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For decades, European building policy focused mainly on reducing operational energy: heating, cooling, and other energy used during building operation. In recent years, however, the perspective has begun to shift. Buildings are increasingly seen as having climate impacts that extend beyond their operation, beginning with material extraction and manufacturing and continuing through demolition and end-of-life processes.
Within this view, buildings are understood not only as energy consumers, but also as long-term stocks of materials and emissions. Embodied carbon—the emissions associated with materials and construction—therefore represents a growing share of the climate impact of new buildings, sometimes accounting for up to half of total life-cycle emissions.
This shift is now reflected in European regulation. Recent revisions to the Energy Performance of Buildings Directive (EPBD)—the EU’s main law aimed at decarbonizing the building stock by 2050—introduce the requirement to calculate and disclose the life-cycle Global Warming Potential (GWP) of new buildings, meaning their total contribution to global warming over their life cycle. The requirement will apply from 2028 for buildings larger than 1,000 m² and from 2030 for all new buildings.
Under this regulatory framework, carbon stored in materials becomes particularly relevant, as some materials not only emit carbon during production but can also store it. This has drawn particular attention to a wider range of materials, especially biogenic ones such as timber and other plant-based materials, which store carbon captured during plant growth and can keep it locked in buildings for decades. While many of these materials have long histories in construction, they are now being revisited through advances in processing, engineered formats, and performance standards. Other materials are also gaining importance, including low-carbon steel and cement and mineral materials such as lime. The discussion thus expands beyond operational energy to include both the carbon associated with materials and the carbon that may remain stored in them during a building’s life.
The EU has regulated building energy performance for more than two decades. Between roughly 2021 and 2024, however, regulation began to integrate material-related emissions and full life-cycle carbon much more explicitly.
The EPBD recast is the central instrument, but it now interacts with several other policies shaping the sector: the Construction Products Regulation, which establishes rules for declaring the environmental performance of construction products; the EU Emissions Trading System (EU ETS), which prices CO₂ emissions from carbon-intensive industries such as steel and cement; the Carbon Border Adjustment Mechanism (CBAM), which applies a carbon adjustment to certain imported materials; and green public procurement rules that can prioritize low-carbon materials in public projects.
Together, these policies bring increasing attention to the carbon associated with materials throughout a building’s life cycle. In practice, this means assessing a building’s life-cycle emissions using standardized indicators such as life-cycle GWP (kg CO₂e/m²) and environmental data such as Environmental Product Declarations (EPDs).
Implementation differs between countries—some introducing emission limits while others rely on reporting requirements or incentives—but a common European framework is emerging. The climate impact of materials, including the carbon they emit or store, is therefore becoming an increasingly important factor in building regulation and design decisions, increasing the need for reliable and well-structured material data.
Despite its growing prominence in policy discussions, carbon storage in materials remains a technically debated topic. The central issue is the duration of storage. A material may store carbon for the lifetime of a building, but this does not necessarily imply its permanent removal from the atmosphere.
In biogenic materials such as wood, the CO₂ absorbed by a tree during growth can remain stored for decades while the material is in use. That carbon may be released again if the material is burned, decomposes, or is destroyed at the end of the building’s life, making the climate benefit potentially temporary. Pressure to improve carbon metrics can also lead to design choices that prioritize accounting outcomes while generating other unintended impacts.
For this reason, Life Cycle Assessment (LCA) methods continue to evolve, defining how biogenic carbon is accounted for, how end-of-life scenarios are modeled, and how temporary storage is treated. Clear accounting rules, reliable data, and verification are becoming increasingly important to ensure that life-cycle assessments remain consistent and comparable across projects and materials.
This evolving framework is not only about measuring emissions more precisely. It reflects a broader shift in climate policy: materials are increasingly understood as active components of a building’s carbon balance, turning material choices into climate decisions. As a result, reliable data and transparent life-cycle assessments are becoming essential for informed material selection.
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