Label C obligation for offices: a guide for businesses
Direct answer
The Label C obligation requires that, since 1 January 2023, an office building in the Netherlands must have at least energy label C: a primary fossil energy use of no more than 225 kilowatt-hours per square metre per year, or a label letter C or better. If the building does not meet this, it may no longer be used as an office. The municipality and environmental agency enforce the rule.
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Label C obligation for offices: scattered information versus Energy Intelligence
Offices account for a substantial share of energy use in buildings. To reduce this, the Dutch government set a floor for the energy performance of offices. Since 1 January 2023 that floor is firm: an office below label C may no longer be used as an office. The rule matters to every owner or user of an office building, from a single office property to a landlord with a portfolio of buildings.
- The obligation applies to office buildings with a usable floor area of more than 100 square metres in which the office function covers more than half of the space.
- The competent authority is the municipality, province or environmental agency; with a label below C it can prohibit use of the building as an office.
- Exemptions apply to, among others, small offices, monuments, offices as a secondary function and temporary use of no more than two years.
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What does the Label C obligation involve?
The Label C obligation requires an office building to have at least energy label C. In figures this means a primary fossil energy use of no more than 225 kilowatt-hours per square metre per year, or an energy label with the letter C or better. The rule is set out in the Dutch Buildings (Living Environment) Decree, and previously in the Buildings Decree. It has applied since 1 January 2023. If an office does not comply, a use ban applies: the building may not be used as an office until the label is in order. The energy label is recorded in the national EP-online database, where you can look it up by address.
- At least energy label C, meaning no more than 225 kilowatt-hours of primary fossil energy use per square metre per year.
- The requirement has applied since 1 January 2023.
- A lower label triggers a ban on using the building as an office.
- Registered labels can be found by address on EP-online.
Who does it apply to and what are the exemptions?
The obligation applies to office buildings with a usable floor area of more than 100 square metres, in which the office function covers more than half of the total area. Several situations fall outside it. Small offices, where the office plus its secondary functions stay below 100 square metres, are exempt. Also exempt are offices that make up less than half of a larger, multifunctional building, so an office as a secondary function. Monuments under the Dutch Heritage Act or a provincial or municipal ordinance are likewise exempt, as are buildings used for no more than two years and buildings not intended to be heated or cooled.
- Offices larger than 100 square metres in which the office function covers more than half of the space.
- Exempt: small offices up to 100 square metres, including secondary functions.
- Exempt: an office as a secondary function, less than half of a larger building.
- Exempt: monuments, temporary use of no more than two years and unheated buildings.
What should you do as an owner or user?
Start by establishing the current label. Look up your property in EP-online; if there is no label or an outdated one, have a valid energy label drawn up by a certified energy adviser. If your property does not reach label C, map out which measures are needed, for example insulation, LED lighting or a more efficient installation, and carry these out until the label reaches C or higher. If you are unsure about your specific situation, the competent authority, usually the municipality or environmental agency, decides whether your property falls under the obligation or an exemption. A hardship clause also exists for cases in which the remaining measures have a payback period of more than ten years.
- Check your current label on EP-online and have a new label drawn up if needed.
- Engage a certified energy adviser for a valid label.
- With a lower label: carry out measures until the property reaches label C or better.
- Unsure whether an exemption applies? The competent authority provides clarity.
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