The Council of European Producers of Materials for Construction (CEPMC) has taken note of the European Commission proposal for the revision of the Public Procurement Directives (December 2011).

 

Following the European Parliament decision on 21 February to start Trilogue Negotiations about a first reading agreement with the Competitiveness Council, CEPMC would like to express its concerns about some of the specific proposals, which could have a bearing on the procurement of construction works.

 

CEPMC SUPPORTS:

 

sustainable assessment, including environmental and social aspects;

  • "direct payment" of subcontractors by the contracting authority;
  • measures aimed at facilitating SMEs access to finance and reducing administrative burden;
  • whole life-cycle considerations when deciding the best value for money offer; the most economically advantageous criteria (Article 66) and NOT "lowest cost principle";
  • naming the proposed subcontractors in the contract (Article 71).

Contracting authorities should not be allowed to refer to specific processes or stages of the production process (Recital 41), as this goes against the aim of considering the whole life-cycle.

 

CEPMC is in favour of harmonizing rules in Europe. In particular, references to labels, certificates, etc. should be avoided if they lead to excessive burdens for SMEs or barriers to trade.

 

USE OF LABELS VERSUS LIFE-CYCLE ASSESSMENT (ARTICLES 41 & 67)

 

Labels (ecolabels etc.) may only target end-products. An ecolabel for individual construction products cannot guarantee adequate performance of the construction work.
In the case of buildings, it is the design and the combinations of different products which are decisive. Therefore, the sustainability assessment of buildings should be based on the CEN standards covering the environmental, economic and social performance of buildings (CEN/TC 350).

 

In the case of works, whole life-cycle assessment at the construction work level should be used rather than labels being applied to intermediate construction products.
The construction products industry fully supports the use of sustainability criteria in the procurement of construction works; however, if the Commission proposal does not take into account already existing European schemes for buildings, this could lead to significant confusion in the market.

  • The CEN standards will include a method for the assessment of the economic performance of buildings (life-cycle costs). This method should be used for the procurement of buildings.
  • The social pillar of the sustainability assessment comprises indicators such as accessibility, adaptability, indoor air quality, resistance to climate change, acoustic performance etc. Again, an ecolabel for individual construction products could not guarantee adequate performance of the construction work.