Why does BR18 have two separate CO₂ budgets?
BR18 divides the climate calculation for construction into two completely separate accounts. This is not accidental — it is a deliberate design choice to prevent low material emissions from compensating for an inefficient construction process, and vice versa.
The two budgets are:
- Budget 1 — Materials and operation: Covers modules A1-A3 (material production), B4 (replacement), B6 (operational energy), C3-C4 (waste treatment and disposal). The limit varies by building type.
- Budget 2 — Construction process: Covers modules A4 (transport) and A5 (construction site activities). The limit is a flat rate of 1.5 kg CO₂e/m²/year, the same for all building types.
The crucial principle: you cannot borrow between the two budgets. Surplus on materials cannot compensate for exceeding the construction process limit. The two accounts are completely isolated.
Limits for Budget 1 — materials and operation
Budget 1 covers the total climate footprint of materials from cradle to grave. The limit is differentiated by building type because different buildings have fundamentally different material needs.
| Building type | 2025 limit (kg CO₂e/m²/year) |
|---|---|
| Holiday homes and vacation properties under 150 m² | 4.0 |
| Single-family homes, row houses, holiday homes ≥150 m² | 6.7 |
| Apartments and commercial buildings (offices, retail, warehouses) | 7.5 |
| Institutions (schools, daycare, etc.) and other buildings | 8.0 |
Limits tighten further in 2027 and 2029. Modules included in Budget 1: A1-A3, B4, B6, C3-C4. Module D is reported separately.
Module D (potential benefits): In addition to the modules above, module D must be calculated and reported. Module D covers potential climate benefits from reuse, recycling, and energy recovery after the building's lifetime. Important: Module D must be included in the calculation (cf. §297), but does not count towards compliance with the limit value (cf. §298). It is reported separately as information — it cannot be used to "save" a budget that would otherwise be exceeded.
The limit for Budget 2 — construction process (A4+A5)
Budget 2 covers transport of materials to the construction site (A4) and all activities on the construction site itself (A5). Here the limit is the same for all building types:
| Year | Limit (kg CO₂e/m²/year) | Class |
|---|---|---|
| 2025 | 1.5 | Standard |
| 2025 | 1.1 | Low-emission class |
| 2027 | 1.3 | Standard (expected tightening) |
| 2029 | 1.1 | Standard (expected tightening) |
The 1.5 kg limit was set based on analysis of construction site data from 2021. It is designed to force approximately half of construction sites to improve compared to the then-average. It is not an unrealistic ambition — but it requires deliberate effort.
The tightening to 1.3 (2027) and 1.1 (2029) means that what is today the "low-emission class" becomes the standard requirement within three years. Read more about the transition rules and effective dates.
What do the two separate budgets mean in practice?
For you as a builder, advisor, or documenter, the separation means concretely:
- Two separate calculations: You must perform two independent CO₂ calculations — one for materials (A1-A3 + B4 + B6 + C3-C4) and one for the construction process (A4+A5). They are not summed.
- Two separate data streams: Data for Budget 1 (EPDs, material quantities) and data for Budget 2 (invoices, fuel, waste) often come from different sources. In larger projects, however, it is typically the contractor who selects materials and can therefore also supply EPD data for Budget 1.
- No cross-compensation: A low material footprint (e.g. using timber) cannot save a construction process with high transport emissions. And conversely: an efficient construction site cannot compensate for emission-heavy materials. See the hidden CO₂ traps that can drive up the budget.
- Different actors: Budget 1 is typically managed by architects and material advisors. Budget 2 is managed by contractors and logistics managers. The two parties don't necessarily need to coordinate — but both must deliver.
The most common misunderstanding is that you have one combined CO₂ budget. You don't. And this mistake is most often discovered too late — at project completion, when it's too late to change anything.
Frequently asked questions
No. BR18 has deliberately separated the two budgets completely. Surplus on the materials budget (A1-A3, B4, B6, C3-C4) cannot compensate for exceeding the construction process budget (A4+A5), and vice versa. The two accounts are isolated.
The limit for A4+A5 is 1.5 kg CO₂e/m²/year from July 1, 2025. It is the same for all building types. The low-emission class has a limit of 1.1 kg. The standard requirement tightens to 1.3 kg in 2027 and 1.1 kg in 2029.
Because different building types have fundamentally different material needs. Offices typically require more steel and glass, while single-family homes can be built with lighter materials. The limits reflect this difference — e.g. 7.5 kg for offices and 6.7 kg for single-family homes.
Budget 1 includes A1-A3 (material manufacturing), B4 (replacement over the calculation period), B6 (operational energy), C3 (waste treatment), and C4 (disposal). Together they cover the material's full life cycle from cradle to grave.
The A4+A5 limit tightens from 1.5 to 1.3 kg CO₂e/m²/year in 2027, and further to 1.1 kg in 2029. This means the current low-emission class requirement (1.1 kg) becomes the standard requirement within three years.
You still do not comply with BR18 requirements. Both budgets must be met independently. The municipality can refuse the occupancy permit even if your materials budget has ample surplus. The two accounts are completely separate.
Ready to automate your BR18 documentation?
See how A45 can save you hours on every construction project with AI-powered invoice scanning and automatic climate calculations.
Related articles
BR18 A4-A5: The Complete Guide to Climate Requirements for the Construction Process
Everything you need to know about A4-A5 requirements in BR18 — limits, documentation, calculation methods, responsibility distribution, and practical workflow from planning to occupancy permit.
Who is responsible for A4-A5 documentation?
Public-law responsibility, contract types, and contractual provisions — a practical overview of who bears responsibility for A4-A5 climate documentation under BR18, AB 18, and ABT 18.
Practical guide to data collection on the construction site
Everything you need to collect for the A4-A5 calculation — from delivery notes and fuel receipts to weighing slips and electricity meter data. With checklist and subcontractor handling.
Hidden CO₂ traps on the construction site
Construction waste accounts for 38% of the A4+A5 budget — and mixed waste is penalized harshly. Overview of BR18 Table 11's 15 fractions, energy traps from drying and site huts, and concrete reduction strategies.
Transitional rules 2025: When do the new A4-A5 requirements apply?
The cutoff date is the building permit application date — not the approval date. The 1,000 m² requirement is abolished. Unheated buildings over 50 m² are now covered. Here is the full overview.