The national implementation of the Energy Performance of Buildings Directive (EPBD) is underway. The directive entered into force on 28.5.2024 May 29.5 and must be transposed into national legislation by 2026 May XNUMX. In Finland, a steering group of stakeholders and civil servants and subject-specific subgroups have been established to support the legislative work, whose expertise the authorities can consult and utilize in their work. This opportunity has not been used sufficiently in all respects.
According to its Article 1, the directive has the objectives of both improving the energy performance of buildings and reducing greenhouse gas emissions from buildings. The directive and its interpretative guidance published in summer 2025 emphasize this overall approach (“all measures improving the energy performance of buildings also reduce in parallel operational GHG emissions”). Saving energy and reducing greenhouse gas emissions go hand in hand.
We are now concerned that energy efficiency is being forgotten in national legislation. It seems that, according to the proposals, using low-emission energy could in certain cases mean forgetting to improve the energy efficiency of the building. The Ministry of the Environment is mainly emphasizing the reduction of emissions in the proposals that have been submitted for comments. The way it is now proposed dilutes the importance of energy efficiency measures in practice if the E-number can be reduced by using renewable energy alone.
The same building in a different location can pass the requirements with flying colors or remain without a permit, depending on, for example, the local district heating production methods. However, energy consumption and its costs will not be reduced in this way. In the selection of means, automation, consumption flexibility and energy storage have received too little attention. Improving the U-value of the walls is no longer helpful. Talteka has commented on the matter and is still trying to influence the matter in the regulatory monitoring and preparation groups.
The revised EPB Directive now also strongly includes indoor environmental quality (IEQ), which by definition takes into account the well-being of users based on, among other things, indoor temperature, humidity, air change and air pollutants. IEQ must also be taken into account in energy performance certificates, which must include the necessary instructions for improving the situation. Important points regarding IEQ include emphasizing air change and linking it to CO2 concentration in the instructions. The effects of poor air quality are described in the justifications in terms of health and comfort, and it is noteworthy to mention the increased risk of spreading airborne diseases. There is also recent domestic research evidence on this. A monetary value can be calculated for reducing sick leave, which facilitates investment decisions in a good indoor environment.
High indoor temperatures and relative humidity are also given weight in the directive as part of IEQ management. In Finland, buildings have traditionally been designed with the heating season in mind. In reality, we now live in a different climate than in the last millennium and this must be taken into account in many ways to limit excessively high indoor temperatures outside the heating season. The weather data for the design is being updated and all passive cooling methods must be utilized from early spring to late autumn.
Attitudes and mindsets also require renewal. Using blackout curtains and blinds during the day and increasing ventilation at night are examples of new summer routines. Indoor air will continue to be easily too dry in winter, but overall, higher humidity requires attention. Minimizing internal heat loads is also important for an increasing part of the year, as they have previously been thought to mainly reduce the need for heating. Mechanical cooling will in any case become more common.
More legislative proposals are coming up for comment in the autumn, and we will also see the potential impact of the summer comment round on future articles. There will be a rush if the national legislative work is to be completed with honor before the spring deadline. It would be worthwhile to involve stakeholders better in the work to take into account the best expertise and different perspectives already in the preparation phase.
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Ilkka Salo
CEO
ilkka.salo@rt.fi + 358 40 847 9907Finnish Building Services Industries and Trade (Talteka)
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