Published: 29 March 2023

On the road to implementation of the Ladder in Belgium

Jonathan De Clerck



The CO2 Performance Ladder was developed in the Netherlands by ProRail as a way to stimulate action from the market on carbon reduction. For the first decade of its existence, the CO2PL remained a Dutch instrument, focused on the Dutch market, despite international interest from early on, including across the border in Belgium. As a result of that interest, the CO2 Performance Ladder was piloted in 24 construction projects in Belgium, in the period 2019 – 2023. The results of this pilot phase were positive, and are available here. Governments and companies in Belgium are enthusiastic about the instrument and have the ambition to move forward with it.

Of course, the first pilot of the CO2 Performance Ladder didn’t happen overnight! Before the Ladder could be implemented in a new context for the first time, many stakeholders worked hard to make it possible and create the best conditions for the experiment. This included market parties, – who provided the push to get started – and regional governments – who co-financed the pilot, alongside experts and certifying bodies. This timeline illustrates how the CO2 Performance Ladder was piloted in Belgium, sharing the insights gained and lessons learned in the process. Together with IISD’s feasibility study, the pilot in Belgium demonstrates the widespread applicability of the CO2 Performance Ladder, and helps future users to streamline their implementation of the Ladder.

“the pilot in Belgium demonstrates the widespread applicability of the CO2 Performance Ladder”

Structural implementation in Belgium

Structural implementation in public tenders is currently being discussed by multiple major public authorities in Belgium. The Flemish department for Mobility and Public works (MOW) has announced that they will use the CO2 Performance Ladder in all their public tenders with a value above € 5 million starting from 2025, and progressively lowering the threshold annually after . The Public Waste Agency of Flanders (OVAM) continues using the CO2 Performance ladder in its tenders for remediation works, and several other public authorities are interested in applying the CO2 Performance Ladder consistently, including Port of Antwerp-Bruges and the Walloon water agency (SWDE).

As part of the structural implementation, the independent organization BENOR has taken over the coordination of the CO2 Performance Ladder in Belgium, and will expand its use in Belgium. BENOR will be responsible for helping companies and governments navigate the certification system, providing practical advice and expert guidance, in collaboration with the owner and manager of the tool, the Foundation for Climate-friendly Procurement and Business (SKAO).

Pilot phase in Belgium

After the co-creative process, it was of course a matter of actually getting started with the CO2 Performance Ladder in Belgium. Implementing a new system in its entirety from the very start is naturally quite a challenge, so in Belgium it was decided to start with a pilot phase. During this pilot phase, the aim was to concretely implement the Ladder in a number of projects.

Specifically, pilot projects were sought spread across the three Belgian regions: Flanders, Wallonia and Brussels. The aim was to launch a total of about 25 projects using the CO2 Performance Ladder: 10 in Flanders, 10 in Wallonia and 5 in Brussels. The pilot phase was coordinated by CO2logic and followed up quarterly in a Steering Committee that included key stakeholders involved since the very beginning of the CO2PL in Belgium (including the Flemish & Walloon administrations, SKAO & ADEB-VBA among others). A final evaluation was produced at the end of the pilot phase, showing the positive findings from both procurers and companies after using the CO2 Performance Ladder in Belgium.

Guiding principles Belgium

Based on the development process, guiding principles were drawn up for implementation in Belgium:

  • In line with the Dutch model: certificate valid in Belgium and the Netherlands;
  • In line with the Greenhouse Gas Protocol;
  • Administrative burden for governments must be as low as possible through external certification;
  • Must ensure real CO2 reduction;
  • Only for works above EU threshold amount (€5.5 million). Focus on larger projects to avoid (potential) negative impact on small companies;
  • Subcontractors not included, for joint ventures the lowest level of the Ladder certificate applies;
  • Advantage only given up to level 3 of the CO2 Performance Ladder, to be achieved within one year. This was to avoid granting a competitive advantage to Dutch companies already at higher levels (4 or 5).
  • Award advantage by means of a fictitious discount (% or lump sum) or via a points system;
  • If the ambition level is not met, a sanction higher than the fictitious discount follows;
  • BELAC is responsible for the accreditation of certifying bodies in Belgium.

Co-creative implementation process of the Ladder in Belgium

Interest in implementing the Ladder was of course only the beginning. Therefore, after the positive stakeholder analysis, a co-creative process was started with the main stakeholders: governments, public institutions, SKAO, certifying institutions and the construction sector. This led to answers to questions which emerged from the stakeholder analysis and concrete proposals for implementation and coordination of the Ladder in Belgium. The Belgian authorities and the sector organisation ADEB-VBA funded this trajectory, based on their interest in implementing the CO2 Performance Ladder in Belgium.

The trajectory mainly consisted of thinking about specific questions from Belgian stakeholders in working groups. Thus, working groups were organised to reflect on:

  • The organisational aspect; how could the Ladder be managed and implemented in Belgium?
  • The legal aspect: can the Ladder system be adopted in its entirety from the Netherlands, or might some adjustments be needed? Does it comply with Belgian legislation?
  • The technical aspect: is the Ladder’s system applicable in the Belgian context or are adjustments needed?

Stakeholder analysis

Knowledge sharing among Belgian contractors provided an important step in the implementation of the CO2 Performance Ladder in Belgium. To check whether the Belgian market was open to using the Ladder in Belgium, a stakeholder analysis was launched by ADEB-VBA. Its purpose was to find out whether the various stakeholders (companies, contracting authorities, sector organisations, etc.) in Belgium were interested in the Ladder. The construction sector in Belgium thus decided on its own to investigate the possible implementation of the Ladder in Belgium.

The results of this stakeholder analysis were positive! Important motivations for interested Belgian stakeholders were mainly the uniformity of the Ladder (one system), the simplicity for administrations and the now proven success in the Netherlands.

A one-to-one implementation of the Ladder in Belgium was of course difficult. Specific questions and concerns of Belgian stakeholders naturally had to be answered and resolved first. This was carried out in the next phase, considering implementation in Belgium.

Rising interest in the Ladder from Belgium

Over the years, the CO2 Performance Ladder was taken up by more and more organisations in the Netherlands, and sustainability became an increasingly important topic for both companies and the government. In Belgium, during this period, contracting authorities occasionally experimented with systems to evaluate CO2 emissions in large projects. In addition, a number of large Belgian construction companies decided to certify for the CO2 Performance Ladder because of their activities in the Netherlands.

These companies actively shared their experience on the operation and use of the CO2 Performance Ladder within ADEB-VBA, the Belgian sector organisation for large contractors. Based on those exchanges the demand came from the construction sector itself to start investigating a uniform system for sustainability. This demand from the sector itself helped to win over governments as well: the regions of Flanders, Wallonia and Brussels.

Following the Ladder in the Netherlands

In the early years of the development of the CO2 Performance Ladder in the Netherlands, these developments were closely followed in the Belgian market not only by companies that came into contact with the Ladder in Dutch projects, but also by government bodies interested in using the Ladder in their tenders. In those early years, it remained a case of ‘wait-and-see’ from the Belgian market. There was no concrete implementation yet, but Belgian stakeholders watched with interest as the CO2 Performance Ladder became the sustainability instrument of the Netherlands.

The CO2 Performance Ladder in your country?

Interested in reducing carbon emissions in your country with the CO2 Performance Ladder? Get in touch to find out how the Ladder can be used in your organisation as sustainable procurement tool and CO2 management system.

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