacant or underused spaces back into use, as well as changing buildings' function and prioritising renovation over new construction. In the policymaker's broader view, European cities are full of unused or underused buildings, while the shortage of housing is a growing problem. Why not convert these buildings into housing and thereby address both social and environmental problems at once?
The second important direction is efficiency (efficiency), which focuses on optimising both energy and material use. From the European policymaker's perspective, this means far better design solutions than today, lower material consumption, greater recycling, and a longer service life for buildings.
The third direction is renewables (renewables). Under this direction, the Commission envisages that both energy and material needs will be met from renewable sources as far as possible. The best examples of the renewables direction are the use of renewable energy for heating and cooling buildings, and the use of bio-based or low-carbon construction materials.
A Commission discussion paper is usually followed by a whole series of roadmaps and legislative regulations. Policy changes can therefore also be expected following the discussion paper on the decarbonisation of buildings. The European Union has already introduced, or is preparing, a number of regulations that require the whole-life-cycle carbon of buildings to be assessed and reported. For new buildings, this will become mandatory in the coming years, and several countries have already set limit values for how large a building's carbon footprint per square metre may be. Standards and a digital product passport are also being developed, since these make it possible to track the environmental impact of construction materials across their entire life cycle, while also encouraging the development of the circular economy.
The European construction sector is thus moving toward a state where every building is no longer merely a physical object, but a complex bearer of environmental impact throughout its entire life. As a result, understanding and taking into account the whole-life carbon approach is no longer just one option among many, but a new compliance standard.
The most significant regulatory change underpinning the application of this new compliance standard is the implementation of the new Construction Products Regulation (CPR). While the Construction Products Regulation in force until January 2025 [2] focused on the technical properties of products, the approach under the new Construction Products Regulation [3] requires manufacturers of construction products to demonstrate their products' environmental impact across the entire life cycle. This means that every material used in a building must be described not only in terms of its technical characteristics, but also in terms of its environmental impacts.
In Estonia, the requirements of the new Construction Products Regulation have already entered into force as of 01.01.2026, having been transposed through amendments to the Building Code. Taasterahastu has also previously pointed out in its own analyses [4] that a building's environmental footprint cannot be reduced to carbon alone. The carbon footprint — more precisely, the Global Warming Potential (GWP) indicator — is only one metric. The actual environmental impact, however, also encompasses resource use and consideration of circular economy principles.
The most important conclusion to draw from the discussion paper on the decarbonisation of buildings is that the construction sector, both in Estonia and across Europe, is moving toward a state where decisions are no longer made solely on the basis of energy efficiency or price, but with regard to the full picture of a building's life-cycle environmental impacts. The Construction Products Regulation is of key importance here, since it creates the dataset on which all other decisions can be based. Without reliable product data, it is not possible to calculate a building's actual environmental impact or make informed choices.
[1] Commission staff working document. Supporting life-cycle approaches to decarbonise European buildings, Brussels, 17.3.2026, SWD(2026) 93 final
[2] Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC
[3] Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2025 laying down harmonised marketing rules for construction products and repealing Regulation (EU) No 305/2011
[4] https://taasterahastu.ee/mis-on-hoone-keskkonnajalajalg-ja-miks-see-pole-ainult-susinikujalg/