The recently updated Energy Performance of Buildings Directive (EPBD) is a pivotal legislative framework aimed at improving the energy efficiency of buildings across the European Union. While its primary focus remains on energy savings and decarbonization, the revised EPBD now formally recognizes the crucial link between energy performance and Indoor Environmental Quality (IEQ). This update requires member states to address IEQ in their national legislation, ensuring that energy-efficient buildings also support the health, comfort, and well-being of their occupants.

---

A Framework for IEQ, Not a Rigid Standard

A significant aspect of the updated EPBD is its approach to IEQ. Rather than imposing a single, rigid set of Europe-wide limit values for all IEQ parameters, the directive establishes a flexible framework. This approach acknowledges the vast diversity in climate zones, building types, and occupant needs across the EU. The consensus is that a one-size-fits-all model would be counterproductive, potentially leading to suboptimal outcomes and hindering innovation.

The new EPBD defines IEQ as a comprehensive concept that includes several key domains:

• Indoor Air Quality (IAQ): Addressing contaminants and ventilation.
• Thermal Comfort: Pertaining to temperature and humidity.
• Lighting: Considering both natural and artificial light.
• Acoustics: Controlling internal and external noise.

This framework allows member states to set their own specific, measurable, and locally adapted criteria for each of these domains. The directive sets the high-level objectives—such as minimizing health impacts and ensuring occupant comfort—and then empowers national governments to implement these objectives in a way that best suits their unique circumstances. This performance-based approach encourages innovative solutions over purely prescriptive rules.

---

The Debate on IAQ Harmonization

While the flexible approach for IEQ as a whole is widely supported, a strong argument can be made for a more cohesive, harmonized strategy for Indoor Air Quality (IAQ) across all member states. The reasoning behind this perspective is that IAQ is a fundamental human need that transcends geographical and cultural differences.

The argument for common IAQ standards is based on several key points:

• Universal Health Needs: Unlike thermal comfort, which can vary based on climate and personal preference, all humans require the same clean air to breathe. Poor IAQ, characterized by pollutants like particulate matter (PM2.5​), volatile organic compounds (VOCs), and excess carbon dioxide (CO2​), has a direct and universal impact on human health, leading to respiratory diseases, allergies, and reduced cognitive function.
• Avoiding Fragmentation: A fragmented approach to IAQ could create significant disparities in health and well-being across the EU. It could result in a scenario where citizens in some countries are legally protected by stringent IAQ standards, while those in others are exposed to unhealthy indoor environments. A common standard would ensure that every European citizen, regardless of their location, has a right to a minimum level of healthy indoor air.
• Promoting Fair Competition: Harmonized IAQ standards would also create a more level playing field for the building and construction industry. By establishing common benchmarks, it would encourage manufacturers and developers to invest in and adopt high-quality ventilation systems, low-polluting building materials, and effective air filtration technologies across the entire EU market.

While the climate-related factors that influence temperature and humidity make sense for local adaptation, the core components of air pollution—such as biological agents, chemical contaminants, and particulate matter—are a universal threat. Therefore, a single, Europe-wide set of clear, common IAQ limits for key pollutants would not be a mistake, but rather a necessary step toward a truly cohesive and fair Europe.

In conclusion, the updated EPBD marks a significant step forward by integrating IEQ into its framework. However, the decision to allow member states to set their own IAQ standards risks creating a patchwork of regulations that could lead to unfair and unequal health outcomes for citizens. A unified approach to IAQ, with a clear set of common limits for key pollutants, would complement the directive’s objectives and ensure that the EU’s commitment to creating a sustainable future for its buildings is matched by a steadfast commitment to the health of its people.

References:

• Breathing Life into Efficiency: IEQ as a Cornerstone in Building Policy Session 1
• Breathing Life into Efficiency: IEQ as a Cornerstone in Building Policy Session 2
• Energy Performance of Buildings Directive
• Model Indoor Environmental Quality regulation aligning with new provisions