Does every product sold in France need a French-format FDES?

Strictly, only products specified into buildings subject to RE2020 must provide FDES (or PEP for electrical equipment). If you sell into fit-outs or refurbishments, the legal trigger may not apply—yet. Market demand often does.

Can we reuse an EN 15804 EPD from another EU market?

Yes, but you must translate it into the French FDES/PEP schema and include dynamic-LCA fields. A verifier accredited by INIES must sign off before upload.

How long does an FDES stay valid under RE2020?

Five years, unless the underpinning PCR expires sooner. Renewal requires updated production data but not another round of dynamic weighting.

Is generic data ever good enough to pass a permit?

Possibly for tiny pilot projects, but generic values are often so conservative that the building will overshoot the 2025 caps. Most teams ditch suppliers without specific data rather than gamble.

RE2020: France’s Carbon Rulebook Hits 2025 Gear

RE2020 in one coffee break

Think of RE2020 as France’s upgrade from energy-only rules to a full-body scanner for buildings. Instead of checking just the energy a building will consume in use, it also measures the carbon locked into every beam, slab and finish—the whole-life impact—before a permit is issued (European Commission, 2024).

2025 thresholds: the squeeze starts now

The first tightening point has landed. Carbon limits on construction materials dropped by roughly 15 percent on 1 January 2025: individual houses slid from 640 kg CO₂e/m² to 530 kg CO₂e/m² and apartments from 740 to 650 kg CO₂e/m² (KHL, 2023). Two more cuts follow in 2028 and 2031. Miss today’s bar and you will chase specs for years.

Dynamic LCA: why early emissions bite harder

RE2020 weights each tonne of CO₂ by its time of release. An emission in year 0 counts as 1.00; wait fifty years and it scores just 0.58 (Ministry of Ecological Transition, 2025). Wood and other bio-based materials that store carbon early can leapfrog heavier options. Good news if your product traps carbon; a headache if it does not.

EPDs fuel the INIES database

Regulators do not eyeball brochures. They pull numbers from INIES, France’s official pool of 6 500+ environmental declarations as of July 2025 (INIES, 2025). Without a verified FDES or PEP in that pool, your material defaults to conservative generic data that may torpedo a project’s carbon budget.

Paperwork chain you cannot ignore

Publish a verified FDES/PEP and upload to INIES.
Architects model whole-building LCA with your data.
Project manager files a carbon declaration when applying for the permit.
A qualified professional confirms compliance at hand-over. Slip at step 1 and the chain snaps.

Cost or ticket to bid lists?

French developers estimate that meeting the 2025 cap can shave €10–€35 per square metre off structural works when low-carbon products are locked in early (Rivaton Report, 2025). Products with solid EPDs are already winning substitutions because nobody wants a last-minute redesign.

Choosing an LCA partner in the RE2020 era

Speed matters; summer permits queue up fast. Ask potential partners three blunt questions:

How many FDES have you published in the last twelve months?
Can you chase plant-level utility data so my engineers stay on the line?
What is the average time from kickoff to INIES upload? Anything beyond four months feels slooow.

Countdown to 2028

The carbon noose keeps tightening. Nail your FDES now, tweak formulations next year, and arrive at the 2028 checkpoint with room to breathe. Waiting could leave you scrambling when the music stops.