The assignment to investigate how the introduction of a limit value can be done earlier than 2027

In February 2022, the government commissioned the Swedish National Board of Housing, Building and Planning (Boverket) to submit proposals on how to accelerate the introduction of limit values for climate impact from buildings and expand the application of climate declarations. On 10 May 2023, Boverket submitted a final report to the government. 

Legal proposal on limit values for the climate impact of buildings

Boverket submits a constitutional proposal on limit values for the climate impact of buildings, which can be introduced on 1 July 2025 at the earliest in the regulation on climate declarations for buildings. The limit value applies to the maximum climate impact for modules A1–A5 in kg CO2e/m2 GFA from the buildings that are erected and subject to regulation on climate declarations for buildings. The limit value is proposed to include all building elements from the foundation and its insulation excluding solar cells and fixed equipment. Limit values are proposed to be dealt in two groups, for the buildings covered by the climate declaration.

• Group 1 includes single-family houses, multi-dwelling blocks, office buildings, education excluding pre-school, pre-school, and special housing. A limit value corresponding to the median level of the building type reference value is proposed for this group (excluding single-family houses). For single-family houses, a limit value corresponding to the 75th percentile of the building type reference value is proposed instead.
• Group 2 includes other buildings where there are no robust reference values. A common limit value is introduced for this group, corresponding to the 75th percentile of the reference value for multi-dwelling blocks. Technical equipment and fixed interior design intended for the activity are not included in the climate declaration or limit value.

Limit values are proposed to be tightened every five years.

Proposal on a building’s whole lifecycle in a climate declaration from 2027

An expanded climate declaration is proposed to come in January 2027 in order to be able to make adjustments to similar future regulations from EU. The modules from the building's life cycle that are proposed to be included in the climate declaration are, in addition to modules A1–A5 the construction stage, B2 maintenance, B4 replacement, B6 operating energy, and C1–C4 end-of-life stage must also be included. The climate impact of groundworks and ground improvements must also be reported in a climate declaration.

Proposal on a climate declaration for alterations to existing buildings

A requirement for a climate declaration is also proposed for certain alterations to existing buildings from 1 January 2027. The requirement is limited to two measures that require a building permit. This requirement is applicable if the alteration means that the building is fully or partially occupied for, or is fitted out for, a substantially different purpose. The requirement is also applicable if an additional dwelling, or additional non-residential premises for commerce, skilled trades or industry are fitted out in the building. The climate declaration must cover the construction products included in the alteration that is subject to a climate declaration requirement and must be reported in kg CO2e per m2 GFA for modules A1–A4 + A5 construction product waste.

Boverket proposes that extensions shall not be subject to climate declaration requirement.

Proposal on a more precise supervision from Boverket on a climate declaration

Boverkets´ supervision of limit values for the climate impact of new buildings not exceeded places more precise demands on the design. A legally certain procedure is based on similar assessments being made using methods that have a basis on recognised standards. Such processing can only be achieved with a high degree of digitalisation and automation. Boverket therefore proposes that the developer should enclose a calculation base when the climate declaration is registered. The calculation base must be submitted digitally in a format and structure decided by Boverket. To make it easier for the construction sector, Boverket should be commissioned to investigate the use of the classification system CoClass in a climate declaration.

Impact assessment on legal proposals on climate declarations for buildings

Administrative costs are estimated to arise as a result of all regulations changes. The administrative costs are assessed to initially be incurred by developers and contractors, including the small and medium-sized enterprises. The cost of extra work, which primarily distinguishes a limit value from a climate declaration, is the cost of conducting climate calculations that follow the construction project from project planning to a finished building. It is mainly the developer who is affected. For contractors, the project planning stage becomes more important than before, which is considered to be a consequence of the limit value. There are greater opportunities in the design process, to make choices that optimize a building's climate impact.