
Belgium
Flanders Building GWP Proposal Creates An As-Built Carbon Evidence Chain
A Flemish proposal would bring lifecycle global warming potential into building energy certificates from 2028.
2 min readAI-drafted, expert reviewed

A Flanders building GWP proposal would create the legal machinery for calculating, certifying and recording the lifetime climate impact of construction materials. Belgium notified the draft to the European Commission on 22 July 2026. It matters across cement, concrete, steel, insulation, chemicals, construction products, property development and design because credible building calculations depend on comparable product data.
Lifecycle Carbon Moves Onto The Energy Certificate
The Flanders building GWP framework implements the materials provisions of the revised EU Energy Performance of Buildings Directive. Lifecycle global warming potential would appear on energy performance certificates from 1 January 2028 for new buildings above 1,000 square metres, and from 1 January 2030 for all new buildings. Maximum GWP limits must also be established from 2030.
That shifts embodied carbon from a voluntary design exercise towards a regulated project output. A developer choosing concrete, glazing, insulation or floor finishes will need data that can survive design revisions and quality checks. Manufacturers with robust environmental product information may gain an advantage when specifiers compare lower-carbon options.
OVAM Would Oversee Calculation Quality
The draft gives the Public Waste Agency of Flanders a central role in methodology, the calculation database, material-performance certificates and quality assurance. Flanders already operates the voluntary TOTEM calculation tool, providing a foundation for the new system.
A certified material-performance officer would prepare the calculation and must be an architect or energy-performance reporter. Certification bodies would themselves require recognition. More detailed conditions and limits will follow through an implementing decree that Belgium says will be notified separately.
Prepare Data That Follows The Product
Product manufacturers should check the coverage, age and comparability of environmental declarations, then connect carbon data with product identifiers and technical documentation. Contractors and designers should decide who records substitutions and collects evidence when materials change on site, so the final calculation reflects materials actually installed. The current TRIS standstill for the Flanders building GWP draft ends on 23 October 2026.
Official source
European Commission Technical Regulation Information System, Flemish building GWP draft received 22 July 2026technical-regulation-information-system.ec.europa.eu
Topics
Questions about this change
Which buildings would need lifecycle GWP calculations?
Under the EU timetable described in the notification, lifecycle GWP must appear on energy performance certificates from 1 January 2028 for new buildings above 1,000 square metres, then for all new buildings from 1 January 2030. Flanders still needs implementing rules to define detailed methodology, scope and maximum limits.
What should construction-product manufacturers prepare?
For Flanders building GWP compliance, manufacturers review environmental product declarations, formulation-change controls and the evidence supplied to designers. Data should be comparable and easy to transfer into building calculations. Suppliers should monitor the implementing decree, because it will refine methodology, certification conditions and limits beyond the basis notified by Belgium.

Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
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