RE2020 since May 2026: which buildings are covered?

The regulatory framework for building eco-design became more extensive in 2026. RE2020 expanded under Decree No. 2026-16: since 1 May 2026, 13 new building types (hotels, shops, restaurants, nurseries, sports facilities, healthcare, industrial and craft buildings, universities, media libraries, airport terminals) must undergo a regulatory life cycle assessment (LCA). Meanwhile, BREEAM and HQE are becoming established on projects with investor requirements. For projects outside the framework (data centres, process buildings, overseas territories), voluntary LCA under EN 15978 remains the only reliable management tool.

This guide is for the project owner, technical director or client adviser launching a project who must work with regulations, voluntary standards and design trade-offs. It covers building LCA basics, the actual breakdown of emissions by source, the framework applying to each situation, quantified design measures and an implementation checklist.

1What is building LCA?

LCA (life cycle assessment) applied to a building measures its environmental impact from raw material extraction to deconstruction. The European reference standard is EN 15978, itself based on ISO 14040/14044. In France, the underlying data come from the INIES database, which centralises environmental declarations (FDES) for construction products.

In 2026, a "low-carbon" building incorporates several dimensions:

• Water consumption (process, use, rainwater)
• Site biodiversity and land take
• Summer comfort and the ability to avoid air conditioning
• Indoor air quality and healthy materials

But carbon remains the central marker: it is where regulations have an effect, and what investors examine first.

Why materials contribute more than heating

For 30 years, the sector built by optimising thermal performance: better insulation to reduce heating. RE2020, which entered into force in January 2022, added materials’ embodied carbon to the calculation. In a high-performance new building, construction-phase emissions (concrete, steel, insulation, windows and doors) often exceed operational emissions from 50 years of heating. Hence the value of starting the LCA at concept design, when material choices are still open.

Building LCA and Bilan Carbone®: what distinguishes them

In practice, the most frequent confusion concerns building LCA and Bilan Carbone®, which measure different things:

• Bilan Carbone® measures an organisation’s emissions over an annual reporting period, under scopes 1, 2 and 3.
• Building LCA measures a structure’s impacts over its complete life cycle (construction, operation, end of life).

A developer constructing 3 buildings needs both: Bilan Carbone® for the company footprint, and an LCA for each property development.

2Emission sources in a new building

A new building’s carbon footprint is concentrated in 4 sources. Knowing them avoids investing in the wrong eco-design measures:

• Structure and structural works (concrete, steel, foundations): 50 to 70%
• Envelope and insulation (insulation, windows and doors, façades): 15 to 25%
• HVAC and energy systems (heating, ventilation, air conditioning, domestic hot water): 10 to 20%
• Material transport (module A4, depending on site location): 2 to 15%

Structure and structural works: the dominant source

Concrete is the largest contributor. Cement production emits 600 to 900 kg of CO2 per tonne, mainly from the chemical reaction of limestone calcination, with the remainder from kiln energy. Structural steel comes second. Together, structure and foundations account for 50 to 70% of the total footprint. This is where design decisions have the greatest impact, and the source that can no longer be changed once foundations are poured. Low-carbon concretes (reduced clinker content, substitution with slag or ash) reduce emissions by 30 to 50% without impairing mechanical performance.

Envelope and insulation: the second measure

Insulation, windows and doors, façades. The difference between conventional glass wool insulation and bio-based insulation (hemp, cellulose, wood fibre) can range from 1 to 3 in carbon footprint for equivalent thermal performance. This is often underestimated because decisions are made late in the project, sometimes during construction, when it is too late to change the system.

HVAC and energy systems: operational impact

In operation, this is the largest annual emission source. But over the complete life cycle of a high-performance new building, systems (heating, ventilation, air conditioning, hot water) account for 10 to 20% of the total footprint. Choosing between a heat pump, a district heating connection or a gas boiler has measurable consequences, and this decision is now made with the F-Gas timetable in mind. In hot climates, well-designed natural ventilation can divide air-conditioning needs by 2, provided it is planned at concept design.

Material transport: critical over long distances

Module A4 covers transporting construction products to the site. It remains minor for a locally supplied site in Île-de-France, but becomes important elsewhere: on a project in Martinique or Réunion, sea transport can account for 10 to 15% of the total footprint, compared with 2 to 5% in mainland France. Standard calculation tools often underestimate this parameter.

3The regulatory framework in 2026

A project owner launching a project in 2026 must first determine the applicable framework, as it sets thresholds, the method and support timeframes. There are 3 frameworks.

RE2020: mandatory French regulation

RE2020 requires a regulatory LCA for covered new buildings, with emission thresholds per m² that tighten progressively until 2031. The initial scope (2022-2023) covered housing, offices and educational buildings. Since 1 May 2026 (Decree No. 2026-16), 13 new building types have entered the scope: hotels (with different requirements by category), shops, restaurants, nurseries, healthcare facilities, sports facilities, media libraries, universities, airport terminals and buildings for industrial and craft uses. Data centres and process buildings (specific temperature, humidity or air quality constraints), temporary constructions, constructions and extensions under 50 m², certain extensions under 150 m² representing less than 30% of the existing floor area and all overseas projects remain outside RE2020.

A key step for a project owner: check the date RE2020 applies to the building type, as it determines the method, thresholds and submission timetable.

BREEAM: international certification

BREEAM (Building Research Establishment Environmental Assessment Method) is the most widespread voluntary environmental certification: more than 600,000 buildings certified in 90 countries. It speaks the language of international investors and ESG funds. BREEAM assesses 10 categories: energy (15 to 20% of the score, the most heavily weighted), health and wellbeing, management, transport, water, materials, waste, land use, pollution and innovation. The Materials component (Mat 01) relies on an EN 15978 LCA, but accounts for only around 10% of the total score: a good LCA is therefore insufficient; comprehensive BREEAM advisory support with an accredited assessor is needed.

HQE: the French voluntary reference

HQE (Haute Qualité Environnementale) is the reference French voluntary certification. Its process is more accessible than BREEAM’s, and it is well established in commercial property and multi-family housing. The 2 certifications are compatible: projects seek BREEAM for international credibility and HQE for the French market.

Voluntary EN 15978 LCA: when nothing else applies

For projects outside RE2020 without a certification target, voluntary EN 15978 LCA is the reference framework. Nothing requires it, but its recognised method supports managing trade-offs. It is the right response for a process building, an overseas project or a project owner wanting to document decisions for an investor.

4Design measures and their impact

Some measures divide the footprint; others improve it marginally. The following 3 families produce measurable results:

Structural choice: timber, low-carbon concrete, hybrid

For the structure, the choice goes beyond timber or concrete. There are 3 options:

• Structural timber stores biogenic carbon instead of emitting it: an R+4 timber building has a structural footprint 2 to 4 times lower than concrete. Its limitations: a constrained French supply chain, a maximum height of R+7 without a hybrid structure and a cost 5 to 15% higher for many building types.
• Low-carbon concrete, with clinker content reduced through substitution (slag, fly ash, calcined clays), reduces emissions by 30 to 50% with sufficient mechanical performance. It is often the best compromise between cost, carbon and feasibility, particularly in industrial buildings.
• Bio-based insulation (hemp, cellulose, wood fibre, straw) offers the best ratio between thermal performance and carbon footprint, and suits every structure.

Envelope and systems: adapting to the climate

Envelope and systems work together: a good envelope reduces HVAC needs, which then contribute less to the LCA. The most underestimated measure remains adaptation to the local climate.

• In a tropical climate, well-designed natural cross-ventilation can divide air-conditioning needs by 2.
• In a mountain climate, south-facing orientation and an earth-air heat exchanger change the heating picture.
• In a temperate climate, building compactness and the proportion of glazed area are decisive.

These decisions are made at concept design. They require no additional investment, only design tailored to the site’s climate.

Reuse and local sourcing

Reuse and local sourcing are becoming more important:

• Reusing construction materials (slabs, windows and doors, steel) avoids the manufacturing footprint, meaning zero emissions in modules A1 to A3. The French reuse sector is taking shape (Cycle Up, Backacia).
• Choosing materials produced within 200 km of the site reduces module A4. This is especially useful on remote sites: overseas, a local aggregate can reduce transport by 40 to 60%.

5Mistakes to avoid

These mistakes often arise in building eco-design. Avoiding them takes time upfront and prevents rework during construction.

Intervening after concept design

70 to 80% of the carbon footprint is determined during concept design and detailed design: construction system, orientation, envelope and energy systems are all fixed before the planning application. During construction, all that remains is to measure the result. Intervening early costs a few thousand euros; reworking a poorly designed project after plans are finalised costs much more.

Confusing building LCA with Bilan Carbone®

Treating a building LCA as the project owner company’s Bilan Carbone® remains common. The 2 exercises use different data, scales and timetables: Bilan Carbone® measures the organisation’s annual emissions, while building LCA measures a structure’s impact over its life cycle.

Neglecting transport module A4

On an urban site in mainland France, transport accounts for 2-5% of the footprint. On an overseas site, it is 10-15%. Neglecting this source systematically underestimates the actual footprint, particularly for aggregates, steel and timber imported by sea freight. On a project in a French overseas department, local sourcing (local rather than imported aggregates) can reduce the transport contribution by 40 to 60%.

Treating RE2020 as a box to tick

Producing the RE2020 study at the end of the project as an administrative document does not work: the calculation guides design from the concept stage. Thresholds (Ic construction, in kgCO2e/m²) cannot be recovered during construction, and every upfront decision made without considering them locks in the final footprint.

6Costs and funding

Moving from a conventional project to a low-carbon project costs little when addressed upfront, and a lot when the project needs correcting afterwards.

The price of a building LCA in 2026

There are 3 budget lines:

• Eco-design advice from concept design costs €3,000 to €8,000 excl. VAT for a few days’ work on major trade-offs (structure, envelope, systems, sourcing). This is often the project’s most worthwhile investment.
• A regulatory RE2020 LCA costs €3,000 to €10,000 excl. VAT depending on complexity. It is mandatory for housing, offices and educational buildings, and since 1 May 2026 for 13 new building types.
• A complete voluntary LCA under EN 15978 costs €15,000 to €30,000 excl. VAT for a process building, a BREEAM Mat 01 application or an overseas project: the scope is broad, data are complex and results must be defended before an assessor or investor.

Relative to a development’s total cost, LCA accounts for less than 0.1% of the works budget. A few thousand euros committed upfront avoid much more expensive rework during construction.

Available grants

Several schemes reduce the initial cost:

• Bpifrance’s Diag Éco-conception, restricted to companies with fewer than 250 employees, covers 60 to 70% of a first eco-design process for a company product, service or process, leaving €5,400 to €7,200 excl. VAT to pay. It is intended, for example, for a materials manufacturer and does not fund a building project’s LCA.
• In some territories, ADEME funds eco-design and low-carbon construction through regional grants.
• France 2030 funds low-carbon construction demonstration projects and emerging sectors (bio-based materials, reuse).
• For project owners subject to the CSRD (since Omnibus, groups with more than 1,000 employees and €450 million in turnover), building LCA data also feed sustainability reporting.

7Where to start

Here is the sequence we recommend to project owners launching a project.

Check whether your project is subject to RE2020

The first question determines everything else:

• New housing (multi-family or detached house): RE2020 mandatory since 2022.
• Office or educational building: RE2020 mandatory since 2022.
• Hotel, shop, restaurant, nursery, sports facility, healthcare, university, airport terminal, industrial or craft building: RE2020 mandatory since 1 May 2026.
• Data centre: outside RE2020.
• Process building (temperature or humidity constraints): outside RE2020 if the constraint is justified.
• Overseas project: outside RE2020; voluntary EN 15978 LCA is the only available framework.
• Temporary construction, construction or extension under 50 m², certain extensions under 150 m² and under 30% of the existing floor area: outside RE2020.

If RE2020 applies, it determines the method, thresholds and timetable. Otherwise, voluntary EN 15978 LCA takes over.

Bring in a specialist consultancy from concept design

Once the framework is identified, bring in an eco-design engineering consultancy at concept design, before detailed design. This is when major trade-offs must be scoped (timber, concrete or hybrid construction system, orientation and compactness, envelope and insulation, energy systems, material sourcing), because it is where 70 to 80% of the footprint is locked in. Like other specialist consultancies, we offer targeted design advice assignments: a few days’ work for a few thousand euros, at the point when choices have the greatest effect.

Gather your material data

Data collection is the limiting factor. From detailed design onwards, supply the engineering consultancy with: environmental declarations for construction products (FDES from the INIES database), supplier product sheets and the architect’s quantities. LCA software (One Click LCA, Elodie, Pleiades) will perform the calculation in a few hours. The 3 to 6 month timeframe comes from data collection.

8Key takeaways

Building eco-design means making the right decisions at the right time, before foundations are poured. The framework is tightening (expanded RE2020, CSRD for the largest groups, investor requirements), and major trade-offs are made within a few weeks during concept design.

• 70 to 80% of the footprint is determined at concept design; once the structure is fixed, improvements remain minor and rework is expensive.
• Structure and structural works account for 50 to 70% of the footprint. Cement emits 600 to 900 kg of CO2 per tonne, and low-carbon concretes reduce emissions by 30 to 50%.
• Since 1 May 2026, RE2020 applies to 13 new building types: check whether your project is among them.
• Outside RE2020 (data centres, process buildings, overseas territories), a well-executed voluntary EN 15978 LCA remains the management tool.
• The LCA calculation takes a few hours in software; data collection, trade-offs and defending results take months, and this is where the engineering consultancy adds value.
• The initial cost remains modest: €3,000 to €30,000 excl. VAT depending on scope, and for manufacturers with fewer than 250 employees, Bpifrance’s Diag Éco-conception funds 60 to 70% of a product or service’s eco-design.

Incorporating carbon from concept design is an economic calculation: a few days of study upfront avoid much more expensive rework once the project is fixed. For projects outside the regulatory framework, this is also where a specialist consultancy contributes most, because no threshold guides the choices.

Main sources: RE2020 and Decree No. 2026-16 (Ministry for the Ecological Transition), EN 15978 (environmental assessment of buildings), ISO 14040/14044 (LCA methodology), INIES database (construction product FDES), ADEME’s Base Empreinte, BREEAM International, Bpifrance Diag Éco-conception, CSRD (Corporate Sustainability Reporting Directive).

Further resources

Frequently asked questions

1Does RE2020 apply to my project?

It depends on your building type. Since 2022-2023: new housing, offices and educational buildings. Since 1 May 2026 (Decree No. 2026-16): hotels, shops, restaurants, nurseries, healthcare, sports facilities, media libraries, universities, airport terminals, and industrial and craft buildings. Outside RE2020 remain: data centres and specific process buildings, overseas projects, temporary constructions, constructions and extensions under 50 m², and certain extensions under 150 m² representing less than 30% of the existing floor area. Outside RE2020, voluntary EN 15978 LCA remains the reference framework.

2What is the difference between a building LCA and Bilan Carbone®?

Bilan Carbone® measures an organisation’s annual emissions (company, site) across scopes 1-2-3. Building LCA measures a structure’s impact over its complete life cycle (construction, operation, end of life). A developer needs both: Bilan Carbone® for the company, LCA for each property development. They never replace one another.

3How much does a building LCA cost?

Between €3,000 and €10,000 excl. VAT for a simple regulatory RE2020 LCA, and €15,000 to €30,000 excl. VAT for a complete voluntary EN 15978 LCA (process building, BREEAM, overseas project). Eco-design advice at concept design costs €3,000 to €8,000 excl. VAT and often delivers greater returns. Bpifrance’s Diag Éco-conception does not fund a building LCA: it covers 60 to 70% of a product or service’s eco-design for companies with fewer than 250 employees, leaving €5,400 to €7,200 excl. VAT to pay.

4Timber or low-carbon concrete: which should you choose?

Structural timber emits 2 to 4 times less than concrete, but the supply chain is constrained, height is capped at R+7 without a hybrid structure and cost is 5 to 15% higher. Low-carbon concrete reduces emissions by 30 to 50% compared with standard concrete, with sufficient mechanical performance: it is the best cost-carbon compromise on many projects. The choice depends on building type, height and construction feasibility.

5Do you need BREEAM or HQE certification?

It depends on the project and its stakeholders. BREEAM suits international projects, ESG investors and developments across several countries; HQE is the French reference for commercial property and multi-family housing. The 2 certifications are voluntary. Without certification, voluntary EN 15978 LCA is sufficient to manage eco-design.

6What if my project is overseas or outside RE2020?

This is where a specialist engineering consultancy adds most value. Standard data (INIES, BREEAM) do not cover local specifics: French overseas departments’ electricity mix, dominant sea freight, tropical climate constraints and earthquake-resistant standards. An EN 15978 LCA with specifically collected data remains the most reliable framework.

7When should you engage an eco-design consultancy?

As early as possible, ideally at concept design, before detailed design. This is where the major trade-offs (construction system, envelope, energy systems) are made, locking in 70 to 80% of the footprint. After the planning application, room for manoeuvre becomes limited.

8What are a building’s main carbon impact sources?

In a new building, structure and structural works (concrete, steel, foundations) account for 50 to 70% of the carbon footprint. Next come envelope and insulation (15 to 25%), heating, ventilation, air conditioning and hot water systems (10 to 20%), and material transport to the site, known as module A4 (2 to 5% in mainland France, 10 to 15% overseas). In a high-performance building, materials therefore often emit more than 50 years of heating. Priority measures consequently concern the construction system and envelope, decided from concept design.

9Do you need a building LCA in addition to the RE2020 calculation?

Not necessarily: for a project subject to RE2020, the regulatory calculation is already a building LCA, with emission thresholds per m², generally costing €3,000 to €10,000 excl. VAT. A complete voluntary LCA under EN 15978 is justified in 3 cases: a BREEAM certification application (Mat 01 component), a project outside RE2020 (overseas, data centre, specific process building) or a project owner wanting to document trade-offs for an investor. Budget €15,000 to €30,000 excl. VAT in that case.

10Are grants available for a building’s eco-design?

Yes, several schemes reduce the initial cost. For companies with fewer than 250 employees designing products, such as a materials manufacturer, Bpifrance’s Diag Éco-conception covers 60 to 70% of a first eco-design process, leaving €5,400 to €7,200 excl. VAT to pay; it does not fund a building project’s LCA. In some territories, ADEME also funds eco-design and low-carbon construction through regional grants. France 2030 supports demonstration projects and emerging sectors such as bio-based materials and reuse.

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