3 New Climate Legislation#
To accelerate the green transition within the Danish construction industry and align national practices with ambitious European climate targets, significant revisions to BR18 are scheduled for implementation July 1st, 2025. Driven by the Danish Political Supplementary Agreement of May 2024, these revisions introduce both newer and stricter limit values applicable to several building typologies, expanding the range of buildings that must comply with the upcoming CO₂e requirements. Additionally, life cycle modules A4 (transportation to construction site) and A5 (on-site construction), will be integrated into the mandatory LCA calculations for new constructions. These regulatory changes reflect Denmark’s strong commitment to significantly reducing the carbon footprint of its construction sector in alignment with the EU’s Fit for 55 goals, which aims for a 55% reduction in greenhouse gas emissions by 2030 and climate neutrality by 2050. This chapter provides an overview of the upcoming legislative changes taking effect on July 1st, 2025, and beyond.
3.1 New revision to BR18 in 2025#
Taking effect on July 1st, 2025, the Danish Building Regulations will introduce revised requirements under §§ 297–298, applicable to all new buildings and extensions for which building permits are sought from this date and onward. Building permits granted prior to July 1st will continue to comply with the current Danish legislation as outlined in 2 Current Danish Legislation.
The upcoming changes include the introduction of stricter limit values for multiple building typologies, each defined according to the specific construction type. Additionally, a new requirement has been established addressing the environmental impacts specifically related to the construction phase itself. Life cycle modules A4 and A5 are now included in the building LCA with its own separate required limit value. Compliance with both the building-specific limit value and the construction-phase limit value will be required. Figure 3.1 illustrates the median of emissions for A4 + A5, based on data from 52 projects in the Build Report 2023:14, showing how the emissions can be distributed for an average project. The limit value of 1.5 kg CO₂e / m² / yr is also derived from this median.
Modules A4 and A5 cover the following activities:
Transportation of materials from factories to construction sites, and transportation of equipment to and from the sites.
Energy consumption on construction sites (electricity, heating, and fuel).
Management and the processing of construction waste.
Removal and transportation of soil and waste.
Figure 3.1 Median of emissions for A4 + A5 based on the Build Report 2023:14 for 52 projects.
Consequently, contractors and subcontractors will need to actively document energy and fuel consumption, as well as quantify waste generated during individual construction projects to adhere to the required limit value of 1.5 kg CO₂e / m² / yr for A4 + A5.
Table 3.1 Overview of upcoming CO2e limit value for new construction
*The limit value today (prior to July 1st, 2025) is set to 12 kg CO₂e / m² / yr for a building with a heated floor area over 1000 m².
Documentation of compliance with the requirements listed in Table 3.1 is mandatory upon project completion. Although the table encompasses various building typologies, certain structures with specialized functions or specific requirements are exempt from adhering to these prescribed limits. The exemptions fall into the following two categories shown in Table 3.2.
Table 3.2 Overview of buildings that are exempt from adhering to the limit values
3.2 Updated Emission Factors & Relaxed Energy Requirements for Renovation#
With the 2025 revision of BR18, emission factors for the calculation of operational energy have been significantly reduced. Previous emission factors from 2020 no longer accurately reflect Denmark’s energy system, due to substantial changes to the energy infrastructure and increased reliance on more renewable energy sources. Illustrates the updated emission factors for electricity, district heating, and pipeline gas, comparing them to previous values and showing their projected trends up to 2050.
Figure 3.2 Overview of the updated emission factors compared to the current emission factors for electricity, District heating and Pipeline gas. Data provided from BUILD Rapport 2023:21 and BR18 Table 8.
At the same time, energy performance requirements for renovations are being relaxed to encourage the renovation of existing buildings instead of demolition and new construction, partly due to improved feasibility. The updated energy performance criteria are as follows:
Residential building, dormitories and hotels
from 30 kWh/m² → 70 kWh/m²
Other buildings:
from 41 kWh/m² → 95 kWh/m²
Moreover, with the updated emission factors you can expect to see a significant decrease in environmental impact for free on module B6 by simply using the new emission factors. Figure 3.3 highlights examples of how much you can decrease the environmental impact by utilizing the new emission values.
Figure 3.3 Climate impact of five cases calculated by Rambøll using both 2020 and 2025 emission factors for electricity, district heating and Pipeline gas.
However, the BR18 update also introduces a revised generic data basis for construction products. The changes coming in 2025 will result in an increased importance of material climate impact compared to previous assessments, while module B6 will experience a significant reduction due to updated emission factors as shown in Figure 3.4 illustrates the differences of an LCA calculation using emission data from BR18 (2023) and BR18 (2025). Overall, the example showns that using the updated emission data and calculation assumptions can lead to a total reduction in environmental impact of 13%. Additionally, material production will have a greater influence on the total environmental impact under BR18 (2025), and the benefits of using recycled materials will become increasingly significant.
Figure 3.4 LCA calculation of a case using BR18 (2023) and BR18 (2025) emission data and assumptions from BUILD Rapport 2023:21.
3.3 Danish Legislation Beyond 2025#
Section 3.1 and 3.2 describe upcoming legislation effective from July 1, 2025. To anticipate how Danish building legislation may evolve beyond 2025, one can examine recent legislative trends. In 2021, the Danish Ministry of Interior and Housing published a paper outlining the national strategy for sustainable construction, introducing LCA requirements and corresponding limit values, as detailed in Section 2. Since this publication, newer, more stringent environmental impact standards for buildings have been implemented, and additional building typologies have been included.
Figure 3.5 shows the cover of the 2021 paper published by the Danish Ministry of Interior and Housing. Liberty has been taken to adjust the title from “National strategy for sustainable construction” to “National strategy for more sustainable construction” to prevent unintentional greenwashing.
However, further tightening of these limit values before 2030 remains likely, as the current building industry practices still exceed planetary boundaries. Figure 3.6 illustrates the projected limit values up to 2030, highlighting that even these stricter limits surpass the Planetary Boundaries identified in Reduction Roadmap v2, with a 50% likelihood scenario.
Figure 3.6 Graph over projected limit values over time according to BR18 (2023), BR18 (2025) and Reduction Roadmap V2 with 50% likelihood that we will not see a temperature increase at the end of the century (e.g., 1.5°C or 2°C above pre-industrial levels).
To summarize, based on previous trends and the fact that we are yet to be within the planetary boundaries the Danish legislation beyond 2025 will likely get stricter criteria until we reach carbon neutrality in Denmark by 2050.
References#
Social- og Boligstyrelsen lancerer strategi for et nyt og helhedsorienteret bygningsreglement. (2024, June 24th).https://www.sbst.dk/nyheder/2024/social-og-boligstyrelsen-lancerer-strategi-for-et-nyt-og-helhedsorienteret-bygningsreglement
Social- og Boligstyrelsen – Ny aftale stiller ambitiøse klimakrav til nyt byggeri. (2024, May 30th). https://www.sm.dk/nyheder/nyhedsarkiv/2024/maj/ny-aftale-stiller-ambitioese-klimakrav-til-nyt-byggeri
European Council – Council of the European Union. Fit for 55. (2025, February 24th). https://www.consilium.europa.eu/en/policies/fit-for-55/#:~:text=The%20European%20climate%20law%20makes,EU%20climate%2Dneutral%20by%202050.
Videncenter om Bygningers Klimapåvirkning – Guide til grænseværdien for byggeprocessen i bygningsreglementets skærpede klimakrav fra 1. juli 2025. (2024, December). https://www.sbst.dk/Media/638731490173267243/VCBK_Guide_Byggeprocessen_fra_1._juli_2025-a[1].pdf
Aalborg Universitet - Ressourceforbrug på byggepladsen: Klimapåvirkning af bygningers udførelsesfase. (2025, November). https://vbn.aau.dk/da/publications/ressourceforbrug-p%C3%A5-byggepladsen-klimap%C3%A5virkning-af-bygningers-ud
Aalborg Universitet – Klimapåvirkning fra nybyggeri: Analytisk grundlag til fastlæggelse af ny LCA baseret grænseværdi for bygningers klimapåvirkning fra 2025. (2025, November). https://vbn.aau.dk/da/publications/klimap%C3%A5virkning-fra-nybyggeri-analytisk-grundlag-til-fastl%C3%A6ggelse
BR18 – Bilag 2: Tabel 8. (2020). https://www.bygningsreglementet.dk/bilag/b2/bilag_2/tabel_8/
Rambøll LCA Whitepaper – 2025 LCA requirements. (2024, November). https://brandcentral.ramboll.com/share/yPsLnjPunevMUrNL5fA5?_gl=11jr2fxm_gcl_au*MjAxNTE1NTk0Ni4xNzQyOTAyMTAw