World Green Building Council
WGBC
At the World Green Building Council (WorldGBC) our role is to help property and construction markets around the planet to develop equitable, sustainable and resilient buildings, cities and communities.
ID: 378438436902-06
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
5 Dec 2025
The World Green Building Council (WorldGBC) welcomes the European Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts and emphasises the need for simplification while maintaining alignment with evolving regulatory and market conditions. A full response with references and literature is attached. In summary: Leverage existing EU Taxonomy processes and work for the simplification of the criteria: WorldGBC highlights the importance of anchoring updates in the EU Taxonomy Regulation process, involving expert groups and stakeholders. A key driver for change is the 2024 recast of the Energy Performance of Buildings Directive (EPBD), which introduces life cycle Global Warming Potential (GWP) disclosure requirements for new buildings. WorldGBC argues that the EU Taxonomy should go beyond EPBD by setting ambitious life cycle GWP performance requirements to accelerate the transition to zero-emission buildings. Address usability issues from the taxonomy structure for construction and real estate: WorldGBC identifies structural and usability challenges in the taxonomy for construction and real estate, such as unclear distinctions between activities like acquisition, ownership, and construction, and the lack of incentives for deep renovation. WorldGBC calls for harmonised definitions of major and deep renovation, inclusion of embodied carbon assessments, and recognition of redevelopment activities to avoid favouring new construction over retrofits. Leverage voluntary tools established in the market: WorldGBC recommends integrating real energy performance measurements, developing decarbonisation pathways aligned with Minimum Energy Performance Standards (MEPS) for the acquisition and ownership of buildings, and allowing proxies like green building certifications (e.g., BREEAM, LEED, DGNB) to demonstrate compliance with the EU Taxonomy, especially where EPCs are unavailable. Simplify and guide Taxonomy reporting and compliance: WorldGBC stresses the need for robust implementation and compliance mechanisms, including official guidance, national interpretation frameworks, and an EU Taxonomy helpdesk to address divergent reporting practices. A standardised, independent verification and assurance framework would ensure consistency, facilitate reporting and prevent greenwashing. Adjust certain criteria for facilitated reporting: WorldGBC also urges better alignment of Do No Significant Harm (DNSH) criteria with EU biodiversity and circular economy policies, and simplification of life cycle GWP assessments through default values for less impactful building elements. These measures aim to make the taxonomy more practical, verifiable, and effective in driving sustainable finance and decarbonisation in the built environment.
Read full responseResponse to Union framework for the calculation of life-cycle Global Warming Potential for new buildings
29 Oct 2025
In April 2025, the World Green Building Council (WorldGBC), on behalf of our Europe Regional Network comprising 26 Green Building Councils (GBCs) with over 5,000 private sector members and seven regional partners submitted a position paper to the European Commission on the Delegated Act amending Annex III of the revised Energy Performance of Buildings Directive (EPBD), setting out a Union framework for national life cycle Global Warming Potential (GWP) calculation. We attach that paper again to this consultation response. We welcome that the draft Delegated Act provides comprehensive coverage of life cycle modules, ensuring that key stages of a buildings life cycle are captured, though our network also recommends that modules B5 and B7, currently listed by the European Commission as "optional", should be reported on, to strengthen the consistency and completeness of life cycle GWP reporting across Member States. We also support the inclusion of both design-stage and as-built assessments, which aligns with our recommendation that LCAs should be conducted at both stages: generic or default data may be used at the design stage to inform optimisation of materials and construction methods, while product-specific data should be applied at the as-built stage to accurately reflect actual greenhouse gas emissions. While this draft Delegated Act marks real progress towards defining a harmonised framework for life cycle GWP, there are several points we would highlight where further improvement is needed, based on cross-referencing with our position paper: Avoiding fragmentation across Member States To prevent divergence across the EU construction sector, the EPBD Delegated Act should define a minimum common scope including life cycle stages, physical scope, and methodological requirements that all Member States must follow not only for reporting, but also when developing or applying limit values. Establishing a clear timeline for alignment The framework should include milestones for Member State implementation, ensuring that: Member States without an existing life cycle GWP reporting methodology adopt the EPBD Delegated Act framework as part of their national roadmap by 1 January 2027; and Member States with an existing methodology or one that is under development ensure full alignment with the EPBD Delegated Act framework by 1 January 2030. Separate reporting of Module D Neither section 5 (Scope of life cycle stages) nor section 8 (Results of life cycle GWP) currently specify that the D module(s) should be reported separately. We recommend that the D module(s) be reported distinctly from other life cycle stages, to ensure transparency, avoid double counting, and maintain comparability across Member States. Encouraging a hybrid staticdynamic LCA approach The Delegated Act should encourage a hybrid staticdynamic LCA methodology for life cycle GWP calculation applying dynamic emission factors to energy-related emissions while retaining a static approach for material impacts. This approach offers the best balance at present, using available energy grid decarbonisation projections to provide a more accurate representation of operational emissions, while avoiding the complexity and data gaps associated with fully dynamic modelling, which is not yet standardised across the EU. The World Green Building Council welcomes the opportunity to discuss these recommendations further with the European Commission and our GBCs and partners are ready to support efforts to ensure consistent and ambitious implementation of life cycle GWP reporting and limit values across Member States.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
3 Jul 2025
The World Green Building Council (WorldGBC) Europe Regional Network (ERN) welcomes the European Commissions Call for Evidence on the Industrial Decarbonisation Accelerator Act (IDAA). Our network brings together over 20 Green Building Councils representing close to 5,000 members across Europe, alongside regional private sector partners, including ABB, Assa Abloy, Heidelberg Materials, Knauf Insulation, Ramboll, Saint-Gobain and Stora Enso. We support the Acts objectives to decarbonise Europes energy-intensive industries while preserving their competitiveness and accelerating the development of lead markets for decarbonised or low-carbon products. As a network that is material-neutral and focused on energy efficiency, decarbonisation, circularity and resilience, we wish to contribute constructively to the debate on how the Act can create robust demand signals for locally-sourced, sustainable construction products while also accelerating a transition to a more resource-efficient built environment, which currently accounts for around one third of the EUs total material consumption. In particular, we see two policy areas as critical enablers: public procurement reform and the implementation of the Energy Performance of Buildings Directive (EPBD). Please see our attached position paper for our full recommendations in response to this consultation.
Read full responseResponse to Evaluation of the Public Procurement Directives
4 Mar 2025
WorldGBC and the Europe Regional Network welcome this consultation on the Directive 2014/24/EU on public procurement. We support a comprehensive revision of the Directive and call on the European Commission to acknowledge that procurement is a crucial way to drive an energy efficient, low emission, regenerative and just transition in the built environment. Procurement provides an excellent route for a top-down shift in the way and terms on which public authorities engage the buildings sector in construction projects. European procurement must move towards a model with energy efficiency, sustainability and circularity at its core. This should include the calculation and disclosure of life cycle global warming potential (GWP) emissions of new public buildings in advance of the requirements already established in the 2024 revision of the Energy Performance of Buildings Directive. The vision set out in WorldGBCs EU Whole Life Carbon Roadmap in 2022 requires that all publicly procured projects be net zero whole life carbon (WLC) well before 2050. In this vision, public authorities will be first adopter role models, embracing tools such as the Level(s) Framework and third-party verified environmental data for products to facilitate the multi-actor collaboration and large-scale thinking necessary to deliver a net zero carbon built environment. Public procurement is an important driver for broader market transformation, and the recommendations in this section aim to harness its clear leadership role to model sustainable best practice. Multi-level action is required, and the revision of the Public Procurement Directive will be a crucial first step. We recommend that the Directive 2014/24/EU on public procurement is revised and takes the following actions to address the impact of buildings: Require all new public buildings to be positive energy (in operation), with service-/performance-based energy contracting and district integration where possible Require calculation and reporting of life-cycle GWP for all new public buildings according to the methodology set out in the forthcoming EPBD Delegated Act. Incentivise take-back schemes for building systems, lighting, furniture and promote technology systems-as-a-service and energy-performance-based contracting Stipulate that all tenders include sustainability/circularity criteria based on Level(s) Require all public buildings to undergo reuse assessment to discourage demolition Require all public buildings to undergo pre-demolition/ deconstruction audits and share data across value chain Introduce minimum requirements in new public construction and renovations so a percentage of products/materials from demolition can be reused/recycled Minimum requirements for products/materials in public projects to be reused/reusable and/or recycled/recyclable Apply minimum requirements for new public building design and large renovations Mandate reporting and checking of environmental performance criteria in the design, delivery, commissioning and verification of public buildings to close the performance gap Outline criteria to award contracts based on life cycle costing (LCC) or total cost of ownership instead of capital costs Outline criteria that encourage use of regionally and sustainably sourced secondary materials and/or minimal heavy transport Outline criteria for awarding contracts based on lower embodied carbon through transition towards zero emissions construction machinery and materials transport These actions will ensure that the revised EU Procurement Directive aligns with the EU Green Deals climate and sustainability goals while leveraging public procurement as a catalyst for market transformation. By embedding energy efficiency, circularity, and whole life carbon considerations into procurement processes, the Directive can drive innovation, improve resource efficiency, and create long-term economic and environmental benefits.
Read full responseResponse to 2040 Climate Target Plan
19 Jun 2023
Please see the World Green Building Council's feedback on the EU 2040 climate target consultation in the form of the attached position paper.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
The World Green Building Council (WorldGBC) is the largest and most influential local-regional-global action network, leading the transformation to sustainable and decarbonised built environments for everyone, everywhere. Together, with 75+ Green Building Councils and industry partners from all around the world, we are driving systemic changes to: - Address whole life carbon emissions of existing and new buildings - Enable resilient, healthy, equitable and inclusive places - Secure regenerative, resource efficient and waste-free infrastructure. We work with businesses, organisations and governments to deliver on the ambitions of the Paris Agreement and UN Global Goals for Sustainable Development (SDGs). WorldGBCs Sustainable Finance Taskforce: The urgency and complexity of financing the transition towards a fully decarbonised and sustainable built environment calls for drastic actions. The built environment is of a fragmented and heterogenous nature, rendering large-scale and timely financing of sustainable actions difficult. In that context, WorldGBCs Sustainable Finance Taskforce convenes key stakeholders to enhance collective learning and progress, advises to build capacities amongst the industry and influences sustainable finance practices and policy implementation at a larger scale. WorldGBCs Sustainable Finance Taskforce has convened the EU Taxonomy Working Group to build consensus in the built environment on the interpretation and implementation of the EU Taxonomy, to build capacities amongst our network and beyond in the understanding of EU Taxonomy requirements and reporting procedures, and to build influence ensuring our networks decades of expertise in sustainable construction and real estate practices is leveraged and the EU Taxonomy is practically implementable and understood by the industry. In that context, the EU Taxonomy Working Group has developed WorldGBCs feedback attached, drawing on the expertise and review of the Europe Regional Network (ERN) - a community of over 20 national Green Building Councils (GBCs), 8 Regional Partners, and more than 5,000 members across Europe. GBCs have been at the forefront of enabling sustainable finance in the real estate sector, with green building certifications forming the foundation of early ESG frameworks such as green bond standards. The WorldGBC network is mobilised to continue this enabling role to make ESG reporting and verification of the performance of built assets - across their whole life cycle - streamlined and robust. Through our membership of the first EU Platform on Sustainable Finance, WorldGBC already contributed substantially to the development of the technical screening criteria of buildings and civil engineering. Under the coordination of WorldGBCs representative, Stephen Richardson, Europe Director, Sector Team 7 delivered a package of technical screening criteria recommendations spanning three different sectors (buildings and construction, emergency services and ITC) and five of the six environmental objectives in the taxonomy regulation.
Read full responseMeeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)
3 Feb 2023 · EPBD - staff level
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
31 Mar 2022
Please find attached a summary of WorldGBC’s feedback on the proposed revision of the Energy Performance of Buildings Directive (EPBD) and our recommendations to ensure that the full potential of the buildings sector in delivering on EU goals is recognised.
Read full responseMeeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and
2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards
Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)
29 Sept 2021 · Revision of energy performance of building directive – renovation wave
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
22 Mar 2021
Please World Green Building Council's feedback in the attached document.
Read full responseMeeting with Ditte Juul-Joergensen (Director-General Energy)
15 Jan 2020 · Efficiency in buildings in the context of the Green Deal
Meeting with Daniel Calleja Crespo (Director-General Environment)
8 Jan 2020 · Sustainable buildings