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EU Sustainable Finance Taxonomy for Buildings & Construction

Lifecycle greenhouse gas (GHG) and circularity requirements for the built environment

Summary: EU Taxonomy’s life-cycle assessment needs

This table summarizes the EU Taxonomy’s life-cycle assessment (LCA) requirements for the sectors that have requirements applied to them directly via the EU Taxonomy.

Sector LCA requirements Third-party verification One Click LCA’s matching tools
New buildings & renovation EN 15978 and Level(s) LCA No  Level(s)LCA tool
Transport infrastructure GHG Accounting, Scopes 1-3 No LCA EN 17427, Carbon Strategy tools
Renewable energy ISO 14067 Yes Product LCA tools
Manufacturing ISO 14067 Yes Product LCA tools

In Taxonomy, where ISO 14067 is mentioned as the GHG accounting standard, ISO 14064-1:2018 or Commission Recommendation 2021/2279/EU can be used instead.

The EU Taxonomy in a nutshell

The EU Sustainable Finance Taxonomy helps steer investments to achieve the EU’s sustainability objectives. It is legally binding from 2021, with provisions for circularity and biodiversity added in 2023, which enter into force in 2024. The EU Sustainable Finance Taxonomy (shortened to the Taxonomy), or Regulation (EU) 2020/852, is a sustainability classification system for economic activities. The Taxonomy was legally binding in June 2021 — initially only covering climate change.

The Taxonomy is an essential tool for all types of investors and financial market participants (asset owners, asset managers, insurance companies, and banks) — as well as publicly listed companies and large companies operating in Taxonomy-covered sectors with business in the European Union, and those raising a significant amount of funding from the European Union.

The Taxonomy makes it possible to identify sustainable activities and to identify sustainable investments. In essence, it provides sector-specific sustainability benchmarks.

Skip to the technical screening criteria applied.

The Taxonomy is the technical methodology for many EU regulations

The Taxonomy is a set of interacting rules, with the part being the Commission Delegated Regulation (EU) 2021/2139 and followed by the 4 June 2021 supplementary Regulation (EU) 2020/852 of the European Parliament and of the Council.

It establishes the technical screening criteria for determining the conditions under which economic activity qualifies as contributing substantially to climate-change mitigation or climate-change adaptation, and for determining whether that economic activity causes no significant harm to any of the other environmental objectives. 

The Taxonomy is the underpinning method for a number of other key regulations, as shown below.

Regulation Role of the Taxonomy
Sustainable Finance Disclosure Regulation (SFDR) Compulsory for financial market participants as of 10 March 2021
Green Bond Standard (GBS) and the EU Green Bond Framework EU Taxonomy requirements used to define eligibility criteria
Corporate Sustainability Reporting Directive (CSRD) Supports reporting requirements
Task Force on Climate-related Financial Disclosures (TCFD) Disclosures need to be aligned with the Taxonomy
European Green Deal A tool to scale up sustainable investment  to implement the EU Green Deal

Read more about the growing number of other policies and legislation regulating embodied carbon in construction here.

The environmental objectives of the Taxonomy

In order to be Taxonomy-eligible, an economic activity must contribute substantially to at least one of the below six environmental objectives of the European Green Deal and do no significant harm to the others, as well as meeting minimum social safeguards.

  • Climate change mitigation
  • Climate change adaptation
  • Sustainable use and protection of water and marine resources
  • Transition to a circular economy
  • Pollution prevention and control
  • Protection and restoration of biodiversity and ecosystems

The requirements are now set for all environmental objectives. The initial screening criteria were developed by the EU Technical Experts Group, and supported by the independent platform on sustainable finance.

The Taxonomy has been in force since 12 July 2020 and the screening criteria were set in law on 9 December 2021. Businesses are required to disclose their activities’ compliance for the calendar year 2021 with criteria for climate change mitigation or adaptation in 2022. For the four other environmental objectives, for which the technical screening criteria were issued in April 2023, these are required to be disclosed for the calendar year 2024 to a limited extent. Full provisions apply from 2025 onwards. In any case, reporting ultimately needs to cover all six environmental objectives.

Who does the Taxonomy affect and what do they need to do?

The Taxonomy affects companies offering financial products, including pension funds, and non-financial companies with over 500 employees (as covered by the EU Non-Financial Reporting Directive), and EU member states setting public measures, standards, or labels for green financial products or green corporate bonds.

All companies subject to the Taxonomy will need to describe how and what share of their activities are Taxonomy-aligned for each financial year they report. For non-financial companies, the disclosure must include:

  • the proportion of turnover aligned with the Taxonomy
  • the amount of capital expense (capex) and, if relevant, operating expense (opex) aligned with the Taxonomy.

Financial market participants subject to the Taxonomy are required to complete their first disclosures for the activities that substantially contribute to the environmental objectives. For each relevant product, the financial market participant is required to state:

  • how and to what extent they have used the Taxonomy in determining the sustainability of the underlying investments
  • to which environmental objective(s) the investments contribute
  • the proportion of underlying investments that are Taxonomy-aligned, expressed as a percentage of the investment, fund, or portfolio. This disclosure should include details of the respective proportions of enabling and transition activities, as defined under the Regulation.

Built environment sectors and applicable rules

Taxonomy’s detailed rules, called technical screening criteria, are issued only for sectors which have a high impact and a potentially high positive contribution. An activity can fulfill requirements of multiple environmental objectives, but double counting is not allowed.

The below table cross-references the sectors for which rules are set to meet Taxonomy’s various environmental objectives leveraging life-cycle assessment and circularity metrics.

Environmental objective Climate change mitigation Circular economy Other environmental objectives
Buildings New buildings: Global Warming Potential (GWP) reporting using Level(s) New buildings and renovations: GWP reporting using Level(s) & circularity reporting
Infrastructure Infra for air, water, rail, road, and public transport: conduct carbon footprinting for scopes 1-3 that show the project does not add GHGs Treatment of hazardous waste: show that activity does not on life-cycle basis increase GHGs compared to primary raw materials
Energy supply Electricity from hydropower, geothermal energy, renewable non-fossil gaseous and liquid fuels, co-generation from geothermal energy, and production of heat/cool from geothermal energy: life-cycle GHG emissions limit of 100gCO2e/kWh
Manufacturing

Manufacturing: low carbon technologies, hydrogen, organic basic chemicals and plastics in primary form. Life-cycle GHG emissions calculated using ISO 14067

Basic construction materials, including cement, aluminum, iron and steel apply manufacturing GHG emissions thresholds compatible with the EU ETS with physical emission measurement (2019/331)

Manufacture of plastic packaging goods: life-cycle emissions calculated using ISO 14067 Pharmaceutical manufacturing, pollution prevention & control: water footprint, ISO 14046

 

How to qualify for Taxonomy with buildings and renovation

These rules apply to the development of construction projects and the actual construction and renovation of residential and non-residential buildings. This covers NACE codes F41, F41.2 and F43.

New buildings can qualify via climate change mitigation, and both new buildings and renovations can qualify via circular economy.

New buildings: qualifying for EU Taxonomy via climate change mitigation

The following requirements have to be met:

For buildings larger than 5000 m2, the life-cycle GWP of the building resulting from the construction has been calculated for each stage in the life cycle and is disclosed to investors and clients on demand. The methodology must follow EN 15978:2011 and cover the scope of Level(s) framework for indicator 1.2.

At least 70% of the non-hazardous construction and demolition waste (CDW) is reused or recycled, including backfilling that substitute’s primary materials. 

Design and construction demonstrate design for disassembly and adaptability, using e.g. ISO 20887 or other standards.

One Click LCA’s solutions: Levels tool and Building Circularity tools.

 

New buildings and renovations: qualifying for EU Taxonomy via circular economy

The life-cycle GWP of the building has been calculated for each stage in the life cycle.

New buildings: At least 90% of the non-hazardous CDW is reused or recycled, including backfilling that substitute’s primary materials. 

Renovations: At least 70% of the non-hazardous CDW is reused or recycled, including backfilling that substitute’s primary materials.

Construction design and techniques incorporate design for adaptability and deconstruction. This is demonstrated by using Level(s) 2.3 Indicator on construction and demolition waste at Level 2, and 2.4 Overarching assessment tool: Cradle-to-grave life cycle assessment (LCA), also at Level 2. 

The project demonstrates for the three heaviest material categories (of those below) with the maximum share of primary raw material used: 

Material category Maximum primary raw material share for new buildings Maximum primary material share for newly added material in renovations
Combined total of concrete, natural, or agglomerated stone 70% 85%
Combined total of brick, tile, and ceramic 70% 85%
Bio-based product 80% 90%
Combined total of glass and mineral insulation 70% 85%
Non-bio based plastics 50% 75%
Metals 30% 65%
Gypsum 65% 83%

Where recycled content is not known, it’s calculated as 100% primary raw material. Where a construction product is re-used, it is to be counted as comprising zero primary raw material. Results are to be exported as a bill of quantities and stored in a digital format.

One Click LCA’s solutions: EN 15978 GWP, Level(s) LCA and Building Circularity tools.

Transport infrastructure: qualifying for Taxonomy

Transport infrastructure can only qualify via climate change mitigation. These rules apply for practically all types of transport infrastructure, bar pedestrian routes, as set out below.

Rail transport: Railways and subways as well as bridges and tunnels, stations, terminals, rail service facilities, safety and traffic management. NACE codes e.g. F42.12, F42.13, M71.12, M71.20, F43.21, and H52.21.

Road and public transport: Motorways, streets, roads, other vehicular and pedestrian ways, surface work on streets, roads, highways, bridges or tunnels and construction of airfield runways. NACE codes e.g. F42.11, F42.13, F71.1 and F71.20.

Water transport: Waterways, harbor and rivers works, pleasure ports, locks, dams, dykes and others. This excludes dredging. NACE codes e.g. F42.91, F71.1 or F71.20.

Zero carbon aviation infrastructure: Construction infrastructure for zero tailpipe CO2 operation of aircraft or the airport’s own operation. NACE codes e.g. F41.20 and F42.99

Construction or major renovation of infrastructure for air, water, rail, road, and public transport: qualifying for EU Taxonomy via climate change mitigation

In case of new infrastructure or major renovation, the infrastructure has been climate proofed in accordance with the appropriate climate proofing practice that includes carbon footprinting and clearly defined shadow cost of carbon. Such carbon footprinting covers scope 1-3 emissions, and demonstrates that the infrastructure does not lead to additional relative greenhouse gas emissions, calculated on the basis of conservative assumptions, values, and procedures.

At least 70% of the non-hazardous construction and demolition waste (CDW) is reused or recycled, including backfilling that substitute’s primary materials.

One Click LCA’s solutions: Infrastructure LCA EN 17427 and Carbon Strategy tools.

Construction and operation of hazardous waste treatment for material recovery: qualifying for EU Taxonomy via the circular economy

This refers to the construction, upgrade, and operation of dedicated facilities for the treatment of hazardous waste as a means for material recovery operations. 

The activity, on a life-cycle basis, does not increase GHG emissions as compared to the production based on the equivalent primary raw material(s).

Life-cycle greenhouse gas emissions are calculated using ISO 14067 and are verified by an independent third party.

One Click LCA’s solutions: Product LCA modules & third party verification support.

Manufacturing: qualifying for Taxonomy

Manufacturing chemicals, including hydrogen, chlorine, organic basic chemicals and non-recycled plastics in primary form: qualifying for EU Taxonomy via climate change mitigation.

Life-cycle GHG emissions savings are calculated using the ISO 14067 methodology, and quantified life-cycle GHG emission savings are verified by an independent third party. Furthermore, for hydrogen, a set limit value applies and for other products, and conditional limit values apply.

The list of organic basic chemicals targeted includes acetylene, ethylene, propylene,  butadiene, within aromatics, mixed alkylbenzenes, mixed alkylnaphthalenes other than HS 2707 or 2902, cyclohexane, benzene, toluene, o-Xylene, p-Xylene, m-Xylene and mixed xylene isomers, ethylbenzene, cumene; biphenyl, terphenyls, vinyltoluenes, other cyclic hydrocarbons excluding cyclanes, cyclenes, cycloterpenes, benzene, toluene, xylenes, styrene, ethylbenzene, cumene, naphthalene, anthracene; benzol (benzene), toluol (toluene) and xylol (xylenes), naphthalene and other aromatic hydrocarbon mixtures (excluding benzole, toluole, xylole), vinyl chloride, styrene; ethylene oxide; monoethylene glycol,  and adipic acid.

One Click LCA’s solutions: Product LCA modules & third party verification support.

Manufacturing low-carbon technologies and ICT solutions: qualifying for EU Taxonomy via climate change mitigation

Data-driven solutions for GHG emissions reductions, and manufacturing of technologies aimed at substantial GHG emission reductions in other sectors of the economy, which are not covered separately, and where they demonstrate substantial life-cycle GHG emission savings compared to the best performing alternative technology, product, or solution available on the market, can qualify if their quantified life-cycle GHG emission savings are calculated according to ISO 14067 and verified by an independent third party.

One Click LCA’s solutions: Product LCA modules & third party verification support.

Manufacture of plastic packaging goods: qualifying for EU Taxonomy via circular economy

For plastic manufactured from chemical recycled feedstock, life-cycle GHG emissions of the manufactured plastic, excluding any calculated credits from the production of fuels, are lower than the life-cycle GHG emissions of the equivalent plastic in primary form manufactured from fossil fuel feedstock. Life-cycle GHG emissions are calculated using ISO 14067 and verified by an independent third party.

One Click LCA’s solutions: Product LCA modules & third party verification support.

Construction commodities: qualifying for EU Taxonomy via climate change mitigation

Basic construction materials, including cement, aluminum, iron, and steel apply manufacturing GHG emissions thresholds compatible with the EU Emission Trading system mechanism using the physical measurement of emissions (2019/331). All large production units already apply these measurements as part of their Emission Trading obligations.

Pharmaceutical products: qualifying for EU Taxonomy via pollution prevention & control

This covers manufacturing of active pharmaceutical ingredients (API) or drug substances and manufacturing pharmaceutical products (NACE code C21.1 and C21.2).

To qualify, products must show that their use in products (substitution) does not lead to an increment of lifecycle GHG emissions, calculated using ISO 14067, and verified by an independent third party.

If the products are made using hydrogen, carbon black, chlorine, organic basic chemicals, anhydrous ammonia, nitric acid, their GHG emissions should not exceed the limits set for these products. 

Operators also must assess the water footprint of the chemical production processes in line with ISO 14046:2014 and ensure that they do not contribute to water scarcity, also verified by an independent third party.

One Click LCA’s solutions: Product LCA modules & third party verification support.

Energy supply: qualifying for Taxonomy

Renewable energy: qualifying for EU Taxonomy via climate change mitigation

The following energy production types are applying a life-cycle emissions limit to qualify:

  • Electricity generation from hydropower
  • Electricity generation from geothermal energy
  • Electricity generation from renewable non-fossil gaseous and liquid fuels
  • Cogeneration of heating / cooling and power from geothermal energy
  • Cogeneration of heating / cooling and power from renewable non-fossil gaseous and liquid fuels
  • Production of heating / cooling from geothermal energy
  • Production of heating / cooling from renewable non-fossil gaseous and liquid fuels

To qualify, the life-cycle GHG emissions must be lower than 100 g CO 2 e/kWh. Life-cycle GHG emissions are calculated based on project-specific data, where available, using ISO 14067 and verified by an independent third party.

One Click LCA’s solutions: Product LCA modules & third party verification support.

How can One Click LCA help?

One Click LCA offers Taxonomy solutions that span the built environment.

We support these Taxonomy-relevant sectors with the following tools:

How to deal with new EU Taxonomy requirements with Panu Pasanen, CEO, One Click LCA

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