Construction carbon footprint: RE2020, project LCA and EPDs

Quick answer. A construction carbon footprint covers two distinct exercises: the company's greenhouse-gas emissions report (scopes 1, 2 and 3, ADEME method) and the regulatory life-cycle assessment of buildings required by RE2020, based on the EPDs (FDES) in the INIES database. Mixing them up distorts management: one measures the organisation over a year, the other each building over 50 years.

A construction firm that wants to do its carbon footprint quickly hits a confusion: is it about the company's footprint, or the carbon impact of the buildings it constructs? Both exist, both are mandatory in different cases, and they are not calculated with the same tools. This article untangles the construction carbon footprint in three parts: RE2020 and building life-cycle assessment, the EPDs that feed this calculation, and the company's greenhouse-gas emissions report (BEGES). The goal: know which exercise applies to you, and how to turn it into a margin lever rather than a constraint.

The first carbon is that of the organisation: the greenhouse-gas emissions report (BEGES), which adds up the company's direct and indirect emissions over a year. The second is that of the building: the life-cycle assessment (LCA) of a new building, required by RE2020, which measures the footprint of a construction from material extraction to its end of life, over a 50-year study period.

Confusing the two leads to misreadings: thinking a company BEGES equals RE2020 compliance, or conversely that building a high-performance building exempts the company from measuring its own footprint. These are two scopes, two methods, two databases.

The 2020 environmental regulation (RE2020) has applied to new housing since 1 January 2022, then to offices and education buildings since 1 July 2022, with a gradual extension to other tertiary types. Alongside energy requirements, it introduced a measurement of the building's carbon footprint through life-cycle assessment.

The RE2020 LCA is said to be dynamic: it weights emissions according to when they occur over the 50-year life, which rewards materials that store carbon, such as wood. The calculation covers the building's components, energy consumption and the construction site itself.

Indicators and milestones#

RE2020 is checked through several indicators, each capped by a maximum value:

The key point for a construction firm is the Ic construction indicator: its maximum threshold tightens by regulatory steps, at the 2025, 2028 and 2031 milestones. At each milestone, the carbon weight allowed for construction falls, pushing towards lower-emitting materials and building methods. Anticipating these milestones avoids designing today buildings that will no longer pass the threshold tomorrow.

A building's LCA is not made up: it relies on standardised environmental data. For construction products, this data takes the form of EPDs (FDES in French, environmental and health declaration sheets), type III declarations compliant with ISO 14025, based on a product LCA and valid for 5 years. For equipment (HVAC, electrical, electronic), the equivalent is called a PEP (product environmental profile).

These sheets are hosted in the national INIES database, the official reference for RE2020. They are declared by manufacturers and trade bodies, and must now be verified by an independent third party, which strengthens their reliability.

When no EPD or PEP exists for a product, the calculation uses default environmental data, deliberately penalising: they include safety coefficients that increase the impact to cover uncertainty. The practical consequence: a project documented with real EPDs almost always shows a better carbon result than one calculated with default values. Choosing documented products becomes a direct compliance lever.

The second exercise, the greenhouse-gas emissions report, measures the footprint of the company itself. It is legally mandatory, under article L229-25 of the environment code, for private legal entities with more than 500 employees in mainland France (more than 250 overseas), to be renewed every 4 years and published on the ADEME platform, with a transition plan.

The BEGES covers three scopes: scope 1 (direct emissions, for example fuel for machinery and vehicles), scope 2 (indirect emissions linked to purchased energy) and scope 3 (the other indirect emissions, split into 15 categories: material purchases, transport, travel, end of life of structures). For construction, scope 3 is by far the heaviest, since purchased materials concentrate most of the footprint. Significant scope 3 has become mandatory for the entities concerned, with a broader scope for those that publish an extra-financial performance statement.

Below 500 employees, most construction firms are not legally required to produce a BEGES. Yet they increasingly do, pulled by tenders and clients who demand a supplier carbon footprint. To structure this approach, our first SME carbon footprint method sets out the framework of scopes 1, 2 and 3.

Beyond carbon, the construction site carries its own environmental obligations. The anti-waste law for a circular economy (AGEC) transformed the former waste diagnostic into a PEMD diagnostic (products, equipment, materials, waste), required for demolition or significant renovation operations covering a cumulative area of more than 1,000 sq.m. The diagnostic is sent to the designated body before work starts, and a reconciliation form is filed within 90 days after the works.

To this is added the EPR scheme (extended producer responsibility) for building construction products and materials, operational since 1 January 2023, financed by an eco-contribution and organised around 4 approved eco-organisations. The sector generates around 42 million tonnes of waste a year: the take-back and traceability of these flows are now full items in the site budget.

In construction files, the most common mistake is to treat carbon as a design-office formality, separate from management. It is a costly blind spot. The carbon weight of a structure is decided in design and procurement choices, that is, exactly where the margin is decided. A well-anticipated low-carbon building method can secure a tender; poorly anticipated, it is discovered at the permit stage and forces costly reworks.

Our recommendation: connect the regulatory calculation (LCA, EPDs) to the economic management of the project, and do not wait until you are at the threshold. For firms that want to turn the constraint into a commercial argument, controlled carbon becomes a measurable competitive advantage.

Take a structural-works SME bidding on a collective housing contract. Two building variants are on the table: a classic concrete solution and a mixed wood-concrete solution. The wood variant shows a better Ic construction, thanks to the carbon storage rewarded by the dynamic LCA over 50 years, but a material cost 8 % higher. The question is not only technical, it is economic.

By documenting the wood variant with real EPDs rather than default data, the design office gains several points on the carbon indicator, which can bring the project below the targeted milestone threshold without extra cost. The 8 % material premium must then be weighed against the value of the contract won and the premium granted by the owner to low-carbon bids. It is this calculation, carried out upstream, that turns RE2020 into a selection lever rather than a constraint endured. Securing the accounting traceability of these premiums and the related grants is part of rigorous bookkeeping and review.

• The RE2020 milestones (2025, 2028 and 2031) tighten the Ic construction indicator: a building method compliant today is not necessarily compliant at the next milestone.
• The BEGES scope 3 is mandatory for the entities concerned, with a broader scope for those that publish an extra-financial performance statement: do not reduce it to energy.
• EPDs must now be verified by an independent third party: prefer up-to-date sheets in the INIES database.
• The building EPR scheme is undergoing an ongoing overhaul: follow the changes in the eco-contribution and sorting instructions.
• The penalty for a missing BEGES can reach 50,000 euros, raised to 100,000 euros in the event of a repeat offence.