The long-awaited draft of the Ministry of the Environment's regulation on maximum carbon footprint values for buildings has finally arrived for comment. It was revealed that the limit values are moderate. For example, the carbon footprint limit for a residential apartment building is a reasonable 16 kg-CO2e/m2a.
Since the draft regulation was published, there have been dismayed comments about how unambitious the limit values are. It has been clear from the comments that some might have expected the limit values to shake up the market shares of building materials in a new way. And as for the corresponding figures of our western neighboring countries, our figures should not be compared directly with them, as the calculation bases differ significantly.
The reason why the limit values are relatively loose can be found in the emissions calculation, i.e. the climate report itself.
The climate report was built in a hurry, as usual. Therefore, it was not possible to include any instruments in the calculation that could have taken into account the functional characteristics of the building that have an inherent impact on the formation of the carbon footprint. As a result, one and the same limit value applies to all buildings of the same purpose category, such as residential apartment buildings, whether they are low or super high.
It is clear to the builder that a skyscraper requires significantly more material per square meter than, say, a three-story laminated building. Therefore, the carbon footprint of a skyscraper is also higher. The limit values had to be set accordingly, i.e. so that even a skyscraper is feasible.
The lack of instruments that take functional properties into account actually causes a much bigger problem than just the laxity of the limit values. This is because the current simplified limit values create an incentive to compromise on the functional properties of the building, i.e. in practice, quality.
The first and perhaps most striking example of this is the limitation of the review period to only 50 years. Consequently, all investments that aim to achieve a longer service life than this, such as using stainless steel reinforcement or a thicker concrete cover for reinforcement, appear in the climate study only as negative aspects. The same is true if the builder wants to invest in, for example, better sound insulation or flexibility of the frame. These require the use of materials and increase the carbon footprint, but from the perspective of the climate study they are just a burden without any benefits.
Ignoring functional properties is not a big deal as long as the limits are loose. But when the limits are gradually tightened, you will have to compromise on something before long.
Time will tell how the compromise is made. Will it be made on carbon emissions or quality? It is an embarrassingly easy compromise, for example, to compromise on flexibility, because then you also save money at the same time. The result of compromise is buildings that are optimized for their original purpose in order to minimize their carbon footprint. When the building is unable to adapt when the need for use changes, the building ends up on the list for premature demolition. The building was low-emission on paper, but unfortunately not in reality.
The first tightening of the limit values will come into effect at the beginning of 2028. Hopefully, by then, the climate study will include ways to take into account quality factors and functional properties that affect the carbon footprint so that the building regulations do not encourage compromising on quality.
The article has been published in Rakennuslehti's Näkökulma section on 2.5.2025 November XNUMX.
Jussi Mattila
CEO, Betoniteollisuus ry
jussi.mattila@rt.fi +358 40 063 7224Construction product industry RTT ry, Betoniteollisuus ry
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