Jarek Kurnitski
REHVA Technology and Research Committee
Tallinn University of Technology
jarek.kurnitski@taltech.ee

 

On 30 June 2025, the Commission adopted a support package offering practical guidance to help EU countries implementing and transposing the Energy Performance of Buildings Directive into national law by 29 May 2026. This package consists of 13 guidance documents dedicated to specific topics, all available from EPBD main webpage[1]. In the following we look on two most technical documents which are supported also with REHVA recent documents. These cover relevant Indoor Environmental Quality (IEQ) parameters and Zero Emission Building (ZEB) requirements calculations, the topics where REHVA Technical Guidance for EPBD Implementation Task Force has intensively worked during last years.

New provisions for indoor environmental quality (IEQ) and their possible implementation options are explained in the EPBD guidance document: Technical building systems, indoor environmental quality and inspections (Articles 13, 23 and 24)[2]. As there is new definition in EPBD for IEQ according to which a minimum scope of IEQ addresses thermal comfort and ventilation/indoor air quality domains, the guidance document provides a comprehensive table of relevant IEQ parameters when setting design requirements (e.g. in line with Articles 7(6) and 8(3)), conducting commissioning, performing monitoring (e.g. in line with Article 13(5)), and conducting inspections (in line with Article 23), Table 1. Next table in the guidance document provides recommended ranges for IEQ parameters for new buildings based on a medium expectation of occupants that corresponds to EN 16798-1 Category II values. As whole the document provides about 10 pages overview explaining how IEQ can be controlled at design, commissioning, monitoring and inspection stages and which parameters are feasible to be measured directly, and which ones can be assessed indirectly. To go further from this guidance document explaining principles of IEQ, REHVA has developed a model regulatory text to support harmonized implementation of EPBD IEQ provisions. This REHVA document provides an example on how EPBD IEQ provisions can be addressed in the regulation and relevant requirements set with measurable indicators[3]. Together with European Commission guidance document a model regulatory text should serve as a practical example of evidence based IEQ useful minimum implementation.

Table 1. Relevant parameters for Indoor Environmental Quality as proposed in EPBD guidance.

Indicator

D

C

M(a)

I(a)

Description and references

Thermal Comfort

Operative temperature

X

(X)

Possible alternative to air temperature in the monitoring stage. Uniform temperature of an imaginary black enclosure in which an occupant would exchange the same amount of heat by radiation plus convection as in the actual non-uniform environment. Ranges are provided as a function of building type, season, and dependent on the cooling system (with or without) by the Predicted Mean Vote (PMV) and adaptive comfort models. (EN ISO 7730, EN ISO 7726).

Air temperature

X

X

X

X

Required in the assessment of other indicators. Air temperature can be used in long term measurements if corrected for large hot or cold surfaces to determine the operative temperature. Indoor temperatures above 18 °C during the heating season will have significant health benefits. (EN ISO 7730, EN ISO 7726).

Air velocity

X

It influences general thermal comfort and local thermal discomfort due to draught. Comfortable air velocity generally below 0.2 m/s. In buildings with mechanical cooling artificially increased air velocity under personal control (e.g. fans) can be used to compensate for increased air temperature under summer comfort conditions (operative temperature >25 °C). (EN ISO 16798, EN ISO 7726). A comfort area for increased air velocity (<0.8 m/s) without personal control for temperatures above 25.5 °C is defined in ASHRAE 55(b).

Relative humidity

X

X

Composition of the air in terms of water vapour in relation to the maximum amount it can hold at a given temperature. It also influences air quality. Very low RH (<20%) can cause irritation of eyes, nose, and throat and increase sensitiveness to infections. Persistent dampness, condensation, and excess moisture (RH > 70%) can cause building damage and microbial growth. It is recommended to limit absolute humidity to 12 g/kg (EN ISO 16798, EN ISO 7726).

Indoor air quality

Ventilation rate

X

X

 

X

To be addressed as part of system inspections pursuant to Article 23. Supply or removed air from space for the purpose of controlling air contaminant levels, humidity, perceived air quality or temperature within the space (EN 16798-1). If critical sources for health are identified, it must be checked that they remain below the health threshold values. Minimum 4 l/s per person is prescribed during occupied hours; 0.15 l/s per mduring unoccupied hours. Typically measured from supply and extract terminals.

Carbon dioxide

X

X

Proxy for ventilation effectiveness in spaces where people are the main source of pollution. Indoor COconcentration should be adjusted according to the outdoor COconcentration. It should not exceed 1350 ppm above outdoor concentration. Typically measured in extract terminals. (EN 16798).

PM2.5

X(c)

X(d)

Particulate matter where particles have an aerodynamic diameter equal to or less than 2.5 μm. It can be generated indoors from combustion appliances or outdoors and has harmful effects on human health. Air filtration is required to control particulate matter from outdoor sources. Indoor particulate matter is controlled by reducing emission sources (e.g. electric instead of gas stoves) and adequate ventilation. Ideally below an annual mean of 5 μg/m3. Incremental steps are proposed for PM2.5 limits (35, 25, 15, 10, 5 μg/m3) (EN 16798, WHO).

Formalde-hyde(e)

X(f)

Major sources are building materials and consumer products (e.g. furniture, cleaning). It can cause sensory irritation and respiratory health risks. Use of low-emitting building materials and products can reduce exposure. Measured near potential sources such as furniture and flooring (EN 16798, WHO).

Nitrogen dioxide

X(f)

Originating from combustion. Indoor contamination may be possible from attached garages and indoor combustion sources, in which cases sensors and/or measuring requirements would be recommended. It poses health risks related to the respiratory system. Measured near potential sources such as kitchens and garages. A 1 h mean limit of 200 μg/mand annual mean of 40 μg/mare proposed (EN 16798-1, WHO).

Radon

X(f)

 

 

 

Human carcinogen, originating from decay of radium in soil and rocks. Reference level of 100 Bq/m(or 300 Bq/mbased on prevailing country-specific conditions). Measured in the lowest occupied level of the building (EN 16798, WHO).

Carbon monoxide

X(f)

Originating from combustion. Acute exposure-related reduction of exercise tolerance and increase in symptoms of ischaemic heart disease. A 24-hour mean limit of 4 mg/mis proposed with an interim target of 7 mg/m(EN 16798, WHO).

Lighting(g)

Daylight provision

X

Daylight should be a significant source of illumination as it is favoured by building occupants, contributing to physiological well-being. Daylight can reduce energy use for electrical lighting. Shading devices should be provided to reduce visual and thermal discomfort in spaces where activities comparable to reading, writing, or using display devices are carried out. Daylight can be quantified using spatial daylight autonomy (sDA), representing the level of illuminance achieved from daylight across a fraction of a reference plane for a fraction of daylight hours within a space. An annual sunlight exposure (ASE) (h), i.e. percentage of regularly occupied floor area with illuminance higher than 1000 lx, lower than 10% is desired to prevent glare and overheating (EN 17037).

Glare probability (DGP)

X

Used to assess protection against glare in rooms where activities such as reading, writing, or screen time take place. Glare represents discomfort or a reduction in the ability to see details or objects, caused by an unsuitable distribution or range of luminance, or by extreme contrasts. It can be quantified using daylight glare probability (DGPe) in rooms with vertical or inclined daylight openings and is evaluated across the regularly occupied floor area. If DGPe exceeds 0.45 in more than 5% of the occupation time, glare protection shall be installed or other interventions (i.e. change in orientation, field of view) shall be implemented (EN 17037).

Illuminance

X

 

 

 

Luminous flux incident on a surface per unit area. The areas where an adequate illuminance level should be ensured are task and activity areas, the surrounding and background areas, walls, ceiling, and objects in the space. Required values are dependent on type of task or activity area. For writing, typing, reading, and data processing an illuminance of 500 lx is required (EN 12464–1).

Acoustics(g)

Sound pressure

X

X

Equivalent continuous sound pressure level from mechanical equipment. Sound pressure can be normalized using the reverberation time and standardized to a reference reverberation time. It does not include outdoor noise. Investigated at representative points in the occupied zone (EN 16798, EN 12354-5, EN 16032, EN 10052).

Sound reverberation time

X

X

Duration required for the space-averaged sound energy density in an enclosure to decrease by 60 dB after the source emission has stopped. It takes into account the sound absorption of the room. Reverberation times over 1 s produce loss in speech discrimination and make speech perception more difficult and straining (i) (EN 12354–5, EN 16032, EN 10052).

D = Design, C = Commissioning, M = Monitoring, I = Inspection

a) In assessing indoor values, consideration of outdoor values for air temperature, humidity, COand PM2.5 as well as of other outdoor pollutant levels such as CO, NOis necessary. Further indicators may be monitored or inspected in order to validate IEQ management performance.

b) Khovalyg, D., et al., 2020. Critical review of standards for indoor thermal environment and air quality. Energy and Buildings, 213, p.109819.

c) For non-residential buildings filters are specified in EN 16798-3

d) PM2.5 continuous monitoring may only be needed if the outdoor PM2.5 pollution levels are above those set in EN 16798-1 guidelines. If above, particulate matter should be controlled with filters in the ventilation system and infiltration through building envelope should be checked. Indoor pollution levels may also need to be considered (e.g., for residential buildings, in case of local space heaters with indoor emissions).

e) Volatile Organic Compounds (VOC) refer to a variety of chemicals that can originate in a building, e.g. from building materials and furniture. They are not included here as an indicator, as newer requirements are more focused on specific indicators such as formaldehyde, benzene, etc.

f) Where relevant, based on national, regional, or local health protection priorities or on specific identified issues which should be considered in the design and operation of the building. For example, nitrogen dioxide and carbon monoxide would be relevant when designing indoor parking areas, or if the building is located in polluted areas or in case of indoor pollution sources. Where relevant, e.g. in the case of specific issues such as indoor problems caused by combustion devices, measurement could be needed to address these specific pollutants. A map of the indoor Radon concentration is provided by the Joint Research Centre of the European Commission (http://data.europa.eu/89h/jrc-eanr-02_indoor-radon-concentration).

g) Optional element of IEQ definition: it is recommended that it is at least addressed in the design of new buildings.

h) Illuminating engineering society, IES LM-83-12, 2012.

i) World Health Organisation (WHO). Guidelines for community noise, 1999.

 

Zero Emission Buildings thresholds and other indicators calculation is explained in another European Commission guidance document: Zero Emission Buildings (Articles 7 and 11)[4]. This document explains the calculation principles of ZEB energy demand (total primary energy) threshold, operational greenhouse gases threshold and total primary energy covering requirement. It is shown that EPBD includes a flexibility to calculate these indicators with two possible assessment boundaries, either with building assessment boundary or alternatively with building site assessment boundary. If the building assessment boundary of EN ISO 52000-1 is used, additional multipliers for on-site renewable energy generation and ambient heat captured by heat pump are applied with a reference to REHVA Primary Energy and Operational CO2 calculation guidance document[5]. In this fashion, calculation examples provided with two assessment boundaries provide the same results. To have an idea of ZEB calculations, an example from the EPBD guidance document is reproduced in Figure 1 and Table 2.

Figure 1. Calculation example of ZEB multifamily apartment building used in the EPBD guidance document showing two possible options for the assessment boundary.

Total primary energy calculations conducted in Table 2 show how zero multipliers are applied for the rooftop PV and ambient heat in Case 1. There is also a flexibility in EPBD to reduce PV electricity used on-site for non-EPB uses with recommended PEF=1.0. Another flexibility is to take exported PV electricity to grid into account or not to take. If considered, PEF=0.9 is recommended. It can be seen that in Case 1 and 2 total primary energy result is 16.7 kWh/(m2.y). Total primary energy covering on annual bases is coming from rooftop PV, ambient heat, and renewable and nuclear fractions of the grid electricity resulting in 53.6 kWh/(m2.y). Therefore, the total primary energy covering requirement is fulfilled as 53.6 > 16.7.

Table 2. Calculation example from European Commission EPBD guidance document: Total primary energy use of the building and compensation of the non-compliant energy from the grid by the renewable energy produced on-site and either exported to the grid or used on-site for non-EPB uses.

 

Examples provided in the guidance document explain in detail calculation principles for the total primary energy threshold, operational greenhouse gas emissions and for the requirement to cover total primary energy use from Art 11 a) - d) options. This should ensure that everybody will get the same result.

There is an issue with total primary energy factors which can lead to some problems with district heating. It should be noted that total PEF cannot recognise the benefits of district heating and cooling, and the positive influence of renewable energy. A classic example of a heat pump in a building or in a district heating plant should lead to the same energy performance if the efficiency is the same and there are no network losses, but this is not the case if total primary energy factors, which cannot be by the definition smaller than one, are used. This problem can be tackled by using EPBD flexibility allowing to use weighting factors instead of total PEF. Possible solution is to replace total primary energy factor of district heating with relevant weighting factor and still to use total primary energy factor for grid electricity to ensure equal treatment of district heating and heat pumps.

Jarek KurnitskiPages 11 - 15

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