Last year, the DG for energy announced a package of documents that would support EU countries to implement the Energy Performance of Buildings Directive (EPBD). The effective implementation of this bill "will help to strengthen energy independence, lower energy bills, lower grid investment needs [...] and achieve the energy efficiency goal of reducing energy consumption by 11.7% by 2030."
The EPBD is essentially the first time indoor environmental quality (IEQ*) (and with it, indoor air quality (IAQ)) has been written into law as a core objective, instead of an afterthought, which is a huge deal from a biosecurity perspective. However, seeing as this is a directive of the Directorate General of Energy, these documents only make a offhand reference to the link between air quality and risk of airborne pathogen transmission and otherwise ignore the overlap between these issues.
1. The Energy Performance of Buildings Directive (EPBD)
This directive sets some minimum energy performance requirements for buildings, while also requiring varying considerations of IEQ depending on the building (new vs. existing building, public vs. private, etc.)
All new buildings must be zero-emission by 2028 for public buildings and by 2030 for all other new buildings. For existing building, this comprises of a collection of laws ranging from specifications around large scale renovations, updated building logbooks, and Minimum Energy Performance Standards for non-residential buildings.
For IEQ specifically the following is specified:
All buildings (new + existing) with minimum energy performance requirements must also account for optimal IEQ, so efficiency measures don't cause inadequate ventilation.
New buildings and major renovations must specifically address the issue of optimal IEQ in their design.
New non-residential zero-emission buildings must be equipped with IAQ monitoring and regulation devices.
Member States must set their own national requirements for "adequate IEQ" to maintain a healthy indoor climate.
Existing buildings that are not undergoing major renovation are covered only insofar as the national IEQ standards apply generally, and insofar as national Minimum Energy Performance Standards eventually force renovation, which will be regulated.
2. Implementation of the EPBD IAQ standards
The directive intentionally doesn't set numeric IAQ/ventilation thresholds, leaving this to a set of CEN standards (mainly EN 16798-1) to guide national implementation of the directive in collaboration with expert bodies such as REHVA. Alongside this, a delegated regulation and an implementing regulation address other matters in the EPBD.
The implementation of this IAQ will be mainly achieved through controlling pollutant sources and adequate ventilation in non-residential buildings. The success of these measures can be proxied by measuring CO2 .
It's worth noting that the deadline for implementing this regulation was May 2026 and that not a single one of 27 member states has fully transposed this directive into national law before this deadline. This is both a sign of a clear implementation bottleneck for this directive, as well as another example of a documented pattern of member states consistently ignoring environmental regulation despite the estimated cost of this totaling up to €180 billion a year.
3. What does this mean from a biosecurity perspective?
As no member states have implemented the transposition in national law yet, it is hard to tell what exactly this directive would mean in terms of effective pathogen dilution if ventilation standards are met. However, if we go off of the proposed guidelines, I suspect that a probable answer lies somewhere in the realm of "not enough".
For example, the document specifies suggested ventilation filtration systems with grade ePM1 or ePM2.5 for outdoor air intake. This is focused on removing outdoor air pollutants, but will not aid in filtering respiratory pathogen particles that are already present in the building.
In fact, REHVA states that this standard is lacking for health considerations and has proposed a addendum to this in 2023 to account for respiratory infectious diseases that could extend the current comfort based standards; for example, by using portable air cleaners (such as those with HEPA filters). This forms a possible base for a formal revision of the EN 16798-1 standards.
This revision of EN 16798 is still in progress, and states trade-offs from an energy perspective that vary depending on the type of space. For this reason, a proposition would be to: a. prioritization of certain environments (healthcare establishments, schools, etc.) b. along the line of REHVA's proposal: allow for an on/off switch that enables increased ventilation during pandemics and high-risk seasons (e.g. flu season), while having an established year-long baseline that conforms to the comfort and climate standards.
It is important to note that, although this directive is not aimed at improving indoor air quality from a pathogen-spread perspective, it will form an important base for biosecurity focused IAQ in the future. For example, the mere implementation of using a ePM1-ePM2.5 grade filtration system for outdoor air is an important prerequisite to be able to use CO2 as a proxy for indoor air quality. Equipping buildings with this base can (and hopefully will) be a start to pandemic proofing our indoor spaces.
* Indoor environmental quality is an umbrella term for all conditions inside a building. This includes indoor air quality as well as thermal comfort, lighting quality and acoustics. References to IEQ in the EPBD refer to thermal comfort and IAQ.
Disclaimer: Claude was used during the drafting of this document.
Last year, the DG for energy announced a package of documents that would support EU countries to implement the Energy Performance of Buildings Directive (EPBD). The effective implementation of this bill "will help to strengthen energy independence, lower energy bills, lower grid investment needs [...] and achieve the energy efficiency goal of reducing energy consumption by 11.7% by 2030."
The EPBD is essentially the first time indoor environmental quality (IEQ*) (and with it, indoor air quality (IAQ)) has been written into law as a core objective, instead of an afterthought, which is a huge deal from a biosecurity perspective. However, seeing as this is a directive of the Directorate General of Energy, these documents only make a offhand reference to the link between air quality and risk of airborne pathogen transmission and otherwise ignore the overlap between these issues.
The following paragraphs cover the following:
1. The Energy Performance of Buildings Directive (EPBD)
This directive sets some minimum energy performance requirements for buildings, while also requiring varying considerations of IEQ depending on the building (new vs. existing building, public vs. private, etc.)
All new buildings must be zero-emission by 2028 for public buildings and by 2030 for all other new buildings. For existing building, this comprises of a collection of laws ranging from specifications around large scale renovations, updated building logbooks, and Minimum Energy Performance Standards for non-residential buildings.
For IEQ specifically the following is specified:
2. Implementation of the EPBD IAQ standards
The directive intentionally doesn't set numeric IAQ/ventilation thresholds, leaving this to a set of CEN standards (mainly EN 16798-1) to guide national implementation of the directive in collaboration with expert bodies such as REHVA. Alongside this, a delegated regulation and an implementing regulation address other matters in the EPBD.
The implementation of this IAQ will be mainly achieved through controlling pollutant sources and adequate ventilation in non-residential buildings. The success of these measures can be proxied by measuring CO2 .
It's worth noting that the deadline for implementing this regulation was May 2026 and that not a single one of 27 member states has fully transposed this directive into national law before this deadline. This is both a sign of a clear implementation bottleneck for this directive, as well as another example of a documented pattern of member states consistently ignoring environmental regulation despite the estimated cost of this totaling up to €180 billion a year.
3. What does this mean from a biosecurity perspective?
As no member states have implemented the transposition in national law yet, it is hard to tell what exactly this directive would mean in terms of effective pathogen dilution if ventilation standards are met. However, if we go off of the proposed guidelines, I suspect that a probable answer lies somewhere in the realm of "not enough".
For example, the document specifies suggested ventilation filtration systems with grade ePM1 or ePM2.5 for outdoor air intake. This is focused on removing outdoor air pollutants, but will not aid in filtering respiratory pathogen particles that are already present in the building.
In fact, REHVA states that this standard is lacking for health considerations and has proposed a addendum to this in 2023 to account for respiratory infectious diseases that could extend the current comfort based standards; for example, by using portable air cleaners (such as those with HEPA filters). This forms a possible base for a formal revision of the EN 16798-1 standards.
This revision of EN 16798 is still in progress, and states trade-offs from an energy perspective that vary depending on the type of space. For this reason, a proposition would be to:
a. prioritization of certain environments (healthcare establishments, schools, etc.)
b. along the line of REHVA's proposal: allow for an on/off switch that enables increased ventilation during pandemics and high-risk seasons (e.g. flu season), while having an established year-long baseline that conforms to the comfort and climate standards.
It is important to note that, although this directive is not aimed at improving indoor air quality from a pathogen-spread perspective, it will form an important base for biosecurity focused IAQ in the future. For example, the mere implementation of using a ePM1-ePM2.5 grade filtration system for outdoor air is an important prerequisite to be able to use CO2 as a proxy for indoor air quality. Equipping buildings with this base can (and hopefully will) be a start to pandemic proofing our indoor spaces.
* Indoor environmental quality is an umbrella term for all conditions inside a building. This includes indoor air quality as well as thermal comfort, lighting quality and acoustics. References to IEQ in the EPBD refer to thermal comfort and IAQ.
Disclaimer: Claude was used during the drafting of this document.