The building industry in Europe is undergoing a historic transformation driven by the revision of the Energy Performance of Buildings Directive (EPBD) in May 2024. The central objective is to achieve a property portfolio of net zero by 2050, which requires considering not only operational energy consumption but also greenhouse gas emissions from Full life cycle of the building.
The Basic Document of Environmental Sustainability (DB-HSA)
In Spain, this transition is articulated through the new Basic Environmental Sustainability Document (DB-HSA), integrated into the Technical Building Code (CTE). This document transcends the traditional energy saving approach to establish objective parameters that reduce the global environmental impact of buildings..
29 May 2026 is the transposition deadline for the new EPBD in Spain, which drives the incorporation of the DB-HSA into the CTE.
The DB-HSA is divided into two fundamental sections: the HSA 1, which regulates Global Warming Potential (GWP), and the HSA 2, dedicated to sustainable mobility (electric charging infrastructure and cycle parking).
Its main function is to define the national methodology for determining how much a building contributes to climate change from its construction to its end of life.
Obligations for 2028 and 2030
The mandatory declaration of carbon footprints will be implemented gradually in Spain according to project size:
- From 1 January 2028: The calculation and declaration of the PCG will be mandatory for all new buildings and extensions with a usable area exceeding 1,000 m².
- From 1 January 2030: This obligation will extend to Rest of new buildings and extensions, regardless of its surface area.
The resulting CGPC must be declared mandatorily through the Energy performance certificate of the building, both in the design phase and with the completed work.
Data and correction factors in the calculation of GGPC
To ensure the accuracy of the calculation, which in Spain is made on a 50-year study period, the regulation establishes a strict order of priority for emission data. The priorities are product-specific data, such as benefit declarations under Regulation (EU) 2024/3110 or Individual Environmental Product Declarations (EPDs) produced in accordance with standard UNE-EN 15804.
An innovative element is the application of correction factors) What penalises the use of less accurate data to encourage transparency from manufacturers:
- Individual DAPs or specific data: (without penalty).
- Ministry of Housing Database .
- Type III DAP databases (sector-specific DAPs): .
- Other databases compliant with UNE-EN 15941:
The strategic importance of individual DAPs.
The Environmental Product Declarations (EPDs) - individual They are the cornerstone of PCG calculation. As verified documents detailing the environmental impact of a material, they allow the designer to use the most favourable correction factor (1.00).
This not only makes the calculation more competitive, but it generates a “virtuous circle” where Regulation is pressuring manufacturers to environmentally certify their products if they wish to be chosen for cutting-edge projects.
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