RE2020: Thermal design offices fed up with on-the-ground problems

Following our Article dedicated to the changes to the RE2020 regulations applicable since March 1, 2026This new regulation, which marks a further tightening of carbon requirements and an adaptation of practices for professionals, has prompted several stakeholders to react. Among them, thermal engineering firms are raising concerns about the practical difficulties of implementation and the problems observed.

"We take things seriously... without being valued."

This is the cry for help from a manager of a thermal design office (BET) certified OPQIBI 1331 1332 1905 1911, whose activity is centered on RE2020 and LCAs.

While acknowledging the relevance of regulatory changes, she points to a growing gap between theoretical requirements and the reality on the ground:

"We have been working to implement these changes from the beginning. But the system is not helping us."

At the heart of the problem: educating individuals, which is often difficult.

"The carbon footprint is perceived as an additional constraint. We spend a lot of time explaining it to our clients."

The controls were deemed insufficient.

The testimony calls into question the role of certain key players in the process: diagnosticians, RE2020 controllers and leak testing operators.

According to this professional, these actors do not systematically verify the completion of the LCA beforehand:

"They don't ensure that a carbon footprint assessment is carried out before starting work. Clients are only informed when the project completion certificate is issued."

The result: emergency situations where design offices must intervene within very short timeframes to regularize the files.

She also calls for increased accountability from certification bodies:

"LCA control should be rigorous and systematic."

A problem shared by other engineering firms

Another research firm, based in the Auvergne-Rhône-Alpes region, confirms these trends:

"We see very theoretical LCAs, sometimes copied and pasted from one project to another. This completely discredits the approach."

According to him, the lack of harmonization of practices creates unfair competition:

"Those who take the time to conduct a proper study are penalized compared to those who industrialize."

A diagnostician's perspective: "The framework remains unclear."

On the side of real estate diagnosticians, the situation is more nuanced.

One of them, however, acknowledges a lack of clarity regarding responsibilities:

"We are being asked to do more and more, but the framework is not always clear on who should be checking what."

He also highlights the pressure on deadlines:

"At the end of construction projects, everyone is in a rush. We're doing our best, but it's not ideal."

Project owners sometimes lost

On the private side, the complexity of the RE2020 is also highlighted.

A homeowner who recently built his house shares his experience:

"We discover the obligations as we go along. I didn't even know what ACV was at first."

He regrets the lack of overall support:

"Each speaker talks about their own topic, but no one provides an overall perspective."

Competition deemed unfair

The sector is facing increasing economic pressure, linked to several factors:

• the arrival of real estate diagnosticians on missions historically reserved for engineering firms (audits, studies),
• the increasing complexity of new projects, which hinders them
• and especially the rise of very low-cost online offers.

"We can't compete with studies costing €200."

Direct consequence: a significant drop in activity.

"We have lost 40% of our revenue, both in new construction and renovation."

Certification bodies called upon to respond

A representative from a certification body, questioned about these criticisms, acknowledged room for improvement:

"The implementation of the RE2020 regulation is still recent. Adjustments are necessary to ensure consistency in practices."

However, he insists on collective responsibility:

"Quality also depends on the rigor of each actor in the chain."

A profession at a turning point

For many engineering firms, the issue goes beyond simple regulatory adaptation.

"If nothing changes, the most reputable organizations will disappear."

Between increased requirements, lack of harmonized control and pressure on prices, the industry must find a balance to preserve the quality of studies while remaining economically viable.

A challenge for the entire industry

This debate highlights a central question: how to guarantee the credibility of RE2020 on the ground?

Harmonization of practices, clarification of roles, strengthening of controls…
These are all levers identified to prevent environmental performance from becoming a mere administrative formality.

Illustrative image of the article via Depositphotos.com.