Delegated Regulation (EU) 2026/52, establishing a common EU methodology for calculating the life-cycle global warming potential (GWP) of new buildings, has been published in the Official Journal of the European Union on 4 May 2026. Adopted by the Commission on 16 December 2025 (C(2025) 8723) and subject to a two-month scrutiny period by the Council and the European Parliament, the regulation enters into force on 24 May 2026.
The policy context
Embodied carbon — greenhouse gas emissions tied to construction materials, processes, and end-of-life management — has become a central pillar of the EU's building decarbonisation agenda alongside operational energy performance. The revised EPBD (Directive 2024/1275/EU), adopted in May 2024, makes life-cycle GWP calculation and disclosure in energy performance certificates (EPCs) mandatory from 1 January 2028 for new buildings exceeding 1,000 m², and from 1 January 2030 for all new buildings. The scope covers the full emissions chain: production and transport of construction materials, on-site construction, operational energy use, maintenance, demolition, and end-of-life waste management, including reuse and recycling.
Until now, Member States have applied divergent national methodologies, making cross-border comparability unreliable. Delegated Regulation 2026/52 — which technically amends and replaces Annex III to the EPBD — delivers the harmonised framework the directive mandated, whilst retaining flexibility for national specificities. It promotes alignment with the Construction Products Regulation (CPR) and Ecodesign and Energy Labelling legislation, encourages the use of low-carbon and circular materials such as clean steel, timber, and recycled products, and permits the use of default values where product-specific data is unavailable.
REHVA's contribution
REHVA submitted formal comments on the draft delegated act on 30 October 2025, within the Commission's four-week public consultation (3–31 October 2025) on the Have Your Say platform. Our key messages were:
- Contain Member State flexibility. Excessive national discretion risks undermining the comparability the framework is designed to achieve; EU-level oversight of that flexibility is essential.
- Streamline mandatory life-cycle stages. Maintenance (B2) and Repair (B3) modules rely heavily on assumptions and contribute relatively little to overall GWP; their mandatory inclusion risks overcomplicating calculations without proportionate decarbonisation benefit.
- Fix Tier 2 as the minimum building element scope, leaving Tier 3 items — sanitaryware, IT systems, external lighting — voluntary for Member States, given the data burden on practitioners.
- Address CPR data inconsistencies. The absence of a designated background database produces significant discrepancies between national calculation sources, which must be resolved to ensure reliable and comparable results.
- Clarify on-site renewable energy allocation. REHVA recommends that the full installation be included in the calculation, limited to equipment connected behind the meter, to prevent divergent national approaches.
REHVA will continue to monitor implementation and engage with the Commission and national authorities as Member States incorporate the methodology into their frameworks ahead of the 2028 deadline. For further reading: