What to do with the EPB

In October 2024, a position paper and a website were published: “The Limits of the EPB” (epbd.limited) (“epbd” stands for “Energy Performance of Buildings Directive,” the 2002 European directive that gave rise to the EPB).


This position paper and website were an opportunity to do three things:

  1. Inform and raise awareness
    about the issue. The apparent complexity of the system leads the public to think that it’s a purely technical matter with little political weight. That is obviously not true.
  2. Assess how much our discourse matches public opinion.
    It became clear that our concern is widely shared: the reach and the number of signatories confirmed what the existing studies and articles had already suggested. Among the signatories were researchers and teachers, well-known ecological architecture firms, Brussels associations, and members of administrations signing in a private capacity.
  3. Contribute to a public debate
    on improving the current strategy and developing alternative approaches. On 5 February 2025, we organised a discussion evening aimed at moving beyond observations, gathering proposals, and debating adjustments. The minutes of this discussion, where diverging views and contradictory suggestions sometimes emerged, can be read on the website.


After further work and exchanges, we chose to adopt several proposals, outlined below. They fit into a broader perspective that we wish to follow—a rather familiar one but, essential as our guiding compass:
to collectively and fairly reduce the real consumption of energy and materials in buildings.

In relation to this position, it seemed necessary to us to highlight the main blind spot of a policy that focuses only on the thermal renovation of housing: the legislator chose to consider buildings in themselves, empty of their inhabitants, their uses, their ways of life. And the intention is clear: to reduce the energy challenge to a purely technical question, which is indeed much simpler. In doing so, however, an essential step has been missed. There is a considerable gap between:

  • What “the walls” and infrastructure can do, when considered purely mechanically, which is what current measures heavily rely on within a “whatever-it-takes” approach, both budgetary and social (note, in passing, the contrast with the efforts made to fight against unhealthy housing);
  • And on the other hand, what those same walls can (or cannot) achieve in human reality, once inhabited and lived in by a diversity of residents, each with their own habits, their varying levels of knowledge or ignorance about how heating and ventilation systems function.

This means two essential things simultaneously: firstly, there is considerable room for improvement without heavy renovation, through better control of systems and possibly adapting practices; secondly, further effort is imperative beyond major renovations, which on their own cannot achieve everything, if not followed by appropriate maintenance and use.

A truly effective, inclusive, and ambitious policy must therefore focus on the whole, composed of both the walls and the occupants. To overcome the limits of the EPB, the key is to better balance the efforts required. Certainly, we should not throw out the EPB with the bathwater, but the bathwater still needs to be drained: trimming down the EPB, while investing in complementary actions.

  • Levier 1 : Verspreiden van basiskennis en werken aan de regulering van installaties
  • Levier 2 : Een juiste en toegankelijke kennis van verbruik verschaffen
  • Levier 3 : Het energieprijsbeleid verfijnen
  • Levier 4 : Mikken op robuustheid en eenvoud van gebouwen, en bio-gebaseerde materialen waarderen
  • Levier 5 : Ad-hoc vereisten formuleren voor bestaand vastgoed
  • Levier 6 : De EPB-certificaatindices herdenken en een globaler zicht op het pand bieden
  • Levier 7 : Een systeem van “energetische lasten” overwegen

Part 1 –


Spread basic knowledge and work on regulating installations ↑

How many people really know how to use a room thermostat and radiator valves? How many heating systems are optimally regulated? The potential for improvement here is huge compared to the current situation—both in terms of comfort and energy savings—and at relatively low cost compared to renovation works. Possible actions:

  • Rely more on associations that provide concrete advice on housing and rational energy use (information desks, info sessions, home visits, school interventions, etc.). Energy savings will not happen unless residents have real control over their homes.
  • Train frontline staff in various administrations. By giving them some basic knowledge about ventilation, thermostats, and radiator valves, immediate results could be achieved.
  • Seriously check the regulation of technical installations. For boiler rooms >100 kW, the EPB-heating legislation requires an “EPB Diagnosis” every 5 years to optimise regulation. Given the quick benefits of good regulation, this control should be extended to all boiler rooms (even if less frequent, e.g., every 10–15 years).



Part 2 –


Provide accurate and accessible knowledge of consumption ↑

In order to take action, one must have comprehension. Concrete and precise data are useful both for authorities designing strategies and for households needing tools for better control. Possible actions:

  • Equip each dwelling with individual meters and accelerate the rollout of smart meters.
  • Provide households with reference consumption figures that allow them to make comparisons themselves, taking into account household size and the EPB category of their home. These benchmarks should raise awareness and feed reflection. They could be based on statistical averages/medians or on collectively agreed reduction targets.
  • Regulate service charge billing by imposing a single calculation method for buildings with collective equipment.


Part 3 :


Refine the energy pricing policy ↑

Prerequisite 1: Have reliable energy accounting (see Part 2).


Prerequisite 2: Have reliable household composition data that reflects actual occupancy; it should be possible to know how many people live at an address and to what extent they are actually present (holidays, telework, shared custody, unemployment, retirement, illness…). This data would be known only by the State and remain confidential, just like annual tax declarations.

As with Parts 1 and 2, the goal is to work as close as possible to real consumption, to influence it positively while protecting the most vulnerable. With these prerequisites, one could:

  • Vary tariffs according to quantities consumed per person (progressive tariffs), to encourage real energy savings (achieved through frugal behaviour and/or effective insulation), and ensure that the biggest consumers contribute most to financing mitigation and adaptation measures for climate change.
  • Vary tariffs according to income (differentiated tariffs for low/medium/high incomes), to guarantee access to energy for all. This socially necessary measure is coherent with the fact that the less costly lifestyles of poorer households are also less damaging to the environment.


Part 4 :


Aim for robustness and simplicity of buildings, and promote bio-based materials ↑

The current EPB system focuses attention on the insulating power of materials (not their durability or environmental cost of production) and favours complex heating and ventilation systems (at the expense of robustness and resilience). Possible actions:

  • Recognise and value the qualities of older and low-tech constructions: their independence from technical systems and flexible spaces are a unique guarantee of sustainability—like the famous “Brussels houses” that have adapted over centuries.
  • Give more importance, within architectural culture, to the knowledge of materials, the implementations and the way they age. These issues should be discussed beyond construction sites; they have a rightful place in lectures and courses.
  • Require manufacturers (or contractors) to document the ageing of products, materials, and systems. Otherwise, give more resources to associations or universities to ensure post-construction monitoring.
  • Do not take life cycle analyses (LCA) at face value. Tools like Totem (common to all 3 Belgian regions) are useful, but assumptions about lifespan and recycling are less reliable.
  • Lower thermal resistance requirements for bio-based insulation. The savings in embodied energy could compensate for lower thermal performance.
  • Promote natural or improved natural ventilation (System A+), or partial solutions (e.g., partial System D), and discourage systematic double-flow systems. These often escape user control, require maintenance, and can malfunction if neglected. If mechanical ventilation is installed (MV), require compliance certification/regular checks, like with boilers.


Part 5 :


Formulate ad-hoc requirements for existing buildings ↑

D’abord ne pas nuire.

The current EPB obligations are defined by numerical thresholds. By 2033, homes with an EPB class of F or G (theoretical consumption >275 kWhEP/m².year) will be penalised, followed by classes D and E (>150 kWhEP/m².year). This threshold-based approach does not account for construction realities or the opportunities of specific configurations. It is urgent to express obligations with material sensitivity that goes beyond raw numbers. Possible actions:

  • Avoid setting requirements in terms of EPB labels and instead impose roof insulation and improvements to heating systems. These obligations make far more sense constructively than abstract numerical limits. Moreover, these actions are technically well understood, unlike others: window replacement without ventilation leads to new types of unsanitary conditions; wall insulation is heavy, costly, and often polluting; installing a heat pump without major insulation works can be very energy-intensive.
  • Address energy improvement on a case-by-case basis. Two buildings of different ages, contexts, and configurations should be renovated differently, even if they do not reach the same standards. For some homes, escaping F and G might mean just insulating the roof or renovating the boiler room, while in other cases it will involve much heavier, less profitable, and technically delicate work.


Part 6 :


Rethink EPB certificate indices and provide a more global view of the property ↑

The EPB certificate describes energy aspects in a questionable way. Moreover, energy is only one aspect, and others are not highlighted enough. Possible actions:

  • Reconsider the main EPB unit (kWh/m²):
    • Speak in terms of Power [kW] rather than energy [kWh]. The current use of theoretical kWh is ambiguous. Watt, on the other hand, is more relatable (everyone can compare to the power of a vacuum cleaner, light bulb, etc.). Power is by definition a possibility, making it clearer.

    • Highlight total performance [kW(h)], without dividing by square meters, since that division hides the impact of the property’s size. What matters to residents (and the planet) are the total quantities.

  • Take into account the number of people who can benefit from the energy consumed. For equity, this is useful. Inspiration could come from water-heater EPB labels, where performance is based on withdrawal profiles (S, M, L, XL). Similarly, a dwelling’s energy performance could be linked to an advised occupancy rate (e.g., based on number and size of bedrooms).
  • Integrate location impacts into the energy performance calculation. Proximity to schools, shops, and public transport affects potential energy use and should be considered (see “Mobiscore” in Flanders).
  • Indicate the theoretical temperature reached when consumption does not exceed the “virtuous” threshold of 150 kWh/m².year. Instead of fixing temperature to obtain kWh, fix kWh to obtain temperature. This would highlight the link between energy and temperature.
  • Provide a more complete picture of properties through a “building passport” centralising available information: EPB certificate, electrical compliance, asbestos-free status, etc.


Part 7 :


Consider a system of “energy charges” ↑

For any real estate project of a certain scale, the applicant is required to integrate housing, equipment, roads, or green spaces into the project. These are called urban planning charges. We could build on this idea to collectively work on energy savings. Possible actions:

  • Design a system where new large-scale constructions are not only energy-neutral but ideally energy-positive (A+ in Flanders), meaning they must also contribute to producing decarbonised energy. This production would benefit the surrounding neighbourhood and reduce the collective footprint.
  • Require that developers of new housing projects also contribute to improving the adjacent housing stock (replacement of obsolete technical equipment, etc.).


Conclusion ↑

To some extent, EPB policy is part of the solution. However, it has its limits, and while it should not be discarded entirely, we must not rely on it alone. Resources must also be dedicated to other approaches, currently underused or ignored. Several of the proposals above are already being studied or implemented by administrations, but we must stress their importance.

It also seems essential to develop a coherent overall environmental strategy: otherwise, how can we justify the pressure on housing while allowing low-cost flights, giant data centers, or fast fashion?

We sometimes feel like the European legislator is isolated on an island; surrounded by commercially driven lobbies, European co-legislators launch large vessels that member states then struggle to manoeuvre. In comparison, the proposals above are like modest bottles thrown into the sea from a small atoll by a few concerned but, not hopeless buccaneers: with the help of benevolent sea gods, these messages sometimes reach their destination. May these proposals feed the debate.