The June 2025 issue of Rakennuslehti featured an article on EU-level and national carbon regulation of buildings – carbon footprint calculation and the associated limit value control. The article clearly highlighted the pain points of the Ministry of the Environment’s long process of national regulatory development, which began in 2017. These will continue to arise from updates to the input data and default parameters related to materials and energy use in carbon footprint calculation, as well as from refinements to the calculation method itself.
The ministry's project – a roadmap for low-carbon construction – is now receiving some kind of interim decision after Finland sent a government decree on the carbon footprint limits of new buildings to the EU Commission's notification process in September. A response is expected later this year. At the same time, the Ministry of the Environment's decree on the climate assessment of buildings, i.e. the calculation of their carbon footprint, will come into force at the beginning of 2026. It has been found that there are still many gaps in the decrees, for example, regarding who is ultimately sufficiently qualified to calculate the carbon footprint and who is qualified to declare the legally correct results.
Carbon regulation is also being mixed up by the reformed energy efficiency regulation for buildings, which, based on an EU Commission directive, will include the presentation of the carbon footprint value alongside the energy class by the end of the decade. At the turn of the year, the Commission will issue its delegated regulation on the carbon footprint calculation method that EU member states must use. Certain exceptions will likely be allowed, but the Commission will outline the rules for the calculation method and the production of its input data, referring to the relevant EN standards.
In its Climate Assessment Decree, the Ministry of the Environment has defined the calculation method to be applied from the beginning of January 2026 as a continuation of the previous revised versions. However, the next update is expected to be carried out already next year, now based on the Commission's calculation method. It seems that even next year, Finland will not be able to calculate the carbon footprint of buildings using a harmonised method that would produce statistically comparable information on the carbon footprint of buildings of different types and with similar life cycle characteristics. The confusing situation seems to continue later on.
The problems with carbon regulation are also the single limit value for the intended use category and the mandatory 50-year calculation period presented in the regulations. The same limit value applies unequally to technically and functionally even completely comparable alternatives. For example, solutions with poorer long-term durability and energy efficiency would be preferred and better ones would be penalized, which cannot be credibly justified even by the acute need to reduce carbon emissions. The EN reference standard for the EU Commission's calculation method defines the functional equivalence that allows for the comparison of alternative solutions. According to it, the compared solutions must have the same intended use and service life, as well as the same technical and functional characteristics.
In its comments, the Construction Industry RT has listed situations in which it should be possible to deviate from the individual limit value of the regulation. The ministry has now included these in its draft regulation sent for notification to the EU Commission for the sake of reason. The carbon footprint limit value per use category should be exceeded by a maximum of five percent if the design and implementation of a new building below the limit value is particularly difficult due to the characteristics of the building, its purpose or location, and due to compliance with planning regulations that significantly increase the carbon footprint of the building. In addition, the same excess rule applies to additional emissions caused by the implementation of life cycle features that differ from conventional construction and promote longevity. Of course, one can ask how the 5% excess rule was defined; why not 10% or something else, when the justifications for the excesses must be presented on a project-specific basis in any case.
Another necessary additional flexibility added to the regulation is that the limit value may be exceeded when it is particularly difficult to fall below the limit value due to the height of the building and the design and implementation of load-bearing and stiffening structures is particularly difficult due to the exceptionally demanding location. The permitted exceedance of the limit value may be as much as the special situation in question causes a necessary increase in the carbon footprint, although the determination of this remains subject to interpretation on a case-by-case basis. The impact of construction conditions on the carbon footprint has also not been addressed.
It should be noted that the derogation rules made to the limit value regulation proposal now aim to fill in the missing rule in the EN standard for carbon footprint calculation regarding the comparability of different alternative solutions. In this way, the limit value set by use category, or in fact the modified limit values, also take into account various factors of life cycle sustainability. Logically, higher emissions should be allowed for alternatives with better and more sustainable life cycle characteristics. However, their carbon footprint should not even be calculated for 50 years, but for the actual service life. Therefore, the calculation bias remains.
Throughout the Ministry of the Environment's long regulatory project, the construction industry and the construction products industry have developed their operations and products to be lower-carbon in a market-driven manner. This has happened without compromising the life cycle quality and sustainability of the building over its long service life. In their previous comments, the construction industry RT and Rakli proposed green deal-type project-specific guidance as an alternative to problematic regulation aimed at individual use-class-specific limit values. This did not suit the Ministry of the Environment. We are now in a situation where prematurely launched carbon regulation has to be corrected due to both the Commission's own regulation and the practical concerns expressed by operators in the rental sector.
The text has been published in Rakennuslehti.
Jani Kemppainen
Manager, Technical Regulations and Legislation and Quality
jani.kemppainen@rt.fi + 358 40 541 8090Building Construction Industry Association
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