Low-carbon regulation is very much a guardian. It must be absolutely material and technology neutral and encourage innovation in order to maintain enthusiasm for the Kira sector's emission reduction work, writes low-carbon construction expert Pekka Vuorinen in his article in Expert.
Carbon regulation of buildings – assessing the life cycle carbon footprint and limiting emissions – has a long history. The first EN standard for the environmental impact assessment of buildings was completed in 2011 following a mandate from the EU Commission, with the long-term aim of developing uniform tools to support regulation.
Manufacturers of construction products have long been market-driven and have been preparing so-called environmental declarations to report essential environmental and emission data of construction products in accordance with their own EN standards for use in building-level assessments. As the first steps in EU regulation in the 2020s, carbon footprint assessment has been required in the taxonomy and the Energy Performance of Buildings Directive. Certain EU Member States have also had their own initiatives leading to regulation.
However, the standardization work initiated by the EU Commission and the subsequent carbon regulation at the member state level have been marked by credibility problems. An example does not have to be found far away. In Finland, the carbon footprint limits for use categories are scheduled to come into force at the beginning of 2026. This is the final stage of the low-carbon regulation – the low-carbon construction roadmap – launched by the Ministry of the Environment in 2017.
The carbon footprint assessment method is specified in the Building Climate Assessment Regulation and the proposals for limit values were given in the draft regulation that was submitted for comment last spring. However, neither of these documents explains what kind of uncertainties are involved in the life-cycle assessment of carbon emissions and how a single limit value guides carbon emission reduction, considering the speculative nature of the calculation results.
Functional equivalence of solutions forgotten in comparison
The uncertainties that most affect the calculation results can be summarized as the accuracy and verifiability of emission data for materials and products, the lack of service life information, and the timeliness of energy use and specific emissions of its various energy forms.
The construction emissions database maintained by the Finnish Environment Institute was supposed to provide reliable, up-to-date initial data for assessment, both in the form of environmental declarations for construction products and, for example, so-called generic data on energy use. However, the accuracy of the data or various uncertainties has not been checked by any independent party – a true “third party”. In the low-carbon assessments of practical sites using the database, the results have been reported with an accuracy of two decimal places, at worst without even knowing whether the reported integer was correct.
The EN standards that serve as reference standards for the Climate Change Regulation define functional equivalence, which allows for the comparison of alternative solutions: the solutions must have the same intended use and service life, as well as the same technical and functional characteristics.
However, the Ministry of the Environment has unjustifiably set only one individual limit value for each category of use and a calculation period of 50 years. In this way, the limit value regulation compares solutions that are even completely incompatible in terms of functionality.
For example, the same basket contains unequal options for longer-lived and short-lived, as well as more sustainable and less sustainable options. This does not promote sustainable construction or its true low-carbonization, when buildings should be designed for a lifespan of one hundred or one hundred and fifty years and at the same time be highly energy-efficient.
One-sided regulation of low-carbon can lead to compromise on quality or sustainability
Problems have been raised in the statements given to the various regulations of the low-carbon regulation. The Ministry of the Environment has not taken them into account because the political objective of the regulation was to be able to compare buildings made of different materials, even if these differ completely in terms of durability and other properties.
Among others, the Finnish Climate Panel has highlighted the shortcomings in reporting the actual emissions of wood. It has stated that in a situation where Finland's carbon sinks are not at the level of the carbon neutrality target required by the Climate Act or the obligations of the EU land use sector, wood does not have the climate benefits currently presented. The same fact also applies to the presentation of the carbon stock of wood as a carbon footprint in the Climate Assessment Regulation. Very critical comments have also been made on the very significant specific emission values of various energy forms that deviate from reality.
The proposed carbon regulation package could, at worst, lead to compromises on quality and various elements of sustainability. Solutions that appear low-carbon based on climate studies and limit values but are actually not sustainable in the long run can lead to unpredictable emissions.
For example, many solutions that improve long-term durability, energy efficiency, sound insulation or even reliability of supply mean greater use of materials during the construction phase and possibly also more emissions. The real emission and cost savings are achieved over a long service life.
Regulation must not kill innovation and enthusiasm for low-carbon development
Positive steps in preparing for future carbon regulation have included rapid and significant emission reduction measures in the real estate and construction sectors. These have already been guided by the EU's emissions trading scheme, among other things. Emission reductions in energy-intensive construction product manufacturing have been strongly supported by the much faster than expected decarbonization of energy in the first half of the decade.
Even during the construction boom, the construction phase has accounted for only 6-7 percent of Finland's total emissions, although this figure is subject to statistical uncertainty. These emissions have often been misleadingly lumped into the approximately 30 percent emissions pool of the entire built environment, the majority of which is accounted for by the energy use of the existing building stock.
Low-carbon regulation is very much a guardian. It must be absolutely material and technology neutral and encourage innovation, so that enthusiasm for the Kira sector's emission reduction work is maintained. A life-cycle carbon footprint assessment with credible, up-to-date data is a good tool for project-specific presentation of the benefits of different product and structural solutions. As part of politically motivated regulation, it is a bad host.
The author is a Master of Science (Engineering) and entrepreneur. He worked at the Finnish Construction Industry Association (RT) from 2003 to 2025 and served as an expert in European standardization of sustainable low-carbon construction and environmental impact assessment.
The original article was published in the Expert column of Rakennuslehti.
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