In its consultation response, Bellona proposed three main improvements of the methodology from a technical perspective:

1. Mandate the inclusion of the demolition of pre-existing buildings in the calculation.
2. Introduce a time-dependant coefficient to promote better end-of-life practices.
3. Use of generic or default values for building elements only for data gaps and not for simplification purposes.

Starting from the first point, the methodology draft gave the possibility to the Member States of excluding the pre-construction demolition from the calculation. This approach presents issues both on a theoretical level and practical one. Specifically, not including pre-construction demolition in the calculation implicitly states that the demolition process can be considered disconnected from the construction one: the demolition of an existing building would not take place if not for making space for new construction, therefore the emissions resulting from it should be accounted for. On a practical level, not including pre-construction demolition is a missed opportunity of encouraging better end-of-life practices and the reuse and recycling of materials directly on-site, promoting circularity and reducing the need for raw materials.

On the second point, the idea of introducing a time-dependant coefficient when it comes to reused and recycled materials promotes better end-of-life practices while not incentivising demolition and new construction. Specifically, it has been proven that renovation greatly reduces emissions compared to new construction1 as it extends the lifetime of materials and products. At the same time, incentivising good end-of-life practices might lead to premature demolition rather than renovation. Using a coefficient that increases over time, as presented in our consultation response, would still promote better end-of-life practices while also incentivising renovations over demolition and new construction.

Finally, Member States are allowed to adopt generic data or default values for the calculation of the single building elements to simplify the procedure or in case more specific data are not available. While there is no alternative when it comes to data gaps, simplification should not be used to weaken the methodology: giving permission to use generic data and default values would hinder the creation of better databases and the use of more specific data.

2 BPIE and Ramboll 2024, “Sufficiency in the building sector for the EU Whole Life Carbon Roadmap Final report