Instituut Natuur- en Bosonderzoek/Research Institute for Nature and Forest
INBO
The Research Institute for Nature and Forest (INBO) is the Flemish research and knowledge centre for nature, biodiversity and its sustainable management and use.
ID: 207972329605-55
Lobbying Activity
Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings
29 Oct 2025
We appreciate the European Commission's work on this important subject. However, in the interpretation of the EN 15978 (EN 15978:2011 Sustainability of construction works) there are inconsistencies on the biogenic carbon of products for the GWP calculations. Now producers are obliged to deduct the biogenic carbon (the positive storage of biobased materials that can be counted in module A of the life cycle assessment) in the end-of-life phase (C-module), because - as the reasoning goes - the material will decompose inevitably/be burnt. This reasoning is mainly based on what happens with classic building materials and goes completely against the CRCF directive that opens the possibility of CO2 certificates if carbon storage in products can be provided for >35 years - which is ideal for biobased building materials. There's currently absolutely no scientific proof or common indication that these biobased materials, upon dismantlement, are standardly burnt/ decomposed and thus releasing CO2 emissions again. So the biogenic storage of CO2 in biobased building materials (of the A-module) should be able to be calculated for the total GWP of a building, and this framework should make this explicit. To avoid carbon leakage (of end-of-life) a building material passport, an obliged take-back-program for producers that is written into the EPD, design-for-disassembly, or a carbon buffer (a 15-30% precalculated loss, depending on real life cases in dismantlement) can be proposed. As the ECTP mentions in its position paper: "By coupling rigorous measurement with credible trading platforms, biobased construction can shift from incremental decarbonisation to active carbon removal, capturing new revenue streams while accelerating the EUs net zero trajectory." The reference to the French system of ADEME is also important: "In ADEME it is stressed that long life wood systems and straw infill should be prioritised because their biogenic carbon can remain locked up for centuriesdirectly matching CRCF permanence rules." There are lots of concrete examples of long term storage in wood, straw, hemp,.. buildings. As also mentioned: "Nevertheless, current EPD templates seldom capture biogenic carbon storage, a key advantage of timber or mycelium based- systems. The CBEJU is therefore preparing a dedicated method to award separable CO storage in WLC -accounts accelerating timber payback. ". If, as currently happens, some countries do calculate the biogenic carbon separately and other EU countries do not, the biobased producers in the countries that are not counting, have a comparative disadvantage, and so in the light of the upcoming implementation of the EU CRCF directive, it would be coherent to make the biogenic uptake apparent in the EPD, and a factor to be calculated in the total GWP calculation, with an obligation to criteria like a buidling material passport, take back program, design-for-disassembly and/or carbon buffer, to avoid carbon leakage. We would like to stress that the upcoming 25 years are the window of opportunity to avoid very dangerous climate change. It therefore makes sense to build with biobased materials and keep the buildings as intact as possible where only transformations or top up's would be accepted, so long term storage is guaranteed (> 35 y). This is also in line with centuries of building culture of reuse & smart adaptation, that was only interrupted by the second half of the 20th century, where quick and wasteful building became a trend. In light of the Waste Framework Directive, the Circular Economy Package, and the insights from the Level(s) forum, it makes perfect sense to keep the biogenic uptake positive and visible in the GWP calculations. Thank you for your consideration.
Read full responseResponse to Roadmap towards Nature Credits
30 Sept 2025
A roadmap towards nature credits provides a useful basis to assess their credibility, scientific rigour, and potential contribution to nature restoration. However, nature credits are only one of several tools available to mobilise finance for nature protection and restoration. Other policy instruments remain decisive: for example, IPBES [1] confirms that environmentally harmful subsidies still far exceed current finance needs for restoration. Reducing these subsidies represents a key pathway for both halting the increasing financial needs for nature protection and restoration and for financing these needs. At the same time, the market for biodiversity credits is projected to mobilise only modest amounts, with associated design trade-offs [2,3] and potential unintended negative consequences for restoration outcomesespecially when credits are used for offsetting [4]. Focusing the debate primarily on marketable credit systems therefore risks diverting attention from more effective policy instruments. A more explicit embedding of nature credits within the broader set of innovative public and private financial tools could strengthen and balance the roadmap, ensure synergies and avoid trade-offs between these instruments. The current policy context is favourable for discussing such a system. A large body of standardised data is now being generated for baseline assessments and evaluations under the newly adopted Nature Restoration Regulation. These could support the issuance of credits, creating efficiencies and alignment with existing institutions and experts. Linking accreditation processes with knowledge institutes would also strengthen scientific capacity, especially for nature certification and credits in an urban and agricultural context. For certification and crediting of nature restoration to be effective, careful design is required [5]. Designing nature credits should take into account the priority framework described by ecological economists [6]: first ensure through sound and enforced regulation that enough nature is conserved and protected to safeguard our economy and society that depend on its contributions, second, ensure that benefits from nature are shared fairly to avoid injustices, and only in third place can nature markets be used to ensure an efficient use of nature. Transactions of the credits should also exclude secondary trade to prevent perpetuating or intensifying documented negative effects of financialization and commodification of nature [7,8,9]. Moreover, good design of nature certification and credits includes being tailored to local contexts, including long term monitoring, co-developed with local communities to avoid injustices, implemented in an accountable and transparent governance setting (e.g. third party accreditation) and subject to strict regulatory oversight [10,11,12,13,14]. Central as well is the sound selection of metrics [15] which should not be limited to financial or market-based values, but include the three broad value dimensions as defined by IPBES [16]: intrinsic, relational and instrumental [17]. An overarching requirement is transparency in financial flows, open data, and standardised reporting. While these safeguards are necessary, they will also increase transaction costs [3], potentially to the point of outweighing financial benefits. In conclusion, nature credits can be assessed as a potential tool, although their role may remain limited and costs may exceed benefits. Nature credits should complement, not replace, strong public policies and investments, which remain essential to reaching a sustainable economy within planetary boundaries. The document rightly highlights some conditions and trade-offs. A next version could be strengthened by placing nature credits in the context of other public financial instruments, and by elaborating and emphasizing the conditions and risks to operational effectiveness.
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