Implementation of the EPBD in Finland

Status in November 2010

Maarit Haakana
Ministry of the
Environment 1> Introduction

The implementation of the EPBD in Finland is based on laws and decrees published
in 2007. Since the last report in August 2008, some amendments have been made to
Finland energy certification provisions and minimum energy performance requirements. At
the moment, the implementation of the Recast of EPBD is under discussion.

In Finland, the implementation of the EPBD is the overall responsibility of the

Ministry of the Environment. This report presents an overview of the current status
of implementation and plans on how the implementation will unfold. It addresses
certification and inspection systems, including quality control mechanisms, training
of Qualified Experts, information campaigns, incentives and subsidies.

2> Certification

National websites: In Finland, the Ministry of the Environment is responsible for legislation and
guidelines regarding energy performance certificates, energy performance
› www.ymparisto.fi certificate templates and other instructions concerning the issue of certificates. The
› www.ymparisto.fi/en Ministry of the Environment has designated two accreditation bodies to approve
ergiatodistus qualified experts. All material pertaining to energy performance certificates is
› www.motiva.fi/energi available on the Ministry’s website.
atodistus
For all new buildings, certificates must be presented when applying for a building
permit. The certification of new buildings began in early 2008. New buildings
constructed in strict accordance with the requirements of the Building Regulations
2010 would typically fall into energy class C.

As of January 2009, all existing buildings must be certified when sold or rented.
Energy certificates for existing buildings can be issued in three different ways. The
building owner may choose which type of certificate will be used:
1) included in the property managers' certificate
2) issued through a so-called "separate energy certificate"
3) in connection with an energy audit.

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The implementation timetable has been the same for all building types.

An energy certificate will be valid for 10 years for most buildings and for four years
in the case of new apartment blocks and commercial buildings.

Certificates for new buildings will be provided by the principal designers of the
buildings. For existing buildings, the energy certificate may be issued by a qualified
expert, energy auditor or property manager. When a qualified expert issues an
energy certificate, it is called a "separate energy certificate".

Premises of public authorities providing public services and with more than 1,000
m2 will be required to display energy certificates. This requirement was set in the
new law that will come into force in the beginning of March 2011.

The energy performance certificate

An energy certificate assigns an energy performance label to buildings and lists

measures for improving their energy performance.

ENERGIATODISTUS

Rakennus
Rakennustyyppi: Asuinkerrostalo Valmistumisvuosi: 1959
Osoite: Hauhontie 1200 Rakennustunnus: 123-456-7-89 B 001
Hauho

Energiatodistus on annettu
rakennuslupamenettelyn yhteydessä ja perustuu laskennalliseen kulutukseen
energiakatselmuksen yhteydessä ja perustuu toteutuneeseen kulutukseen
x erillisen tarkastuksen yhteydessä ja perustuu toteutuneeseen kulutukseen

Rakennuksen
ET-luku Vähän kuluttava ET-luokka
- 100

101 - 120

121 - 140

141 - 180

181 - 230 E
231 - 280

281 -

Paljon kuluttava

Rakennuksen energiatehokkuusluku (ET-luku, kWh/brm²/vuosi): 218

Energiatehokkuusluvun luokitteluasteikko: Suuret asuinrakennukset

Todistuksen antaja: Todistuksen tilaaja:

Eero Energia-Asiantuntija Matti Meikäläinen

Allekirjoitus:

Todistuksen antamispäivä: Viimeinen voimassaolopäivä:

1.1.2008 31.12.2017

The energy label classifies buildings on an efficiency scale, ranging from A (high
energy efficiency) to G (poor efficiency). Energy performance is based on the yearly
net final energy demand of the building per m² of floor area (kWh/m2.year). No
primary energy factors or CO2 factors are applied.

The energy label for new buildings is always based on calculated final energy
consumption. The scale in the energy certificate is an absolute value
(kWh/m2.year). There are ten different scales for ten different building types.

In small residential buildings, the calculated energy consumption includes space and
water heating, all electricity consumption and cooling energy. In large residential
buildings, household electricity is not included in the energy consumption. The
energy consumption of non-residential buildings includes heating (space and water),
cooling energy, HVAC-electricity and built-in lighting.

The calculation methodology is described in the building regulations. It must be

used for calculating energy consumption when issuing energy certificates for small
residential buildings. When applying for a building permit or issuing energy
certificates for other building types (new buildings), EN standards, other more
detailed calculation methods and simulation tools can also be used. The calculation

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methodology described in the regulations follows the main principles of EN ISO
13790.

Existing buildings are rated according to their actual metered final energy
consumption.

Recommendations are included only in "separate energy certificates" issued by

qualified experts, for existing buildings only. In the case of other certificate types
for existing buildings, recommendations are included in the energy audit report or
the property managers’ certificate.

A qualified expert must visit the building and assess the energy efficiency of its
structure and technical systems (outdoor walls, doors, windows, heating and
domestic hot water systems, ventilation systems, lighting and other electrical
heating systems). After the audit, the qualified expert must suggest cost-effective
energy-saving measures in the certificate. Because there are no general lists of
recommended energy-saving measures, these recommendations depend on the
expert’s skills and knowledge. Savings must be calculated in detail for every
building, reporting savings in kWh/year for each measure individually and for all of
the proposed measures combined.

Responsibility for ensuring possession of such a certificate lies with the building
owner. The cost of the certificate depends on the certificate type. The price of a
"separate certificate" for an existing building begins from 500 € for a whole
apartment building. If an energy certificate is based on an energy audit, the cost of
an audit can rise to 2,000 €.

An energy certificate for a single-family house building permit costs close to 120 €.
With several service providers issuing energy certificates, a certain “market price”
has been struck in the Finnish market.

Quality assurance (QA)

The quality control procedure is not regulated by legislation. However, the current
legislation does allow the Ministry of the Environment to gather relevant information
on certificates and certificate prices from qualified experts. Qualified experts must
keep a 15-year archive of any certificates they have issued. The local building
supervision authority must also keep an archive of certificates issued for new
buildings that have been issued with a building permit. The Ministry has the right to
access these archives in order to conduct periodic checks of the certificates, but no
control has been made so far.

A national, centralised database has been developed for energy certificates. This
system was ready by the end of 2009. In the current phase, the database collects
only statistical data on the number of certificates. The intention is for the database
to operate on a temporary basis for a few years, until a centralised, quality control
database is developed in connection with implementing the recast of the Energy
Performance of Buildings Directive.

3> Inspections - status of implementation

Finland chose option B (advice, voluntary inspections) instead of mandatory boiler

inspections for the implementation of Article 8. The Ministry of Trade and Industry
(now the Ministry of Employment and the Economy), the Ministry of the Environment
and the Finnish oil sector established a co-operation programme (the HÖYLÄ energy
efficiency agreement) in 1997, on furthering energy conservation in oil-heated
properties. Since the beginning of 2003, Government subsidies have also been

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 available for changing old heating systems in residential buildings by systems that
utilise renewable energy sources. These existing instruments formed the basis for
the voluntary approach.

The main objective of the voluntary approach is to promote energy efficient

installations and operations, mainly by providing information and advice. As part of
the implementation of the energy efficiency agreement, a magazine is distributed
to all of Finland’s 180,000 households with oil heating. The magazine informs end
users on how to enhance the energy efficiency of buildings and oil heating systems.
In addition, there are regular reviews of boilers and of solutions for their
ergiatodistus replacement. This magazine has been issued three or four times a year since 1985.

Figure 1. Information material for boiler owners

Figure 2. The Höylä-energy efficiency agreement; extensive savings in heating oil

have been achieved by refurbishing ageing oil-heated properties.
 B

Although boiler inspections are voluntary, a national inspection methodology was

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developed in 2004, before CEN-standards were available. Voluntary energy

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efficiency inspections of boilers have been conducted since early 2008. However, no
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major interest has been dexpressed in conducting energy efficiency inspections. The
intention is therefore to a include such inspections as part of ordinary, regular
servicing in the future. Ai total of 50,000 such audits, with costs in the range of 100 -
200 €, are carried out perl year, on average.
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According to the Act on the Inspection of Air-conditioning Systems, inspections are
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compulsory for cooling equipment
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with a nominal cooling output of at least 12 kW.
The national inspection methodology
 B

n was developed in 2004, before CEN-standards

were available. Inspections
B

a are only necessary where cooling systems are based on

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 the use of compressors, i.e., district cooling systems are not included in the
mandatory inspection scheme. Such equipment must be duly inspected at least once
a decade. The new act came into force on the 1st of January 2008.

A model report and guidelines exist on the content of inspection reports. The main
parts of the report are as follows:
› description of the air-conditioning system
› measurements and inspections used
Sticker of voluntary boiler › assessment of saving potential
inspection (to be attached › recommendations for improvement
to aergiatodistus
boiler). Until now, relatively few inspections of air-conditioning systems have been carried
out. The first ten-yearly inspections of systems deployed in 2000 will fall due in
2010. Older systems must be inspected by the 1st of January 2013.

The Act on Inspection of Energy Efficiency of Air-conditioning Systems’ Cooling

Equipment has been amended in the autumn of 2010 in order to reduce the interval
of periodic inspections from ten to five years. The amended act will come into force
in the beginning of March 2011.

Figure 3. Information material on A/C inspections

Inspections are paid for by the owner of the building. Property owners have shown
little interest in inspecting the energy efficiency of their air-conditioning systems.
Despite being informed of the inspections and the related benefits, not all building
owners are necessarily aware of the compulsory inspections in force. Some house
owners consider a separate energy efficiency inspection unnecessary if a
comprehensive air-conditioning system maintenance agreement has already been
made for their building. In practice, they are confident that servicing will prove
sufficient to ensure that the equipment functions as energy efficiently as possible.
They therefore see no need for a separate inspection report. At the moment, there
are no penalties for not having an inspection made.

 B

 B

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Qualified experts
B

 B

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Qualified Experts aini certification have the authority to issue so-called Separate
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Certificates. Such ilexperts must be architects, engineers or technicians with an
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educational background d in building, HVAC or electrical engineering. A professional
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examination can bey replaced by at least three years’ experience in energy efficiency
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within the buildinga sector.
l Furthermore, Qualified Experts must pass an exam
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arranged by an accreditation
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legislation and in the
n a certification system itself. Attendance of a training course is
not mandatory. ag m
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 Qualified Experts receive accreditation with a validity of 7 years. They can either
operate on an individual basis or be integrated with public or private organisations.
Two accreditation bodies have been authorised by the Ministry of the Environment
to approve qualified experts: FISE Oy and Kiinteistöalan Koulutuskeskus (Kiinko).
There are around 520 Qualified Experts in energy certification. If there is a
compelling reason for doing so, the accreditation of a Qualified Expert can be
withdrawn. Such reason may be for example reluctance to correct the false
certificate after several notes of complaint. At the moment, there are no other
penalties in use. So far, only two accreditations have been withdrawn.

Other professionals entitled to issue energy certificates (e.g. principal designers,

property managers, chairpersons of housing company boards and energy auditors) do
not require accreditation under the Act on Energy Certification of Buildings.

Training for experts engaged in voluntary boiler inspection was first arranged in
April 2007. Some 300 experts have so far been trained. The majority of them
comprise staff in oil heating installation and service businesses, and one third
concerns chimney sweepers. Experts can apply for voluntary certification once they
have completed the training. Approximately 130 of those trained have applied for,
and been granted, certification. Organisations in the industry (Heating energy
association/Lämmitysenergia Yhdistys and the Finnish Federation of Chimney-
Sweeps/Suomen Nuohousalan keskusliitto) have arranged training. They also
maintain a list of certified inspectors on their websites.

Professionals authorised to carry out the inspection of leakages of certain

fluorinated greenhouse gases from A/C systems, as referred to in Regulation (EC) No
842/2006 of the European Parliament and of the Council of 17 May 2006, can also
act as qualified experts in air-conditioning inspection. The Safety Technology
Authority (TUKES) accredits inspection companies and persons in charge of these
inspections, while also maintaining a register of the accredited companies and
persons. The Ministry of the Environment and the Finnish Refrigeration Enterprises
Association (FREA) have developed further training for those in charge of inspecting
www.nuohoojat.fi the energy efficiency of air-conditioning systems. This is intended to ensure that
www.lammitysenergia.fi inspections and reports are carried out to the appropriate extent. Training sessions
have been arranged in four key locations in 2009 and 2010. These cover an
estimated 80-90% of the key equipment base, at which inspections are being
targeted for the time being. A total of 82 participants have attended training.
Training sessions will continue as the need arises.

5> National information and communication campaigns

An information campaign was launched at the beginning of April 2008. The Ministry
of the Environment mandated Motiva to coordinate this campaign. The main
objective of the campaign is to inform the general public, professionals and other
interest groups of the energy certificate.

The campaign’s key information source is a web portal. It includes detailed

information on certification procedures and provides answers to frequently asked
questions. It also has links to lists of qualified experts and to official texts of the
Logo of the energy Ministry. The latter include, e.g., legislation, energy certificate templates and
certification info examples of the different types of certificate. These are available on the national
campaign. website of the Ministry of the Environment (www.ymparisto.fi).

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Campaign web portal:

www.motiva.fi/energiatodi
stus ergiatodistus

Figure 4. Web-portal

Motiva also maintains a helpdesk service centre, which can be contacted by

telephone, e-mail or through the web portal. This web service attracts an average
of 2,000 visitors per month. Both consumers and industry professionals seek advice
and answers to questions.

A "pocket" leaflet has been published to promote the campaign. This leaflet has
been distributed at major national housing fairs, seminars and other related events.

Figure 5. Leaflet of certification

Ministry representatives have visited regional events to inform municipal authorities

of practices related to energy performance certificates. Representatives of Motiva
and the Ministry have given presentations on energy certificates at a number of
events arranged in various parts of the country. Organisations and enterprises in the
industry have also arranged information and training events related to the
certificates.

Energy certificates have been prominently displayed every year at the Housing Fair.
In connection with the Housing Fair, and building fair events, seminars have been
 B

arranged informing consumers and building trade professionals of energy

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certificates. Once a year, the Ministry of the Environment and Motiva arrange a
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networking event for qualified experts in energy certification.

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d
A campaign has been implemented
 B

a involving the production of leaflets (in figures 1

and 5), news articles and
B

i press releases on energy certificates, voluntary boiler

inspections and air-conditioning
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l equipment inspections. The aim has been to

y awareness of certificates and inspections and the benefits
enhance property owners’
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they confer. (
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 Figure 6. Certificates on Housing Fair

6> National incentives and subsidies

The state supports residential buildings in making energy efficiency improvements,

low-CO2 investments and engaging in the use of renewables with respect to heating
systems, in four ways:
› subsidy for housing companies
› subsidy offsetting material costs for low income households
› tax deduction for households purchasing services
› subsidy for installing renewable energy sources
Since 2003, the State budget has been allocating subsidies to housing companies (10-
15%) for the repair of buildings and specifically targeted energy renovation. For
example, these include changing to more-energy-efficient windows, adding extra
insulation to walls or ceilings, and switching from old heating systems to district
heating, wood based boilers or ground-source heat pumps. The State also supports
the low-income households with an optional subsidy of 25% covering the material
costs of energy efficiency renovation.

The tax incentive for domestic employment of various service providers has been in
effect since 2001. A household may deduct 30% of personnel salary costs or 60% of
company-provided services (but not of materials) from personal taxation. This
deduction is applicable to acquisitions of labour (services) for household purposes.
Although the deduction can be applied to various works done within a household, in
information concerning the tax deduction, the households have been encouraged to
make improvements in the energy efficiency of their properties. At the moment, the
 B

annual maximum is 3,000 €/person.

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A subsidy scheme entailing

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support for up to 20% of costs when a residential building
introduces a groundd source heat and air-to-water heat pump as its main heating
system, or when it ashifts to pellet heating and other wood-based fuels, will be
introduced from thei 1st of January 2011. The intention is to grant support for
renovations of houses l with electric or oil heating, but not for new buildings or old
houses using district yheating.
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For the non-residential
a building stock, grants are provided for energy audits only.
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 7> Impact of the EPBD at national level

Development of minimum requirements in building regulations

In its National Building Code, Finland has set minimum requirements for the thermal
insulation and ventilation of new buildings since 1976. These requirements have
been changed several times, in order to improve energy efficiency in buildings.

Changes were made in 2003, when the level of the requirements was tightened by
25-30%, and in 2007, when the requirements were changed due to the
implementation of the EPBD. The latest tightening of the requirements (-30%) was
given on December 2008 and came into force at the beginning of 2010.

Thermal losses from buildings have traditionally been controlled by the regulatory
framework. The Minister of Housing has announced that, in 2012, Finland will
introduce a regulation based on overall energy consumption, which will take
account of the energy source (primary resource factor). Proposals for new energy
efficiency requirements have been developed and a public consultation took place
in October 2010. After this process is completed and the requirements are finalised,
they will enter into force at the beginning of 2012.

Reference values Year

for maximum heat loss 1976 1978 1985 2003 2007 2010
Wall, U-value (W/m²,K) 0.40 0.29 0.28 0.25 0.24 0.17
Roof, U-value (W/m²,K) 0.35 0.23 0.22 0.16 0.15 0.09
Floor, U-value (W/m²,K) 0.40 0.40 0.36 0.25 0.24 0.16
Window, U-value (W/m²,K) 2.1 2.1 2.1 1.4 1.4 1.0
Door, U-value (W/m²,K) 0.7 0.7 0.7 1.4 1.4 1.0
Air-tightness, n50 (1/h) 6 6 6 4 4 2
The yearly exhaust air heat
recovery efficiency 0% 0% 0% 30 % 30 % 50 %
Thermal transmittance (W/K) 1 2017 1905 1879 1367 1353 917
Change 1976 =100 0% -6 % -7 % -32 % -33 % -55 %
The EPDB-effect -1 % -33 %
1A typical 3-floor apartment house design in Finland

Other impacts

Since an energy certificate must be appended to a building permit application

submitted to municipal building inspection authorities, in essence, energy
certificates have been issued for all new buildings since early 2008.
 B

The Ministry of the Environment maintains a monitoring system for energy

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certificates and has compiled information on these certificates from municipal

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building supervision authorities.
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Statistics indicate that new detached houses have
significantly better energy
a efficiency than required by the building code. Over 50%
of all detached houses built
i in 2009 were in energy class A or B, while a house in
classes C or D would comply
l with the standards set in the building code.
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Other new buildings were not as energy-efficient as detached houses. Instead, they
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mainly complied with building
a
code standards: the vast majority fall into energy
class C or D. Although n construction complied with regulations in general,
development projects increasing
a the share of passive houses and nearly-zero energy
houses have become remarkably
g more common in recent years.
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 Figure 7. Energy class distribution for new single-family buildings, year 2009.

A survey of real estate sector professionals conducted in late 2009 revealed that the
majority of them regarded the energy certificate as a clear and easily
understandable tool for enhancing the energy efficiency of buildings. Moreover, the
price of an energy certificate was considered reasonable. Although energy
certificates had been compulsory for existing buildings for less than a year,
proposals for energy saving measures have been well implemented in practice
(Figure 8).
Fig. 8. Implementation of
suggested measures

8> Conclusions and future planning

Energy efficiency requirements for new buildings were strict in Finland, even before
the implementation of the EPBD, which has rendered them even stricter. The major
challenge for 2011 is to prepare operators in the sector for the change due in 2012,
through which the emphasis of the building code will shift to overall energy
consumption and the requirement to take account of the energy source.

The Ministry of the Environment has commenced the implementation of the recast
of the EPBD. This will require new legislation, as well as a large number of reports,
analyses and development projects. The further development of a building code
applicable to new buildings, and nearly zero-energy buildings, will be promoted as a
follow up to the building code reform now in progress.

The preparation of energy efficiency requirements for renovation has begun.

Identifying well-functioning solutions for different buildings and various renovation
projects will be challenging. Another major task lies in the development of energy
certificates and a more extensive monitoring system.

Summing up, developing the measures required for recasting the EPBD into cost-
efficient, attractive national procedures from the viewpoint of buildings’ end-users,
is challenging. In the future, more training and communication is required on new
issues, both for consumers and building and real estate sector professionals.

Finland has still to implement a few legal reforms to enhance the short-term
implementation of the former EPBD. Premises of public authorities providing public
services and with more than 1,000 m2 will be required to display energy certificates.
The Act on Inspection of Energy Efficiency of Air-conditioning Systems’ Cooling
 B

Equipment has been amended in order to reduce the interval between periodic
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inspections from ten to five years. These two new legal reforms have been approved
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by the Parliament and will take effect in the beginning of March 2011.
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This report is funded by the Community’s
Intelligent Energy Europe programme
under the contract IEE/CA/07/333

The sole responsibility for the content of this publication lies with the authors. It does not
necessarily reflect the official opinion of the EACI, the European Commission or other
European Institutions. Neither the EACI, nor the European Commission nor any other
European Institutions are responsible for any use that may be made of the information
contained herein. The content is given for information purposes only and does not legally
bind any of the parties involved.

© European Union, 2011

More details on the IEE Programme can be found at

www.ec.europa.eu/intelligentenergy

This report can be downloaded from

www.epbd-ca.eu and also from www.buildup.eu

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