How NTT DATA navigates the European carbon regulation wave with whole-life LCA

NTT DATA’s Green Engineering practice in Spain operates inside a multinational technology group, delivering sustainability consulting that spans energy audits, carbon footprints, and certification services for buildings. Over the past four years, life cycle assessment (LCA) has moved from a niche competency to a core service line, driven by the convergence of European regulation, voluntary certification demand, and client ESG commitments.

The scale of the incoming mandatory requirement is significant. Under the 2024 recast of the Energy Performance of Buildings Directive (EPBD), whole-life carbon LCA becomes obligatory for all new buildings over 1,000 m² from 1 January 2028, and for all new construction regardless of size from 1 January 2030. Spain’s draft Código Técnico de la Edificación (CTE), published for public consultation in November 2025, goes further: it introduces a correction factor that penalizes assessments based on generic datasets, making product-specific Environmental Product Declarations (EPDs) a practical necessity for accurate, compliant reporting.

EU Taxonomy alignment adds a parallel track. Any project seeking access to Next Generation EU funds or presenting to institutional investors under the Taxonomy framework must demonstrate a life cycle Global Warming Potential assessment for buildings above 5,000 m² of floor area, alongside energy and climate risk documentation.

NTT DATA recognized early that this convergence of regulatory drivers would produce a high volume of LCA work across the industry, and that the ability to move quickly from data collection to credible output would be a competitive differentiator for its consulting practice.

NTT DATA structures its zero-emission building pathway around three sequential levers: reduction of embodied carbon emissions, reduction of operational carbon emissions, and compensation of unavoidable residual emissions.

On the embodied carbon side, the team’s analysis focuses on the structural frame, which carries disproportionate weight in whole-life assessments. Moving from conventional CEM I concrete to lower-carbon cement types (CEM II-B, CEM III), sourcing rebar from electric arc furnace producers with strong EPD performance, and introducing CLT or glulam (GLT) for above-grade structure can collectively reduce embodied carbon by 15–22% at no architectural change to the building.

Biogenic carbon stored in structural timber adds a further dimension to the analysis. Under EN 15978, biogenic carbon is sequestered in module A1–A3 and re-released at end of life in module C, meaning it does not contribute to a net reduction across the full life cycle under current accounting rules. However, the team tracks the biogenic carbon store (226 kg CO₂e/m³ GWP, 814 kg CO₂e/m³ biogenic storage for CLT) and monitors the evolving European policy debate — including the French RE2020 approach of applying a time-adjusted reduction factor — as a potential future multiplier for timber-based projects.

On the operational carbon side, the team conducts photovoltaic yield and payback analysis integrated with the LCA workflow. For a rooftop installation scaled from 50 kWp to the maximum feasible 200 kWp, total CO₂ savings over a 25-year service life increase fourfold, while the economic return per m² GFA roughly doubles. Leading certification schemes including LEED Zero, EDGE, and International Living Future Institute require clients to demonstrate on-site renewable energy generation rather than relying solely on green energy procurement contracts, making this calculation a standard deliverable.

The net zero carbon framing NTT DATA applies to client projects distinguishes between zero carbon (gross balance of zero, no offsets permitted, currently infeasible) and net zero carbon (minimized emissions plus verified compensation). Private sector schemes including LEED Zero, ILFI Living Building Challenge, and British Land’s internal targets operate on net zero carbon principles, with embodied carbon benchmarks in the 450–600 kg CO₂e/m² (A1–A5) range as current reference points for office and commercial buildings.

A consistent theme in NTT DATA’s practice is the use of LCA outputs as design recommendations rather than post-hoc compliance reports. The combination of Materials Compass and Carbon Designer 3D gives the team the speed to produce decision-stage analysis during project design development, when structural and material choices are still open.

The CTE’s data quality correction factor (fᶜ) reinforces this direction commercially: an assessment based on product-specific EPDs carries a factor of 1.00, while one using only generic Ministry datasets carries 1.25, and a fully generic dataset carries 1.50. The practical implication is that projects using verified EPD data will report materially lower declared emissions than identical projects assessed on generic data, creating a direct financial incentive for early-stage EPD-led analysis.

NTT DATA sees this as an accelerant for the broader market: as EPD coverage expands across concrete, steel, timber, and MEP products in Spain, the gap between best-in-class and average-case embodied carbon will become both more visible and more consequential for project economics.

The team selected One Click LCA for its breadth of supported standards, the depth of its materials database, and the speed with which it enables design-stage scenario analysis. Three capabilities are central to NTT DATA’s workflow.

Materials Compass allows the team to filter and compare verified EPD data by geography, material category, and carbon performance in real time. For embodied carbon reduction, this means being able to identify, at local, national, and European scale, which concrete mixes, steel rebar suppliers, or structural timber products will deliver the lowest global warming potential for a given project — and to show the provenance and transport distance of each option.

Carbon Designer 3D provides early-design structural scenario comparison. Starting from a baseline office building at 517 kg CO₂e/m² GFA (embodied carbon, modules A1–A5), the team can model the effect of substituting standard concrete for a low-carbon CEM III mix (approximately 12% reduction to 455 kg CO₂e/m²), adding recycled steel rebar from a high-performance Spanish supplier (15% reduction, 437 kg CO₂e/m²), and replacing the above-grade structure with cross-laminated timber (CLT) (22% reduction, 403 kg CO₂e/m²). These outputs give clients a decision-ready analysis at the stage when design choices are still open.

The Emissions and Removals module extends the scope to offsetting scenarios. For a 5,000 m² building generating an estimated 2,000 tonnes CO₂ in construction, the tool supports calculation of the forest-based sequestration required under MITECO’s current 20% ex-ante compensation rule — approximately 50 hectares of Pinus pinea at 35 years of growth, or roughly 10 hectares per 1,000 m² of built area if full compensation were permitted.

The team expects LCA volume to grow substantially ahead of the 2028 EPBD implementation deadline, with the CTE correction factor making EPD-based assessments the standard approach for any project seeking accurate compliance positioning.

The biogenic carbon accounting question remains an active area of monitoring. A policy shift toward time-adjusted carbon credits — along the lines of the French RE2020 model — would substantially change the economics of structural timber and accelerate the conversion of Spain’s paper pulp forestry sector toward construction-grade CLT and GLT production.

On compensation, NTT DATA anticipates growing client interest in domestic forest-based offsetting as MITECO develops its ex-ante availability framework. The team’s view is that at 50–150 €/tonne for domestic credits, compensation is already economically viable for clients with strong sustainability commitments, and that the combination of robust LCA data and credible offset quantification will become a standard component of project-level sustainability reporting.