France’s RE2020, decoded for manufacturers

RE2020 in one minute

RE2020 is France’s environmental code for new buildings. It applies to housing submitted from January 1, 2022, and to new offices and primary or secondary schools from July 1, 2022, with extensions following in 2023 (Plan Bâtiment Durable, 2021). It pairs energy performance with life‑cycle carbon and a summer comfort check.

The two carbon levers you must track

Projects must pass both Ic construction, the embodied‑carbon of the building’s materials and site works, and Ic énergie, the operational‑energy carbon over the analysis period. From the 2025 step, limits tighten. Housing Ic construction caps move from 640 to 530 kg CO2e per m² for single‑family, and from 740 to 650 for multifamily. Office caps shift from 980 to 810, and primary or secondary schools from 900 to 770 kg CO2e per m². Multifamily Ic énergie falls to 320 kg CO2e per m² when connected to district heat and to 260 otherwise. These values are listed in the consolidated RE2020 annex updated after Decree 2024‑1258 (RT‑RE Bâtiment, 2025) (RT‑RE Bâtiment, 2025).

What changed in 2025

France published a simplification decree on December 30, 2024 that keeps the trajectory while adjusting how some targets are reached, especially for small units and buildings tied to classified heat networks. The ministry notes the goal is to ease compliance by favoring renewables and qualified networks without slowing decarbonization (Ministère de la Transition Écologique, 2025) (Ministère de la Transition Écologique, 2025).

2028 and 2031 are already on the horizon

The trajectory keeps tightening. For single‑family housing, Ic construction drops to 475 kg CO2e per m² in 2028 and to 415 in 2031. Multifamily steps to 580 in 2028 and 490 in 2031. Offices step to 710 in 2028 and 600 in 2031. Schools step to 680 in 2028 and 590 in 2031. These are the values authorities will use at permit time on those dates (RT‑RE Bâtiment, 2025) (RT‑RE Bâtiment, 2025).

Where EPDs fit, concretely

France runs on two EPD formats. FDES cover construction and decoration products. PEP ecopassport covers electrical, electronic and HVAC equipment. Both are third‑party verified and published in INIES, the national database used by RE2020 modeling tools. Validity is five years for FDES and PEP, assuming no significant product change (INIES, 2025) (INIES, 2025; INIES, 2025).

How big is INIES today

As of December 31, 2024, INIES listed 6,324 data sets, including 4,560 FDES and 1,342 PEP, plus defaults used when no specific data exists. The program also counted 567 FDES declarants and 101 PEP declarants at year end, showing strong industry uptake driven by RE2020 workflows (INIES Baromètre, 2025) (INIES Baromètre, 2025). In November 2025 the platform reported passing 7,000 total declarations, confirming continued growth into 2025 (INIES, 2025).

Why product‑specific data beats defaults

RE2020’s Ic construction formula includes a penalty term for default data. Teams can finish a building LCA with generic values, but they pay for it in the score. A product‑specific, third‑party verified declaration in INIES replaces those pessimistic defaults so the modeled carbon reflects the actual process rather than a generic estimate. That keeps your product in play when design teams evaluate “France building regulation RE2020” requirements at permit time.

Modeling details that change outcomes

The annex updated for 2025 added surface‑based modulators to Ic construction. The cap for a project is a base value multiplied or adjusted by coefficients for average unit size, total floor area, geography, foundations and parking, site works, and on some projects installed PV. Get these inputs right and you can unlock several dozen kg CO2e per m² of headroom in tough typologies (RT‑RE Bâtiment, 2025).

Getting an EPD ready for France

If you already publish EPDs, confirm they align to EN 15804+A2 with France’s national complement. The transition away from A1 format is complete in 2026, so A1 files no longer count in INIES after December 31, 2025 (Cerema, 2024). Choose the PCR that matches how competitors report, verify with an accredited program, then publish into INIES so modelers can pull the data directly. The real work is collecting complete, plant‑level data without burning out your operations leaders. That is where a white‑glove approach pays off.

Commercial signal to watch

The 2025 thresholds for Ic énergie in multifamily lower the allowable carbon from heat in a visible way, especially for projects off district networks. Product categories that reduce envelope loads and embodied carbon will see more early‑stage conversations, because they help teams clear two bars at once. In other words, the spec game skews toward verified, low‑carbon and easy‑to‑model products. That is not theory, it is how bids are screened now.

If you sell into France, start here

1. Map your portfolio against the 2025 and 2028 Ic construction caps for the typologies you serve using specific FDES or PEP, not defaults. Then identify the few SKUs where a new or updated declaration moves the needle fastest on large projects.
2. Build a clean data room. Utility bills for a chosen reference year, material inputs, scrap and yield, transport legs, packaging, and end‑of‑life assumptions. The better your inputs, the smoother verification runs.
3. Decide your publishing route. Many teams choose INIES for FDES or PEP ecopassport for equipment so the data flows straight into RE2020 tools. If you also market across the EU, align with EN 15804+A2 so a single core model feeds multiple registries. These steps sound simple but they are detail‑heavy, and time can slip by very quikly.

The short take

RE2020 rewards products with credible, accessible numbers. In 2025 the carbon gates narrowed and they will narrow again in 2028 and 2031. Manufacturers that bring A2‑aligned, INIES‑published declarations make it easier for design teams to comply and keep their products specified when the project carbon budget gets tight.