Introduction

NBRPs are becoming the operational backbone of the revised Energy Performance of Buildings Directive (EPBD). They replace the former long-term renovation strategies and require Member States to set out how their residential and non-residential building stocks will become highly energy-efficient and decarbonised by 2050. The first draft plans were due by 31 December 2025, while the first final NBRPs are due by 31 December 2026. The European Commission’s first assessment, published in July 2026, covered 16 complete draft plans and confirmed a high level of ambition on energy consumption and operational greenhouse-gas reductions.

Yet renovation is not only an energy problem. Buildings are also long-lived material banks. Every deep renovation involves decisions about what to retain, repair, replace, dismantle, reuse and eventually recycle. These decisions influence embodied carbon, construction and demolition waste, demand for virgin materials and the future adaptability of buildings. Importantly, the EPBD itself recognises this wider perspective: its NBRP template includes policies on construction and demolition waste, whole-life-cycle greenhouse-gas emissions, circular economy objectives and modular or industrialised renovation solutions. The challenge is therefore not whether circularity belongs in renovation planning, but how to make it implementable. The Horizon Europe CRedIBlE project provides a useful test bed for this transition.

_{Figure 1. First implementation cycle of NBRPs. Source: author’s elaboration based on Directive (EU) 2024/1275 and European Commission NBRP guidance.}

From energy renovation to resource-efficient renovation

The traditional renovation logic begins with energy demand: improve the envelope, modernise technical systems, integrate renewables and reduce operational emissions. These remain essential priorities. However, a renovation programme pursued at scale can also generate substantial material flows. Windows, façades, insulation, heating and cooling equipment, photovoltaic systems, interior elements and structural components may all be replaced during a building’s lifetime. If those interventions are planned only around energy performance, opportunities to preserve existing value or recover components can be missed.

The revised EPBD creates a stronger basis for avoiding this narrow approach. Its recitals state that whole-life-cycle performance should be considered not only in new construction but also in renovation, and that reducing whole-life greenhouse-gas emissions requires resource efficiency and circularity. Annex II, which provides the common NBRP template, asks Member States to describe policies and measures for the prevention and high-quality treatment of construction and demolition waste, reduction of whole-life-cycle greenhouse-gas emissions, district approaches that may consider circularity and sufficiency, and the promotion of modular and industrialised solutions for renovation.

This is significant for implementation. Circularity does not need to be a separate strategy sitting beside the NBRP. It can be treated as a horizontal layer running through building-stock analysis, target setting, financing, procurement, digitalisation, skills, monitoring and local delivery.

A circular perspective also changes the sequence of decisions. Before specifying new products, renovation teams can first ask whether an existing element can remain in service, be repaired or upgraded; whether it can be relocated or reused; and only then whether recycling or replacement is necessary. At programme scale, this hierarchy can reduce unnecessary material turnover and make renovation investment more resilient to resource-price volatility. It also encourages authorities to view the existing building stock as a reservoir of components and materials whose value can be retained over successive renovation cycles.

Six practical ways to embed circularity in NBRPs

1. Enrich building-stock data with material intelligence. NBRPs already require a detailed overview of the national building stock. This can progressively be expanded from energy characteristics towards information on building age, typology, construction systems, likely material composition, refurbishment history and adaptability. At building level, Building Information Modelling (BIM), digital building logbooks and Digital Product Passports (DPPs) can improve traceability. At building portfolio or city level, these data can help identify future material supply, likely renovation needs and opportunities for component recovery.
2. Add circular indicators to the renovation roadmap. Energy renovation rates, primary energy use and operational emissions will remain central NBRP metrics. Complementary indicators can make resource performance visible: construction and demolition waste prevented, share of components reused, recycled-content uptake, embodied-carbon reductions, service-life extension, adaptability and the proportion of projects using pre-demolition or pre-renovation material audits. Not every indicator needs to become a binding national target immediately. A smaller, consistent set can first be used for monitoring and learning, then strengthened as data quality improves.
3. Make renovation pathways reversible and adaptable. A deep renovation should not unnecessarily lock a building into one use, one technical configuration or one material solution for decades. Renovation passports can support staged planning, and the EPBD framework explicitly foresees information on options for improving construction-product circularity and reducing whole-life-cycle emissions. NBRPs can build on this by promoting design for adaptability and disassembly, reversible connections, accessible technical systems and modular solutions that make future maintenance, replacement and reuse easier.
4. Use finance and procurement to create demand for circular solutions. The NBRP is not only a technical roadmap; it also identifies investment needs and financing sources. Grant programmes, preferential loans and public procurement can therefore reward more than energy savings. Circular criteria can include life-cycle assessment, retention of existing structures, reuse targets, design-for-disassembly provisions, requirements for material inventories and evidence that alternatives to demolition have been considered. Public buildings are especially important because procurement can create predictable demand for recovered materials and circular construction services.
5. Connect renovation policy to secondary-material markets. Reuse remains difficult when recovered components cannot be reliably identified, certified, priced and matched with future demand. NBRPs can help create the enabling conditions for regional reuse ecosystems by supporting common data structures, deconstruction planning, quality assurance, storage and logistics, and digital marketplaces. The objective should not be to maximise recycling at any cost, but to preserve the highest feasible value of products and materials while meeting safety, durability and performance requirements.
6. Treat skills and governance as infrastructure. Circular renovation requires architects, engineers, contractors, assessors, municipalities, waste operators, manufacturers and building owners to work across conventional sector boundaries. Training therefore needs to cover material assessment, life cycle thinking, selective deconstruction, reuse specifications, digital traceability and circular procurement. Local and regional authorities are equally important because renovation pipelines, permits, public assets, waste systems and local value chains converge at that level.

These six elements work best as a connected system. Material data have limited value if procurement rules do not permit reuse; ambitious reuse targets are difficult to deliver without quality assurance and storage; and digital passports cannot substitute for competent assessment on site. NBRPs can provide the coordinating framework by defining common terminology, minimum information requirements and responsibilities across ministries, municipalities and market actors. A phased approach is realistic: start with public buildings and larger renovations where information is easier to collect, test the methods, and then extend proportionate requirements to wider segments of the building stock.

_{Figure 2. A practical circularity layer for NBRP implementation. Source: author’s elaboration based on the EPBD NBRP template and CRedIBlE approach.}

CRedIBlE: testing the digital and physical links of circular renovation

CRedIBlE (Circular REDesign for a Resource-efficient, Innovative, and Transformative Built Environment) is a Horizon Europe Research and Innovation Action running from 2025 to 2029. The project is developing an interoperable digital ecosystem intended to support building design, renovation, adaptation, reuse and deconstruction. Its central idea is that circular renovation decisions become more actionable when energy, material, environmental, condition and market information can be connected rather than managed in separate tools.

The project combines BIM and life-cycle assessment (LCA) with digital twins, artificial intelligence (AI)-supported decision tools and DPPs. It also develops modular and disassemblable building solutions and a marketplace for secondary building materials and components. This combination is relevant to NBRPs because it links the policy objectives of resource efficiency and waste prevention with practical questions faced by renovation professionals: What can be retained? Which components are technically reusable? What is the embodied-carbon consequence of different renovation scenarios? Where can recovered materials be used? How can their condition and provenance be documented?

CRedIBlE is designed to validate these approaches through demonstrators across different building types, climatic conditions and regulatory contexts in several European countries. The project proposal includes both residential and non-residential renovation settings and combines technical validation with stakeholder engagement, policy recommendations and capacity building. Because the project is ongoing, these activities should be understood as research and demonstration objectives rather than completed results. Their value for NBRPs lies in generating evidence on which digital workflows, circular design principles and market mechanisms are sufficiently robust to be scaled.

The project also highlights an important implementation issue: circularity is place-based. A component that is technically reusable still needs local demand, an acceptable route for certification and transport and an actor willing to take responsibility for it. For that reason, the CRedIBlE methodology connects building-level information with local and regional value chains. This is directly relevant to NBRPs, which are national plans but must ultimately be delivered through regional renovation programmes, municipal assets, local construction markets and networks of small and medium-sized enterprises.

_{Figure 3. Simplified CRedIBlE methodological approach. Source: author’s adaptation of the CRedIBlE project proposal.}

Turning project innovation into NBRP implementation

For national authorities, the key question is how innovation can move from pilots into a repeatable policy architecture. A useful approach is to connect each stage of the NBRP to a specific circularity function. Building-stock analysis can identify material and adaptability characteristics. Roadmaps can introduce measurable whole-life and reuse indicators. Renovation programmes can require LCA and material inventories for selected project categories. Financial instruments can reward high-value retention and reuse. Public procurement can create early markets. Digital traceability can support monitoring, while demonstrators can provide the evidence needed to refine standards and technical guidance.

The CRedIBlE approach illustrates this chain. BIM-LCA integration can support scenario comparison; DPPs can structure information on products and components; digital twins can maintain information about condition and performance; AI-supported decision tools can explore renovation, reuse and deconstruction options, and a secondary-material marketplace can connect material availability with demand. The value is not the individual technologies in isolation, but the interoperability between them and their connection to policy and market decisions.

Renovation passports can provide a practical bridge between national policy and individual buildings. They can sequence measures over time and, where relevant, record information on product circularity, whole-life greenhouse-gas implications and future intervention points. If these building-level records use compatible data structures, aggregated information can also improve programme monitoring: authorities can learn which measures preserve the most value, which components are commonly recoverable, where secondary-material demand is emerging and where regulatory or insurance barriers persist. The objective is not to create a perfect digital record of every building immediately, but to make each major renovation improve the information base for the next decision.

There is also an important safeguard. Circularity should complement, not dilute, the core objectives of energy performance, safety, indoor environmental quality and affordability. Reuse is not automatically the lowest-carbon or most cost-effective option in every case, and retaining a component with poor performance may be counterproductive. Conversely, replacing functioning elements simply because a new product performs better can create avoidable embodied impacts. NBRPs therefore need transparent life-cycle decision rules that consider operational savings, embodied carbon, durability, technical performance, costs and future adaptability together.

_{Table 1. Translating circularity objectives into NBRP delivery mechanisms. Source: author’s elaboration.}

The opportunity of the 2026 final plans

The timing is particularly relevant. Member States are now moving from draft to final NBRPs, and the Commission’s 2026 assessment gives them an opportunity to strengthen the clarity, completeness and delivery mechanisms of their plans. Circular renovation can be made more concrete during this phase without changing the energy-led purpose of the EPBD. The legal template already provides entry points; what is needed is operational detail.

A practical starting package could include a small set of national circular-renovation indicators; material inventories for major public renovations; LCA requirements for selected funding schemes; guidance for design for adaptability and disassembly; support for reuse logistics and secondary-material platforms; and targeted training for public authorities and professionals. These measures can then be linked to the NBRP monitoring cycle and progressively expanded as reliable data become available.

Proportionality will be essential. Small residential renovations should not carry the same documentation burden as a major public-building transformation. Member States can differentiate requirements by project size, building type, funding level or expected material flow, while retaining a common set of principles. This can keep transaction costs reasonable and still build comparable evidence. It can also allow circularity criteria to mature alongside national whole-life-carbon methodologies, product data and renovation-passport schemes rather than being imposed before the supporting infrastructure is ready.

If implemented in this way, NBRPs can become more than schedules for reducing kilowatt-hours. They can guide a managed transformation of Europe’s existing building stock in which energy, carbon, materials and long-term value are addressed together.

Conclusions

NBRPs provide a rare opportunity to connect energy renovation with the circular use of Europe’s building resources. The revised EPBD already places construction and demolition waste, whole-life greenhouse-gas emissions, circular economy objectives and adaptable renovation solutions within the NBRP framework. The next step is to translate these provisions into measurable indicators, financing criteria, procurement rules, digital workflows and skills. CRedIBlE is exploring how BIM, LCA, digital twins, DPPs, AI-supported decision tools, modular systems and secondary-material markets can support that translation. Circularity should not become an additional reporting burden; it should make renovation decisions more resource-efficient, traceable and durable.

_{Cover image source: OathOn / Wikimedia Commons, CC0}