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Buildings Performance Institute Europe, BPIE ASBL

BPIE

The Buildings Performance Institute Europe (BPIE) is a not-for-profit think-tank with a focus on independent analysis and knowledge dissemination, supporting evidence-based policymaking in the field of energy performance in buildings, throughout Europe and beyond.

Lobbying Activity

Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings

24 Oct 2025

BPIE welcomes the publication of the draft Delegated Act setting out a Union framework for the national calculation of life-cycle GWP of new buildings and is generally supportive of its contents. Harmonisation The main purpose of the EU framework is to create consistency and comparability across Member States by harmonising whole-life carbon calculation methodologies. Establishing comprehensive minimum requirements, particularly with regards to the included life-cycle modules, building elements and the data hierarchy, supports harmonisation of national WLC regulation implementing the EPBD. This common foundation ensures a baseline level of consistency, enables comparison and brings down cost of compliance while still granting Member States the freedom to customise certain aspects according to their unique national context. In our view, the draft of the Delegated Act adequately fulfils this purpose, which is why we recommend to keep the comprehensive approach taken in it. Reporting format It is positive that the results of the GWP calculation are to be reported separately for the different life-cycle stages, but further disaggregation is possible and recommended. BPIE recommends that the Delegated Act also requires Member States to collect and disclose separate values for GWP-fossil, GWP-bio and GWP-LULUC in the EPC, as a complement to the GWP-total. Furthermore, results should be expressed both in absolute (total emissions) and relative (per floor area) values. While not all these values can be displayed on the front label, they can be included in the technical information in the EPC to provide more context, support interpretation of the results and inform decision-making. BPIE also recommends that Member States collect detailed data beyond the figures displayed in the EPCs. Collecting additional data is an important opportunity for building capacity and raising knowledge about the national building stock, that should not be missed. Such data will be needed for the creation of well-designed policy roadmaps. The Delegated Act should include wording that strongly encourages Member States to collect data beyond what will be disclosed in the EPC. Supporting circularity Increasing circularity in construction is an important contributing strategy for bringing the sector in line with climate commitments. In its current form, the Delegated Act makes no reference to supporting circular approaches but relies entirely on the standard EN 15978 in this regard. The Commission must therefore ensure that the standard provides sufficient clarity around how to account for the carbon savings from circular construction approaches. It should facilitate the inclusion and recognition of reused and recycled materials to achieve immediate emission reductions, while encouraging practitioners to model and demonstrate the potential benefits of design-for-disassembly and reuse as additional life-cycle scenarios for the end-of-life stage. Review The EU framework for the national calculation of life-cycle GWP will need to be reviewed periodically to reflect future revisions of the EN standard, improved data availability, and changes in market practices. BPIE recommends that wording on such planned reviews is introduced in the Delegated Act.
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Response to Fitness check – energy security architecture

25 Nov 2024

BPIE's feedback is attached in the enclosed PDF.
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Response to Action plan on accelerating Heat Pump market and deployment

26 May 2023

Heat pumps may have a crucial role in the decarbonisation of the building stock in the EU, the uptake of renewable heating and the reduction of our dependency on fossil fuel imports for heating. To realise their full potential, it is important to understand if residential buildings, and in particular their building envelopes, are fit for heat pump installation and deployment. Energy performance certificates (EPCs) have an important role in conveying this information, especially to building owners. BPIE has prepared a study which 1. Defines an approach to measure the heat pump readiness of buildings, tested on 30 target buildings across the EU 2. Assesses how a break in heating supply may affect indoor temperature and comfort period in target buildings 3. Proposes the heat pump readiness indicator (HPRI) and ways to include it in national EPCs, including a list of policy recommendations Key takeaways - The heat pump readiness of a building is defined as the share of a buildings annual space heating demand that can be covered by energy extracted from outside air using a reference heat pump. - Building renovation can improve the energy efficiency of the building envelope, and by installing low-temperature heat distribution systems, can help improve the heat pump readiness of target buildings. - Deep renovation would in most cases eliminate the need for a backup system, allowing the reference heat pump to completely cover heating demand. Depending on the climate zone and the building type, a medium range retrofit may be sufficient to allow the reference heat pump to completely cover heating demand and reduce temperature drops sufficiently to keep buildings comfortable enough - Renovated buildings will have a longer comfort period after the heating cut-off. Deep renovation can significantly reduce temperature drops when the heating supply is cut off, keeping buildings comfortable for a longer period. - National EPCs do not explain heat pump readiness, although they may capture information on heat pumps. - Heat Pump Readiness Indicator (HPRI) should be included as a label on a buildings EPC, allowing owners/occupants to easily assess and understand the imminent and future potential of a heat pump, and helping to communicate other potential benefits. - The energy that heat pumps can obtain from certain sources, such as outside air, is still not classified as renewable in some national EPC schemes. To ensure consistency, such energy sources should be classified in the same way across the EU. - Introducing the HPRI to EPC schemes should not require additional data collection efforts. Existing EPC schemes contain most of the data required for assessing a buildings heat pump readiness. - Installation of heat pumps triggered by the HPRI will increase buildings demand response and comfort, and could increase the renewable capacity of the energy grid. - An HPRI assessment will enhance the quality of EPCs. Adding a HPRI will make EPCs more accurate through reliable data. Despite the barriers to adding the HPRI to EPC schemes, EPCs are important tools to evaluate and easily communicate a buildings heat pump readiness. More information in the full study available in the attached PDF and at: https://www.bpie.eu/wp-content/uploads/2023/04/Full-report_Introducing-the-heat-pump-readiness-indicator.pdf
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Response to Review of the Construction Products Regulation

12 Jul 2022

BPIE welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR) and the opportunity to provide feedback. Our contribution is aimed primarily at addressing the sustainability performance of construction products and creating transparency and trust around their environmental credentials. Evaluating the environmental impacts of construction materials and products in an objective way and making available reliable and comparable information for building level whole life carbon (WLC) accounting are paramount for taking the right decisions to mitigate the climate change impacts of the building environment. In this sense, it is important that provisions of CPR and that of the Energy Performance of Buildings Directive (EPBD) are aligned so that the CPR will provide information to building-level whole life carbon (WLC) measurements and comply with the newly announced mandatory WLC assessment for new large buildings from 2027. Our detailed feedback is attached below.
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Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

12 May 2022 · Discussion on RE PowerEU Energy Savings Plan.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

23 Mar 2022

The proposal is a good working basis for improving the building renovation eco-system but doesn’t reflect the crucial role the EPBD should play within FF55. Unless proposed elements are strengthened, made more coherent & geared towards deep renovation, the recast will not deliver on climate objectives. BPIE welcomes the widening of the scope to include GHG emissions reduction in addition to energy performance. However, a more profound consideration of WLC emissions is missing & the reduction of operational GHG emissions focuses on fuel switch to RES while EE1 principle is not reflected. The 2050 vision should be a net-zero operational energy & net-zero carbon over the whole life cycle building stock. The proposal should go beyond considering embodied emissions through reporting towards addressing them & requiring their reduction. New buildings should be subject to WLC thresholds tightened over time, reaching net zero carbon emissions over entire life cycle around 2035. The upgrade of new built standard towards ZEB as of 2030 is a step in the right direction, but should go further & quicker on several points (lower max thresholds for primary energy use, deadline brought to 2025). The definition of deep renovation is welcome, but the EPBD fails to make it the default approach & to mainstream it in the design of other measures (MEPS, financing). The definition itself also raises concerns (which levels of max primary energy use to refer to, no consideration of the building starting point in terms of energy performance). MEPS are a suitable addition to increase the renovation rate of worst-performing buildings. However, MEPS should also be designed to increase the renovation depth. Without complementary mandatory provisions applying to buildings above class F & without a clear roadmap with milestones setting higher minimum performance levels beyond 2030/2033, there is a high risk that those buildings will be brought to class E by that date, but then locked-in at that level until 2050. This will not lead to a ZEB stock by 2050 and will not reduce energy poverty. H&C decarbonisation measures are too weak, leaving MS too much leeway or have deadlines not aligned with 2050 targets. MS must include in their renovation plans an overview of policies leading to a complete phase-out of fossil fuels in H&C by 2040: this reporting indicator should be upgraded to a real verifiable requirement. MS should be forbidden to provide any financial incentives for the installation of fossil fuel boilers already as of 2024. NBRPs bring several improvements (better governance system, common template facilitating comparability, shortening of the cycle from 10 to 5 years). They should deliver on a complete fossil fuel phase out by 2040 latest, and act as plans to increase the RES share in H&C in buildings substantially. Financing & TA is recognised as important but would have much greater impact if more clearly tied to stronger requirements on renovation depth & full decarbonisation. There is a high risk of sub-optimal use of financial & advisory resources, especially when referring to 30% savings as threshold for some programmes. BPIE applauds the introduction of a common template for EPCs, widening the scope of indicators & ensuring more comparability. One additional class (A+) should be added to account for positive energy buildings. However, all improvements made on rescaling/design might end up having no/little impact if the coverage of the building stock with EPCs doesn’t increase. There are also questions arising as to how current EPCs should be treated after 2026, which might hamper MEPS implementation. The usefulness of renovation passports is recognised. The provisions are a good starting point, but the development of a common EU framework needs to be strong & detailed enough to avoid any discrepancy between national schemes.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Bureau Européen des Unions de Consommateurs and

2 Dec 2021 · EPBD - Energy poverty

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

BPIE's feedback is attached in the enclosed PDF.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

BPIE welcomes the opportunity to provide feedback on the draft delegated regulation defining the technical screening criteria economic activities must meet to qualify as environmentally sustainable. BPIE would like to comment specifically on the draft provisions related to the construction and real estate activities. Considering the EU climate neutrality objective by 2050 and the recent increase of the 2030 climate target to a 55% cut of greenhouse gas (GHG) emissions, the purpose of the Taxonomy must be to help steering private capital towards zero-carbon investments, without creating emissions lock-ins for the next decades. For the building sector, this means supporting investments that are aligned with the objectives of the Renovation Wave, namely increasing the rate and depth of building renovations. With this in mind, it is unclear how the criteria for existing buildings proposed in the draft delegated regulation align and substantially contribute to these overarching climate mitigation objectives. In our view, the criteria should recognise investments which are aligned with the proposed 2030 GHG reduction objective to which the building sector is expected to contribute with a 60% reduction in emissions by 2030. BPIE’s modelling of GHG scenario pathways for the building sector until 2030 concluded that the rate and depth of renovation must significantly increase so that the sector can meet the desired targets. In this regard, the technical screening criteria should fulfil the “Fit for 55” requirement. BPIE recommends that the technical screening criteria are regularly reviewed and tightened. The selected metrics and thresholds must be robust, relevant, and easily adaptable to the evolving best practices and state of the art technologies in the construction sector. Importantly, to ensure a predictable regulatory environment, the ongoing tightening of the criteria for both new buildings and renovations should happen following a clear transition pathway and agreed timeline that supports the decarbonisation of the sector and enables the market to progressively and quickly build capacity and grow. The DNSH criteria represent an important additional set of criteria, however these need to be designed with proportionality and practicality in mind. As with the climate change mitigation criteria, the regulation should provide a clear pathway and end goal of how the DNSH criteria will evolve over time. We would recommend that the Sustainable Finance Platform work out the detailed criteria and the requirements to document compliance. BPIE also recommends putting in place measures and guidelines that will improve data availability and quality to set benchmarks, prove alignment and monitor overall progress made towards a decarbonised building stock. Finally, as the proposed technical screening criteria rely on national definitions of the rules and standards for nearly-zero energy buildings (NZEB), energy performance certificates (EPC) and “major renovations”, BPIE would like to point out that the corresponding provisions in the EPBD need to be revised, and carefully implemented and enforced, to ensure reliability, consistency and comparability across EU countries. This way, NZEB standards and EPCs will become reliable proxies to assess building performance and support green investment. Otherwise, the different levels of stringency between EU Member States will create an unlevel playing fields within the EU.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

7 Oct 2020 · Renovation wave

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

BPIE welcomes the opportunity to give feedback on the EED roadmap and would like to comment specifically on the provisions of this directive that are related to the building sector. First, the current provision on the renovation of central government buildings (Article 5) is too limited in scope to increase the renovations of the public building segment. This obligation should be further expanded, as the current scope only covers a minority of public buildings and leaves out, for example, the facilities of local authorities, and other buildings that offer a service to the public, such as hospitals, schools, and universities. Additionally, the current Article 5 only requires that those renovations achieve minimum energy performance requirements, which is clearly not in line with the overall objective set by the EPBD of achieving a highly-energy-efficient and decarbonized building stock by 2050. For that reason, the current provision should be amended to ensure that renovations bring the building to a much higher level of performance, such as the highest class in the energy performance certificate, or nearly-zero energy standards. As the EPBD will be reopened in 2021, BPIE suggests that a strengthened Article 5 is moved from the EED to the EPBD to ensure that this directive contains all the relevant provisions related to the building sector (similarly to the provision on renovation strategies that was initially included in the EED, but was moved to the EPBD with the last revision). Second, Article 18 on energy services is a key legal tool to support building refurbishments through energy service companies (ESCOs). On one side, strong implementation of Article 18 is the prerequisite to ensure the development of the ESCO market at the national level; on the other side, the review of the EED is the occasion to strengthen this key provision further. For example, a revised article could require every Member State to set up a public body that oversees ESCO functioning, is responsible for accrediting qualified ESCOs, and supports the creation of standardized contracts to apply EPCs in the residential sector. Additionally, a revision could include provisions for minimum qualifications of service providers to ensure quality installation in the renovation process, or mandated measurement and verification procedures. Furthermore, to ensure that a revised Article 18 fully contributes to unlocking the renovation market, it should put in place/be linked to mechanisms that support local authorities to unlock the local energy services market, including through specific technical assistance both to renovate public buildings and to aggregate residential renovations through energy performance contracting. For example, the EIB Advisory Hub could be better used to supporting local authorities in that respect.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

BPIE fully supports the European Commission’s intention to develop a Renovation Wave and believes that this initiative should have the objective of putting the buildings sector on a path towards climate neutrality by 2050, while supporting the EU economic recovery after the coronavirus pandemic in a way that is directly beneficial to citizens. First, we welcome the intent of taking a fully integrated approach across different areas and to consider the synergies across different sectors. In particular, in addition to the key pillar of reducing buildings’ energy consumption, the Renovation Wave should i) develop an integrated approach to decarbonising heating (and cooling) particularly in the residential sector, ii) mainstream digitalisation, both in relation to energy use and of the construction value chain, iii) devise measures to make buildings resilient to climate impacts, iv) look at the synergies with the transport sector both in terms of supporting electromobility and modal shifts, and v) consider resource efficiency and sustainability of construction materials. Second, BPIE agrees that the Renovation Wave should facilitate access to mechanisms to support the mobilisation of investments in building renovation. The proposal for a strengthened Multiannual Financial Framework and the proposed recovery measures through the Next Generation EU clearly increase available financing for the clean energy transition, including building renovations; however, there is, unfortunately, no specific earmark for building renovations. BPIE would welcome that the Renovation Wave clarifies how available funds and new resources can be mobilised, including at the national and local levels, to speed-up deep renovations. In particular, the Renovation Wave should detail and simplify the accessibility conditions and process to access finance, provide concrete solutions that encourage project aggregation, support the creation of innovative business models that blends different funding streams. Third, the focus on ensuring proper implementation and enforcement of the relevant legislation should be maintained. The great majority of EU Member States is late in submitting their Long-term Renovation Strategies and this is particularly concerning as those plans are the backbone of stronger actions towards the decarbonisation of the building stock. BPIE strongly encourages the European Commission to fully check the thoroughness of those strategy documents in its expected assessment and also to start infringement procedures if those are not submitted. Additionally, the Renovation Wave should also review the status of application of the implementation of the nearly-zero energy buildings obligation for new buildings occupied and owned by public authorities (since 1st January 2019) and clarify how the European Commission is preparing to monitor and enforce the enlargement of this obligation to all new buildings after 31st December 2020. Fourth, as no single measure can speed up alone the renovation of the EU buildings, BPIE encourages the Commission to devise specific measures to remove barriers and target the different segments of the building stock and diverse tenures. In this framework, we would recommend focusing on buildings providing essential services, such as hospitals and schools, and on the worst-performing residential buildings because renovating those is crucial to reduce energy poverty and support the most vulnerable citizens. Finally, the European Commission must first and foremost create the right framework to mobilise all the different actors in the value chain and make sure that their actions are aligned for the Renovation Wave. The building sector can successfully contribute to the EU climate neutrality, and economic recovery, only if all actors move in the same direction.
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Meeting with Kadri Simson (Commissioner) and

23 Apr 2020 · How building renovation can contribute to post covid-19 recovery, how to get renovation projects off the ground, how to remove regulatory obstacles and improve advice.

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

23 Oct 2017 · discussion Energy efficiancy financing platform