RE2020 explained for building product manufacturers

RE2020 in one minute

RE2020 is France’s environmental rulebook for new buildings. It blends energy performance with whole‑building life‑cycle carbon and summer comfort, then checks compliance at permit and completion. If you want RE2020 explained in one line, think of it as EN 15804 data meeting building‑level LCA with legally binding thresholds.

Who it applies to, and the 2025 step

RE2020 has applied since 2022 to new housing and selected tertiary uses like offices and primary or secondary schools, with other uses phasing in over time. A government update in late 2024 adjusted several coefficients and confirmed tighter limits from January 1, 2025 (RT‑RE Bâtiment Guide, 2025) (Guide RE2020, 2025).

The two carbon indicators that decide outcomes

RE2020 watches two LCA‑based indicators over a 50‑year reference life.

• Ic Construction covers materials, products, and the construction phase. From January 1, 2025, the maximum for houses is 530 kg CO2e per m², and for apartments 650 kg CO2e per m² (Legifrance, 2024) (Legifrance, 2024).
• Ic Énergie covers the carbon of energy use. For collective housing it tightens to 260 or 320 kg CO2e per m² depending on whether the building is on a qualifying district heating network. The house limit remains 160 kg CO2e per m² (Legifrance, 2024) (Legifrance, 2024).

These are headline values. Projects apply modulations for climate zone, size and a few specific technical conditions that the official guide spells out (RT‑RE Bâtiment Guide, 2025).

Why EPDs are now day‑one inputs

RE2020 building LCAs pull product data from INIES. Product‑specific FDES for construction materials and PEP ecopassport for equipment slot directly into the model. If a product lacks a verified declaration, designers must use generic defaults that are intentionally conservative. That makes EPDs a pricing variable in disguise because pessimistic data can push a project over its Ic caps.

INIES by the numbers

As of December 31, 2024, INIES reported 6,324 datasets, including 4,560 FDES and 1,342 PEP, plus 1,691 default entries, all available for building LCA tools used with RE2020 (INIES Barometer, 2025) (INIES Barometer, 2025). The base keeps growing, which reduces the need for generic data and smooths compliance.

How generic data hurts your chances

RE2020 allows default data, but it is designed to be penalizing. The more a project leans on defaults instead of product‑specific declarations, the harder it becomes to pass tightening Ic thresholds. Teams increasingly specify products with current, third‑party verified EPDs to protect their carbon budget and avoid last‑minute redesigns.

What manufacturers should prioritize now

Publish product‑specific EPDs that match how designers actually model buildings. That usually means FDES for materials and PEP for building equipment. Favor current EN 15804 compliant rules, include all relevant modules, and provide regionalized transport scenarios where they materially change results. A good partner will wrangle plant data with you so engineering and operations keep working instead of drowning in spreadsheets.

Fast‑track playbook to be RE2020‑ready

• Map your SKUs to the assemblies RE2020 counts most in your category. Start with the high‑volume and high‑mass lines.
• Confirm the right PCR and operator for France, then collect a clean 12‑month reference year of utilities, materials, yields and waste.
• Model improvements you can ship within the EPD cycle, like recycled content or lower‑carbon binders, and document them clearly.
• Publish to INIES promptly so specifiers see your data in the tools they use daily.
• Keep renewal dates visible for sales so a “valid through” surprise never blocks a bid. Dont let expirations sneak up.

Common traps that stall specifications

Assuming a generic EPD elsewhere in Europe is enough for RE2020 will burn time. Ignoring logistics can backfire because transport is part of Ic Construction. Sending a marketing brochure instead of a verifiable declaration slows engineers who need machine‑readable data. Finally, treating an older EPD as a weakness is a mistake unless it is close to expiry.

Commercial edge, not just compliance

Projects under RE2020 pick products that keep the whole building under its caps. A product with a speficic, verified declaration is less likely to be swapped at the eleventh hour. The cost to create an EPD is routinely offset by winning even a single mid‑sized job where carbon is a gating criterion. That is why the smartest teams make data collection painless for plants and publish quickly.