In 2028, RE2020, the French environmental regulation for new buildings, lowers the construction carbon impact threshold by one stage, for example from 650 to 580 kg CO2e/m² for multi-family housing under the initial grid. A decree on this stage has been announced for the end of 2026: until it is published, the grid in force applies.
For a manufacturer, the issue is not the threshold itself. It is what the threshold makes the consultancy calculating the building do: hunt for kilos of CO2e everywhere, starting with products that have no FDES (fiche de déclaration environnementale et sanitaire, the French environmental and health declaration for construction products).
RE2020 carbon thresholds
RE2020 limits the construction carbon impact of a new building, calculated by life cycle assessment (LCA) across all products and equipment. This threshold, the Ic construction, falls in stages in 2025, 2028 and 2031.
| Building type | 2025 | 2028 | 2031 |
|---|---|---|---|
| Multi-family housing | 650 | 580 | 490 |
| Single-family house | 530 | 475 | 415 |
Values in kg CO2e/m² for an average building, before project-specific modulations. Sources: annex to article R. 172-4 of the CCH (the French Construction and Housing Code), Conseil national de l'Ordre des architectes, Le Journal du BTP.
Between 2025 and 2028, multi-family housing loses 70 kg CO2e/m². On a building of several thousand square metres, the effort runs to hundreds of tonnes. Design teams spread it across the structure, joinery, insulation and equipment.
What already changed in 2026
Decree No. 2026-200 and an order of 18 March 2026 were published in the Journal officiel of 20 March 2026. They apply to building permit applications and prior declarations filed since 1 July 2026.
These texts follow the report by Robin Rivaton submitted on 10 July 2025. The decree adds modulations to the carbon threshold and eases the regime for rooftop extensions. The order deals only with rooftop extensions.
| Measure | What the text says |
|---|---|
| Balconies, loggias, stepped terraces (multi-family housing) | Nothing up to 10% of the reference area, then (MIN(amenity area / reference area; 0.25) - 0.1) x 110, so 16.5 kg CO2e/m² at most |
| Ceiling height (residential) | Modulation above an average of 2.50 m, capped at 2.90 m |
| Designated district heating network and air conditioning | +25 kg CO2e/m² on the threshold |
| High-rise buildings | 2028 threshold at 95% of the 2025-2027 value, 2031 threshold at 95% of the 2028 value |
| Rooftop extensions (excluding single-family houses) | Lighter requirements from 50 to 150 m², and beyond that if the extension stays under 30% of the existing area |
Flat roof terraces, ground-level terraces and access galleries do not count as amenity area. Sources: consolidated annex R. 172-4 published by the ministry, FFB.
This decree does not change the general 2028 grid. It only touches the stage for high-rise buildings: in multi-family housing, 617.5 kg CO2e/m² instead of 580. For everything else, the 2028 stage remains as in the table.
The 2028 decree expected at the end of 2026
In its reply published in the Journal officiel of the Assemblée nationale of 20 October 2026, the ministry announces a decree on the 2028 milestone by the end of the year, after consultation. The text is to say whether the carbon threshold will be raised and to better adapt housing to heatwaves (Batiactu, 21 October 2026).
As of 2 November 2026, no text has been published and the public consultations website shows no draft. The March decree followed this path: public consultation from 19 January to 9 February, CSCEE opinion on 10 February, publication on 20 March.
Until the decree is published, betting on a postponement would be unwise. We will update this article when the text comes out.
An adjustment of the thresholds does not change the logic for manufacturers. As long as the 2028 stage stays below the 2025 one, the pressure passes to products, and the default data modulation comes on top.
Why the pressure falls on products
The LCA of an RE2020 building contains no site-specific data for most products. It relies on the FDES and PEP published in the INIES database, France's national database of environmental declarations. When a product has neither, the consultancy takes default environmental data, inflated by 30% to 100%.
Faced with a lower threshold, the consultancy has two levers: change the construction solution, or replace default data with declared values. The second is often the faster. This is where the manufacturer with no declaration loses the specification.
A real example from the INIES database: an aluminium window declared at 88 kg CO2e weighs 187 kg CO2e with the default data. The mechanism is detailed in Default data or FDES: the gap in figures.
The default data modulation in 2028
A project's carbon threshold contains a modulation linked to its default data, the Mided. It depends on the Icded, the share of the building's impact calculated with this data, excluding lots 1, 2 and 13. It applies above a pivot specific to the building use, according to the year the permit application is filed.
| Use | Icded pivot (kg CO2e/m²) | 2022 to 2024 | 2025 to 2027 | From 2028 |
|---|---|---|---|---|
| Single-family house | 370 | +0.3 x (Icded - 370) | 0 | -0.3 x (Icded - 370) |
| Multi-family housing | 250 | +0.3 x (Icded - 250) | 0 | -0.3 x (Icded - 250) |
| Offices | 275 | +0.3 x (Icded - 275) | 0 | -0.3 x (Icded - 275) |
Source: annex to article R. 172-4 of the CCH, version in force since 1 July 2026.
The initial bonus ended in 2025, but the modulation has not disappeared: it is worth zero until the end of 2027, then becomes a penalty. A multi-family housing project with an Icded of 300 kg CO2e/m² will see its threshold fall by 15 kg CO2e/m². The Rivaton report recommends keeping it.
From 2028, default data therefore counts twice: in the project's impact, because it is inflated, and in the threshold, if there is too much of it.
A1 declarations no longer count
At the same time, INIES is archiving declarations prepared under the old version of the standard, EN 15804+A1. According to the INIES notice of 7 January 2026, declarations verified in 2021 and 2022 have been withdrawn since 1 July 2026, with no further postponement possible.
A manufacturer that published its declarations when RE2020 started may therefore find itself without valid data just as the 2028 stage approaches. We explain how to renew in FDES verification and validity.
What a manufacturer should prepare
Three actions, in this order.
- Take stock of your declarations. For each product specified in new construction: is there an FDES? Is it under A2? When does it expire?
- Measure the gap with the default data. For products with no declaration, compare the family's default value with the declarations published by competitors.
- Prioritise. Start with high-volume products in multi-family housing and commercial buildings, where the thresholds are most demanding and where consultancies search hardest.
An FDES takes several months from scoping to publication. To be ready at the start of 2028, a declaration must be launched by the first half of 2027 at the latest. The budget is detailed in EPD and FDES cost in 2026.
The dates to remember
| Date | Event | Source |
|---|---|---|
| 10 July 2025 | Rivaton report on RE2020 submitted | ecologie.gouv.fr |
| 1 January 2026 | A1 declarations verified in 2020 withdrawn from INIES (1 April in the event of an extension) | INIES notice |
| 19 January 2026 | Adjustments announced and public consultation opened on the first decree | Batiactu, decree 2026-200 |
| 20 March 2026 | Publication of decree 2026-200 and the order of 18 March | Légifrance |
| 1 July 2026 | Decree applies to new permits, A1 declarations from 2021-2022 withdrawn | Légifrance, INIES notice |
| 20 October 2026 | Ministry announces a decree on the 2028 milestone by the end of the year | Journal officiel of the Assemblée nationale |
| End of 2026 | Decree announced on the 2028 milestone, not published as of 2 November 2026 | Journal officiel of the Assemblée nationale |
| 1 January 2028 | 2028 stage of the RE2020 grid, negative Mided, European GWP display for large new buildings | Annex R. 172-4, European directive |
Where the pressure will be greatest
The stages do not weigh the same on all buildings. Multi-family housing and commercial buildings account for the large projects where a consultancy carries out the LCA carefully, lot by lot, and where every product is weighed.
These are also the projects where main contractors and clients have formal low-carbon approaches. They increasingly ask suppliers for their declarations from the tender stage. A manufacturer that cannot respond starts at a disadvantage before prices are even compared.
Single-family houses follow a different logic, with more solutions repeated from one project to the next. The 2031 stage, at 415 kg CO2e/m², will nevertheless make the choice of products just as decisive there.
At European level
RE2020 got ahead of Europe, which is now catching up. The Energy Performance of Buildings Directive requires the life cycle global warming potential of new buildings over 1,000 m² to be calculated and displayed from 1 January 2028, then of all new buildings in 2030 (European Commission).
For a manufacturer that exports, this means environmental declarations are becoming a requirement in countries other than France. We go through it country by country in Exporting an FDES in Europe.
What not to do
Do not wait for the decree before deciding. Its content is unknown, the penalty on default data is already written for 2028, and an FDES takes several months. A manufacturer that launches its declaration when the text comes out will arrive after its competitors.
Do not rely solely on a collective FDES when your product beats the sector average. A collective declaration protects you from default data, but it erases your advantage in the calculation.
Prepare for 2028 with your declarations
For the general framework of the FDES, EN 15804 and the INIES database, read our guide EPD: definition, framework and the FDES in France. We take stock of your declarations and estimate the gaps with default data before any quote: tell us about your products or see our environmental declarations offer.
Frequently asked questions
In 2028, the RE2020 construction carbon impact threshold (Ic construction) drops by one stage, for example from 650 to 580 kg CO2e/m² for multi-family housing under the initial grid. A decree adjusting these thresholds is expected before the end of 2026.
The ministry stated on 20 October 2026 that a decree on the 2028 milestone would be published by the end of the year, after consultation. As of 2 November 2026, no text has been published and no draft appears on the public consultations website: the grid in force remains the reference.
Because the building's LCA adds up the impact of each product using the FDES and PEP in the INIES database. The lower the threshold, the harder the consultancy looks for declared products, and the more readily a product calculated with default data is ruled out.
No. INIES is progressively withdrawing declarations prepared under EN 15804+A1; those verified in 2021 and 2022 have been archived since 1 July 2026. A product whose declaration is archived falls back on default data.