The Swedish Competition Authority submitted comments to the government on the National Board of Housing, Building and Planning’s proposal for calculating life-cycle global warming potential (GWP) and setting limits on the climate impact of buildings. The proposal concerns implementation of the EU Energy Performance of Buildings Directive, which requires declarations of buildings’ emissions and climate impact across their life cycle and, in future, limits for new buildings.

The authority considers it possible to design the limits using a broader life-cycle perspective than the proposal’s focus on the construction stage. It has previously noted that construction-stage-only declarations may disadvantage technologies and materials that have lower impacts in later stages of a building’s life cycle. It also recognises that a narrower calculation initially offered advantages because estimates for future life-cycle stages involve greater uncertainty.

However, the authority warns that limits based only on the construction stage could distort competition between materials, systems and solutions. They could also reduce incentives to innovate to lower environmental impacts across other life-cycle modules. The authority says the proposal lacks an in-depth assessment of its potential competitive effects and calls for a systematic comparison of Sweden’s calculation model with models and limits in other EU countries, including an assessment of how differences could affect competition.