HPE renovation : modification of the criteria for awarding the “Haute performance énergétique rénovation” label

By the decree of October 3rd, 2023, published in the Journal officiel of October 12th, the criteria for awarding the “Haute performance énergétique rénovation” (HPE Rénovation in French) label to existing residential buildings have been modified. This label is provided for in Article R171-7 of the French Construction and Housing Code, and its content and award conditions were previously set out in the decree of September 29th, 2009, which is to be repealed and replaced by the new decree as of 2024. The decree came into force on October 13th, 2023, but its provisions apply to label applications submitted on or after January 1st, 2024. You will find details of the decree below.

The HPE Rénovation label, which sets the minimum performance requirements for ambitious energy renovation projects consistent with climate objectives, is provided for in Article R171-7 of the French Construction and Housing Code. The criteria for awarding this label vary according to the type of building (residential or non-residential).

In accordance with the decree of September 29th, 2009, the label comprises the following levels:

For residential buildings:
The “bâtiment basse consommation rénovation, BBC rénovation 2009” level (low energy building – BBC Rénovation in French);
The “bâtiment basse consommation rénovation, HPE Rénovation 2009” level (low energy building – HPE Rénovation in French);

For non-residential buildings: a single “bâtiment basse consommation rénovation, BBC Rénovation 2009” level.

The main changes relating to residential buildings introduced by the decree of October 3rd, 2023, are:

The replacement of the “Th-C-E ex” calculation method by the 3CL method, which is the standard procedure used to assess the energy performance of homes as part of the energy performance diagnosis (commonly called DPE in French) under Article L173-1-1 of the French Construction and Housing Code (Article 1);

A change in the name of the BBC Rénovation level to “bâtiment basse consommation rénovation résidentiel, BBC rénovation résidentiel 2024”, which has been modified to meet DPE class B requirements, in particular (Article 2):
Compliance with DPE class B criteria, i.e. conventional energy consumption of less than 110 kWhep/m²/year and induced greenhouse gas emissions of less than 11 kg CO2eq/m²/year;

Requirements on the energy carriers of building heating systems (ban on the installation and operation of certain boilers);

Various requirements relating to the study of energy renovation work items, the installation of solar shading, ventilation, minimum performance conditions and the insulation of water and heating networks;

Definition of the method for calculating the average heat loss coefficient of the building used to assess compliance with the minimum performance criteria for the building envelope (Article 3).
The removal of the HPE Rénovation level in favour of the “bâtiment basse consommation énergétique, rénovation résidentiel – première étape, BBC rénovation 2024 – première étape” level, which is a high-performance renovation stage aiming to achieve the higher level (BBC Rénovation), and implies in particular (Article 2):
Meeting DPE class C requirements at minimum;Planning of renovation work, the first stage of which is specified;
Carrying out a leakage test;
Banning the installation of certain heating systems based on the greenhouse gas emissions of one or more of their components.

The conditions applicable to non-residential buildings remain unchanged, but the level is now titled “bâtiment basse consommation, rénovation tertiaire, BBC rénovation tertiaire” (Article 4).

The conditions for awarding the HPE Rénovation label remain unchanged. The decree now allows for the agreement awarding the label to be terminated by either party, subject to compliance with a minimum notice period of six months (Article 7).

The appendices are listed below:

Appendix 1: procedures for checking compliance with the label’s standards;
Appendix 2: contents of the label application form;
Appendix 3: contents of the annual report submitted every year to the minister in charge of construction.
The provisions of the decree of September 19th, 2009, which specified the content and criteria for awarding the label until then, shall apply until December 31st, 2023. This decree will be repealed as of January 1st, 2024 (Article 9 of the decree of October 3rd, 2023).”