Update on whole life carbon regulation of constructions in Denmark

Danish Political Agreement Tightens the Limit Values for New Buildings and Extends the Impact

Publiceret 04-06-2024

The Danish government and a broad political majority have agreed that Denmark from July 2025 will tighten the limit of how much CO2e one can emit per m2 per year for new buildings. The new average limit value on 7,1 kg CO2e/m2/year is more ambitious than the Danish National Strategy for Sustainable Construction from 2021 mandates. The agreement includes varied limits for different building types and an expansion of building types included by the demands, as well as a focus on the specific emissions from construction sites. Furthermore, the agreement contemplates a holistic revision of the existing Danish building regulation.

Tightening of the Agreed National Strategy

In 2021, Denmark agreed on a National Strategy for Sustainable Construction, where it was decided to introduce limit values for construction. According to the strategy, Denmark's initial limit value of 12 kg CO2e/m2/year will be negotiated and tightened gradually.

Leading up to the negotiation of a new limit value in 2025, the Danish construction industry gathered to demand an even tighter CO2e-regulation than the strategy mandates, arguing that the industry is ready for an ambitious transformation.

85 % Must Perform Better

After negotiating, the Danish government agreed on four different limit values depending on the type of building and its size. The average CO2e limit is set at 7.1 kg CO2e/m2/year, meaning that approximately 85% of the new constructions covered by the requirement must perform better in terms of climate impact compared to 2021.

One of the four categories of the building typologies are single-family homes, townhouses, tiny houses, and those vacation homes which are over 150 m2 they will see a new limit value from July 1st 2025. From that day the limit will be 6,7 kg CO2e/m2/year with the more strict CO2e-requriments in 2027 (6,0) and 2029 (5,4). See the table below for an overview of types of buildings being effected by the new agreement:

Kg CO2e/m2/year
Limit value General Buildings
Holiday homes under 150 m²
Single-family houses, row houses, tiny houses, and holiday homes at least 150 m²*
Apartment buildings
Office buildings
Institutions (e.g., schools)
Other new constructions
Independent limit value for the construction process
Total limit including construction process

*The 150 m2 limit only accounts for holiday homes

Here are some other highlights from the agreement:

The Scope of New Construction Covered by the Limit Value is Expanded

To increase the ambition level of the agreement, the scope of new construction that is subject to the CO2e limit value is expanded. The limit value for 2025 will also include holiday homes and unheated buildings over 50 m², such as parking garages and warehouse buildings. Tiny houses will be subject to the limit value for single-family houses.

For apartment buildings, office buildings, institutions, and other types of construction, extensions will also be covered by the limit value. For single-family houses, row houses, tiny houses, and holiday homes, however, only extensions over 250 m² will be covered by the limit value.

The intention behind this is to avoid single-family houses, apartment buildings, and social housing from bearing a disproportionately large share of the costs associated with the green transition of construction.

Certain critical infrastructure buildings are exempt from complying with the limit value, but the climate impact of these buildings must still be documented. The exemption includes, among others, waterworks, prisons, the Defense's operational buildings, and hospitals.

Independent Limit Value for the Construction Process Corresponding to 1.5 kg CO2e/m²/year Will Be Introduced

With the new agreement parties have agreed to extend the requirement to include the climate impacts from the construction process (modules A4 and A5) in order to reduce energy and fuel consumption from the transport of building materials to the construction site, as well as internal transportation on the construction site, and to reduce the amount of material waste.

LCA in Denmark

The climate impact of a building is calculated based on a life cycle assessment (LCA). An LCA consists of five phases with associated modules that reflect the different processes in a building's lifespan. The Danish CO2e requirement introduced in 2023 includes climate impact from production, parts of the usage phase, as well as pre-treatment of waste and disposal (modules A1-A3, B4, B6, C3, C4).

With the new agreement parties have agreed to extend the requirement to include the climate impacts from the construction process (modules A4 and A5) in order to reduce energy and fuel consumption from the transport of building materials to the construction site, as well as internal transportation on the construction site, and to reduce the amount of material waste.

In the future, a limit value for the construction process will be set at a level where approximately half of all construction sites must perform better in terms of climate impact compared to 2021. This means that an independent limit value for the construction process corresponding to 1.5 kg CO2e/m²/year will be introduced.

If you want to know more about the construction site, check out our work package focusing on this.

Implementation of a Fundamental Revision of the Building Regulations

Due to the stricter CO2e requirements, a thorough revision of the Danish building regulations (BR18) is necessary. This is because the current safety and health requirements can complicate the practical compliance with the new CO2e requirements. Analysis will be made on how to balance the different requirements in the best possible way. The revision must therefore ensure that the building regulations can be practically complied with while considering the price of construction and the feasibility of building.

Promoting Conversion of Existing Buildings

As part of the revision of the building regulations, new rules must be developed to make it easier to utilize existing buildings through remodelling, renovation, and changed use of existing structures. These new rules should be applicable instead of the rules that apply to new constructions. To promote renovation over demolition, the agreement parties agree to investigate if it is possible to adjust the energy requirements for transformations of existing buildings to match the requirements for major renovations. By mid-2026, the agreement parties will receive an overview of proposals to promote the renovation of existing buildings in order to discuss ways to further encourage renovation.

It has also been decided to investigate the possibility of establishing a scheme where the municipality can refuse a demolition permit when it is deemed appropriate to preserve the building for valid reasons. In this context, it will also be examined whether a scheme can be established where the building owner is charged a fee for the demolition of these buildings, corresponding to the environmental and climate impact that the demolition would cause.

Gradual Implementation and Setting of Limit Values

The limit value will be tightened by approximately 10% in 2027, corresponding to a requirement of about 6.4 kg CO2e/m²/year for e.g. family houses. In 2029, the limit value will be further tightened by approximately 10%, corresponding to a requirement of about 5.8 kg CO2e/m2/year. These limit values should be set based on the latest knowledge and data.

Read the full Danish agreement here (in Danish).

Useful Nordic Regulatory Experiences to Implement EU Directive

In 2022, Norway and Sweden were the first countries to demand a calculations of the climate impact from construction. Denmark followed in 2023 also with a demand to declare the climate impact from new construction. As the first Nordic country Denmark also put a limit to how much CO2e/m²/year one could emit for new buildings over 1000 m2. Several Nordic countries either demand or have plans to demand climate declarations and some also include a limit on how much CO2e/m²/year one can emit.

See an overview of Nordic regulation on the climate impact from new construction here

The detailed experiences from introducing these regulations are especially relevant as the European revised Energy Performance of Building Directive (EPBD) includes mandatory climate impact assessments for buildings greater than 1000 m2 in 2028, and all buildings in 2030. By 2027, EU member states must publish a roadmap for progressive carbon limit values for new buildings towards the EU climate neutrality goal in 2050. By 2030, binding carbon limits have to be introduced.

Across the Nordic countries different types of public private partnerships or industry initiatives have contributed to the development of these regulations and related roadmaps.

See an overview of Nordic sector initiatives here