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RE2020: what is a new building's carbon footprint (and why does concrete weigh so heavily)?

In a new building meeting RE2020 standards, construction emissions often exceed those from 50 years of heating, and many developers discover this once the project is fixed.

Guillaume Pakula
By Guillaume Pakula, co-founder of Celsius. Since 2019, he has helped 80+ organisations with their Bilan Carbone® and climate strategy.
March 2026
Updated May 2026 · 5 min
Since January 2022, RE2020 has required the carbon impact of each new building to be calculated, and the results are surprising. Concrete, steel and foundations often account for more than 30 to 50 years of heating. For a developer or project owner, structural choices at the concept stage determine most of the footprint, well before insulation or heating questions.
Key takeaways
  • 1Cement emits 600 to 900 kg of CO2 per tonne: the chemical calcination reaction is responsible.
  • 2Construction emits more than 30 to 50 years of heating in an efficient RE2020 building.
  • 3Low-carbon concretes reduce emissions by 30 to 50% without compromising mechanical performance.
  • 4Renovation emits 2 to 4 times less than new construction with an equivalent floor area: the best building already exists.

"We discovered that our building's concrete emits more than 30 years of heating." This is what a developer told us on seeing the results of their statutory RE2020 LCA, and their case is far from exceptional. Buildings account for around 27% of greenhouse gas emissions in France, but it is the breakdown that surprises: in an efficient new building meeting RE2020 standards, construction and material emissions often exceed operational emissions over its entire lifespan.

1RE2020 makes LCA mandatory for every new residential building

RE2020: what it actually requires

Having entered into force in January 2022, RE2020 is the first French regulation to incorporate carbon as a performance criterion for new buildings. It requires each building's carbon impact to be calculated over its full life cycle (construction + operation + end of life) through a statutory LCA (Life Cycle Assessment). It sets maximum emission thresholds per m², which progressively tighten until 2031. The building's total carbon therefore joins energy consumption among the compliance criteria.

Carbon becomes a design criterion

This change requires architects, engineering consultancies and developers to incorporate carbon from the design stage. The choice of construction system (concrete, timber, mixed), insulation materials, windows and doors directly affects regulatory compliance. It is a design criterion just as thermal performance or structural strength is.

2Structural materials account for 50 to 70% of the total footprint

Concrete is the largest contributor in a conventional building. Producing cement (concrete's main component) emits around 600 to 900 kg of CO2 per tonne because of the chemical calcination reaction and the energy needed for kilns. Structural steel comes second. Insulation, windows and doors, and technical systems make up the rest. Overall, structural and main construction materials account for 50 to 70% of a new building's total carbon footprint.

Timber structure of a building under construction

Low-carbon concrete, timber, bio-based materials: the alternatives

This finding led the sector to develop alternatives: low-carbon concretes (reducing emissions by 30 to 50% compared with conventional concrete by using cements with less clinker), structural timber (which stores carbon rather than emitting it), and bio-based insulation materials (hemp, straw, cellulose fibre). RE2020 accelerates adoption of these alternatives by setting increasingly demanding thresholds.

3Renovating vs building: the calculation few developers make

In a new building meeting RE2020 standards, construction emissions often exceed operational emissions over 50 years.

When comparing the carbon footprint of major renovation with demolition-reconstruction, renovation almost always wins. Demolition and waste treatment emissions are avoided, the existing structure is retained (having already "amortised" its construction emissions), and only renovation materials generate emissions (insulation, windows and doors, systems). The carbon footprint of renovation is typically 2 to 4 times lower than new construction with an equivalent floor area.

Renovation emits 2 to 4x less than demolition and rebuilding

Calculated over 50 years of operation, per equivalent m²

1x
Major renovation
Structure retained, construction emissions avoided
vs
3x
Demolition + rebuilding
New materials, demolition, waste transport
Source: RE2020 studies

Renovating: the best building is the one that already exists

Developers rarely make this calculation because they are used to thinking in financial costs rather than carbon costs. But with RE2020, carbon thresholds and pressure from ESG investors, carbon calculation is gradually entering property project planning decisions. We see project owners requesting a comparative renovation vs new construction study with a carbon dimension - something unthinkable 5 years ago.

4The weight of property CAPEX: what we found at a portfolio manager

We worked with a hotel property portfolio manager on the carbon analysis of its investments (CAPEX). The results were striking: renovations accounted for 47% of emissions, new construction 41%, and the remaining CAPEX (equipment, furniture) 12%. The analysis identified that material choices in renovations (types of insulation, windows and doors, finishes) had a major impact, and that works specifications could incorporate carbon criteria without significant additional cost.

Incorporating carbon into works specifications

This type of analysis transforms investment policy: rather than choosing materials solely on price and technical performance, a carbon criterion is added to the specification. Bio-based insulation can be price-competitive while reducing the insulation category's carbon footprint by a factor of 3. For the project owner incorporating these data into decisions, the carbon criterion joins price and technical performance, often without significant additional cost.

5Building LCA: method, data and cost for a developer

A statutory building LCA (under RE2020) uses the INIES database (the national reference database for construction products' environmental characteristics) and certified software. An RE2020 LCA costs 3,000 to 10,000 euros depending on project complexity. This is a modest investment relative to the total cost of a property development, and is now mandatory for every building permit for new residential construction.

For non-residential projects, LCA has been mandatory under RE2020 since July 2022 for offices and education. Since 1 May 2026, Decree No 2026-16 extends it to 13 new building types: hotels, shops, restaurants, nurseries, healthcare, sports facilities, media libraries, universities, airport terminals, industrial and craft buildings; process buildings, temporary structures and overseas territories remain outside scope. Beyond the requirement, large groups' CSRD reporting and investor requirements encourage some developers to aim beyond the thresholds. The BBCA (Low-Carbon Building) label has become a selling point in some markets, showing that the carbon dimension is gradually entering property value.

6Key takeaways

RE2020 has made visible a reality the sector preferred to ignore: construction materials emit more CO₂ than decades of heating. Concrete, steel and foundations account for 50 to 70% of a new building's total footprint.

  • Cement emits 600 to 900 kg of CO2 per tonne, largely because of the chemical calcination reaction, with the rest coming from kiln energy.
  • For an RE2020 building, construction emissions often exceed operational emissions over half a century.
  • Low-carbon concretes reduce emissions by 30 to 50% compared with conventional concrete, with sufficient mechanical performance for most uses.
  • Renovation emits 2 to 4 times less than new construction with an equivalent floor area.
  • Incorporating carbon calculation at the project planning stage costs a few thousand euros and can change a project's decisions.

7Key takeaways

  • Cement emits 600 to 900 kg of CO2 per tonne, largely because of the chemical calcination reaction, with the rest coming from kiln energy.
  • For an RE2020 building, construction emissions often exceed operational emissions over half a century.
  • Low-carbon concretes reduce emissions by 30 to 50% compared with conventional concrete, with sufficient mechanical performance for most uses.
  • Renovation emits 2 to 4 times less than new construction with an equivalent floor area.
  • Incorporating carbon calculation at the project planning stage costs a few thousand euros and can change a project's decisions.

Before starting a new project, request a comparative study with a renovation scenario. An LCA costing a few thousand euros can redirect a development costing several million euros and substantially reduce its carbon footprint. For new projects, work with the architect and engineering consultancy from the concept stage to optimise the carbon footprint without waiting for the building permit. Carbon has become a design criterion just as thermal performance or structural strength is, and now guides property investment decisions.

Further resources

Frequently asked questions

RE2020 has been mandatory for all new residential buildings since January 2022 (individual houses, apartment buildings). For non-residential buildings, the extension has been gradual since July 2022. Since 1 May 2026, Decree No 2026-16 extends it to specific non-residential buildings (hotels, shops, healthcare, sport...) and industrial and craft buildings. The building permit cannot be issued without an RE2020 compliance certificate within the mandatory scope.
A statutory RE2020 LCA typically costs 3,000 to 10,000 euros depending on project complexity (size, mixed uses, number of specific materials). This is a modest investment relative to the total cost of a property development. For non-residential projects outside the mandatory scope, the cost is comparable but the investment is voluntary, generally motivated by a label (BBCA) or an ESG investor requirement.
Low-carbon concretes (with low clinker content, incorporating slag or fly ash) achieve mechanical performance comparable with conventional concrete for the vast majority of common uses. Differences exist for heavily stressed structures (prestressed bridges, civil engineering structures), where additional tests remain necessary. For a standard residential or non-residential building, the decision is essentially economic and logistical.
The gap is substantial: major renovation typically emits 2 to 4 times less than new construction with an equivalent floor area. Demolition and waste treatment emissions are avoided, the existing structure is retained, having already amortised its construction emissions, and only renovation materials generate emissions (insulation, windows and doors, systems). Developers rarely make this calculation, but it is now incorporated into some ESG decisions.
LCA has already been mandatory for new non-residential buildings within RE2020 scope since July 2022, with thresholds by building type (offices, education, etc.). Other non-residential uses (healthcare, hotels, retail...) entered scope on 1 May 2026, with thresholds tightening until 2031. Project owners wanting to go further aim for the BBCA label or anticipate the 2028 and 2031 RE2020 thresholds.
RE2020 is the environmental regulation for new buildings, which entered into force in January 2022 for residential construction (Decree No 2021-1004 of 29 July 2021). In addition to energy requirements (bioclimatic need Bbio, primary energy consumption Cep), it requires each building's life-cycle carbon impact to be calculated through a statutory LCA, with thresholds per m² tightening in 2025, 2028 and 2031. The statutory LCA costs €3,000 to €10,000 depending on project complexity, and additional construction cost depends mainly on structural choices made at the concept stage.
For an individual house, the average Icconstruction threshold has been 530 kgCO2e/m² since 2025, then 475 in 2028 and 415 in 2031 (640 in 2022). For apartment buildings, it moves from 740 kgCO2e/m² in 2022 to 650 in 2025, 580 in 2028 and 490 in 2031. Offices and primary and secondary education buildings have their own thresholds set by the same regulation. The threshold applicable to a project is then adjusted according to its floor area, location, infrastructure and attic spaces. Each stage applies to building permits submitted from 1 January of the relevant year.
The main measure comes at the concept stage, through the construction system, because structural and main construction materials account for 50 to 70% of a new building's footprint. Low-carbon concretes with low clinker content reduce emissions by 30 to 50% compared with conventional concrete; structural timber and bio-based insulation (hemp, straw, cellulose fibre) are the other alternatives, with bio-based insulation potentially reducing the insulation category's footprint by a factor of 3. Before building, also compare with major renovation, which emits 2 to 4 times less for an equivalent floor area.
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