In the context of the European Commission (EC) consultation on the Evaluation of Energy Labelling Directive and certain aspects of the Ecodesign Directive, Construction Products Europe would like to share the following concerns:

 

METHODOLOGY

 

The construction products industry is fully committed to the principles of sustainability and sustainable construction, both at product level and construction work level.

 

The calculation of the environmental performance of construction products’ as part of the overall performance of building works has been the subject of extensive standardisation work in CEN/TC350 as mandated(1) by the European Commission. The horizontal methodology is published in European standards including EN 15804(2) and EN 15978. We are now witnessing a rapidly growing number of Environmental Product Declarations (EPDs) developed according to EN 15804. These are now being made available to the market for all kinds of construction products.

 

Because of the specific properties of construction products, the CEN/TC350 assessment methodology was developed to meet the following conditions:

• The methodology takes into account the design and installation of the product/system.
• The assessment of the performance of construction products must be carried out at building level (based on the product’s environmental information). Indeed, the performance of a product will be determined by the characteristics of the construction works such as location, design, installation and use.
• A life-cycle thinking approach, which incorporates all relevant product environmental aspects from cradle to grave, that is encouraged in order to promote the improvement of overall performance of the built environment, thereby avoiding the so-called burden shifting.

CEN/TC 351(3) is developing methods for measuring the release of dangerous substances. The results of this work will be integrated into CEN/TC 350 standards once available.
The proposed Methodology for the Ecodesign of Energy-related Products (MEErP) is a cross-sectoral, business-to-consumer methodology which does not always take into account the above-listed fundamental specificities of construction products. The table in the Annex to this document compares the two methodologies and shows that CEN/TC350 already covers a large majority of the MEErP indicators.

 

Therefore, while Ecodesign aims to set minimum performance requirements for products to enter the EU, CEN/TC350 provides a methodology to assess the building and maximise its performance.

 

ECODESIGN & CPR

 

Further to these methodological considerations, Construction Products Europe would like to make the following points.

 

We are concerned about the possible creation of a secondary route to CE marking. Construction products fall under the Construction Products Regulation (CPR), which means that the procedure to grant CE marking is well established and requires the declaration of the so-called ‘essential characteristics’. Therefore, the implementation of both the CPR and Ecodesign on the same product could lead to two parallel routes to CE marking. This needs to be avoided so that the CE marking on construction products is not weakened and to avoid the illegal placement of products on the market.

 

The upcoming development of the declaration of essential characteristics under the Basic Requirement 3 ‘Hygiene, health and the environment’(4) and 7 ‘Sustainable use of natural resources’(5) of the CPR, is meant to provide the same environmental information as the Ecodesign Directive. To ensure policy coherence, we strongly recommend that the well-established CPD/CPR route be used to declare environmental performance parameters and set threshold levels according to the CPR article 3.3(6) unless there is clear evidence that Ecodesign route is required to improve the sustainability of the built environment. In the latter case, legislative processes must be consistent and coordinated.

 

EC UPCOMING REVIEW

 

Our industry believes that the EC should now focus on the implementation and uptake of the existing 2009/125/EC Ecodesign Directive in line with the conclusion of the CSES study on "Evaluation of the Ecodesign Directive”(7). Furthermore, we recommend ensuring the reliability of the system and acquiring experience rather than extending the scope of the products covered.

 

We consider it essential to have a single methodology to assess the environmental performance of construction products and construction works. Therefore, we believe that in our drive towards efficiency, the best approach shall be to use CEN/TC350 methodology to improve the building performance.

 

(1) Mandate M350: Development of horizontal standardised methods for the assessment of the integrated environmental performance of buildings.
(2) Sustainability of construction works - Environmental product declarations - Core rules for the product category of construction products.
(3) Construction products – Assessment of release of dangerous substances
(4) The construction works must be designed and built in such a way that they will, throughout their life cycle, not be a
threat to the hygiene or health and safety of workers, occupants or neighbours, nor have an exceedingly high impact,
over their entire life cycle, on the environmental quality or on the climate during their construction, use and
demolition, in particular as a result of any of the following:
(a) the giving-off of toxic gas;
(b) the emissions of dangerous substances, volatile organic compounds (VOC), greenhouse gases or dangerous particles into indoor or outdoor air;
(c) the emission of dangerous radiation;
(d) the release of dangerous substances into ground water, marine waters, surface waters or soil;
(e) the release of dangerous substances into drinking water or substances which have an otherwise negative impact on drinking water;
(f) faulty discharge of waste water, emission of flue gases or faulty disposal of solid or liquid waste;
(g) dampness in parts of the construction works or on surfaces within the construction works.
(5) The construction works must be designed, built and demolished in such a way that the use of natural resources is sustainable and in particular ensure the following:
(a) reuse or recyclability of the construction works, their materials and parts after demolition;
(b) durability of the construction works;
(c) use of environmentally compatible raw and secondary materials in the construction works
(6) Article 3.3 of the CPR indeed states: "[…]Where appropriate, the Commission shall also determine, by means of delegated acts in accordance with Article 60, the threshold levels for the performance in relation to the essential characteristics to be declared.”
(7) The Executive Summary of the study states that: "Improved transparency and coherence should be promoted in the interface between the Ecodesign Directive and other policy tools including WEEE, RoHS and the Construction Products Regulation. A practical guidance document should be developed that will clarify the respective areas of application of the different instruments and the possible synergies and overlaps and state in clear terms which policy tool should be given priority for addressing which areas.”