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JP Amended Building Energy Efficiency Act — Mandatory Energy Conservation Standard Compliance from April 2025

ENFORCEMENT TIMELINE

Fully effective April 1, 2025 (applies based on building confirmation application)

Enforcement: Fully effective April 1, 2025 (applies based on building confirmation application)

Overview

Under the amended Act on the Improvement of Energy Consumption Performance of Buildings (Building Energy Efficiency Act), from April 1, 2025, all newly constructed buildings, whether residential or non-residential and regardless of scale, are required to comply with energy conservation standards. The change was introduced to dramatically strengthen energy conservation measures in the building sector, in support of Japan's goal of carbon neutrality by 2050 and its 2030 greenhouse gas reduction target (a 46% cut from fiscal 2013 levels). Previously, the mandatory requirement applied only to buildings of a certain scale (300 square meters or more), but the amendment extends the obligation in principle to essentially all new buildings. Building owners must design new buildings to comply with the energy conservation standards, covering both primary energy consumption and building envelope performance, and must undergo an energy conservation compliance review as part of the building confirmation application process; a building that does not meet the standard cannot receive a building confirmation certificate and construction cannot begin.

Enforcement Timeline

April 2021: Mandatory compliance takes effect for non-residential buildings of 300 square meters or more.

June 2022: The amended Building Energy Efficiency Act is promulgated.

April 2024: A best-efforts obligation to display energy performance labeling begins for buildings being sold or leased.

April 1, 2025: Energy conservation standard compliance becomes mandatory in principle for all new non-residential and residential buildings.

2030 (planned): Energy conservation standards for new buildings are raised toward ZEB (net zero energy building) and ZEH (net zero energy house) levels.

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Business Impact

Design and construction costs for new construction or major renovation of factories, warehouses, laboratories, and office buildings rise, as high-efficiency air conditioning, lighting, and insulation become mandatory. The building confirmation process may also take longer, since the added energy conservation compliance review can extend the lead time needed before construction can begin, making careful schedule planning essential. Failure to comply carries the risk of being unable to start construction (denial of the building confirmation certificate), a corrective order for a non-compliant building, and penalties for violating such an order, including a fine of up to 3 million yen.