The Europe 2020 Strategy aims to establish ‘a smart, sustainable and inclusive economy with high levels of employment, productivity and social cohesion’. The Roadmap to a Resource Efficient Europe COM(2011)571 outlines how we can transform Europe's economy into a sustainable one by 2050. Buildings and construction works are identified as key elements of these EU policies.

 

As part of this Roadmap, the EC announced its intention to present a Communication on ‘Sustainable Buildings’. To support the work of the European Commission, Construction Products Europe would like to share the following views that complement our response to the EC stakeholder’s consultation that ran from 16 July to 1 October 2013.

 

DEFINING SUSTAINABLE BUILDINGS

 

As we strive towards more sustainable buildings, the first essential step is to have a single, clear definition of what a sustainable building should be.

 

In its introduction to the consultation, the EC explains that:

 

‘Sustainable buildings will relate to the environmental aspect of sustainability. Other aspects, i.e. social and economic, will be taken into account when assessing the impacts of possible actions but the main objectives of the actions will focus on the reduction of the environmental impact of buildings.’

 

All definitions of sustainability rest on this idea of the three pillars. Therefore, we believe that it is absolutely essential that the EC takes into account all aspects of sustainability when attempting to define a sustainable building. More so, the methodology used should cover the whole life cycle of the building, from the production phase of the building materials to end of life, and including the use phase. We therefore urge the European Commission to incorporate the social and economic criteria to the scope of its work.

 

The calculation of the environmental performance of construction products as part of the overall building performance has been subject to extensive standardisation work in CEN/TC350, mandated by the European Commission in 2004 The standards under this framework provide clear guidance when dealing with calculation methods, indicators and reports. This framework should therefore be considered as the best existing source of information by public authorities, which can of course be adapted to new requirements.
Above all, Construction Products Europe considers it essential to have a single methodology to assess the environmental performance of construction products and construction works. The consultation suggests differentiating private from public buildings. Construction Products Europe believes that private and public buildings should adhere to the same methodology and set of indicators. These could be easily integrated into Green Public Procurement when it comes to public buildings.

 

The questionnaire seems to lack clarity when it comes to the differentiation between products and buildings. Our view is that assessment should be done at building level, and include all information coming from construction products.

 

Finally, we would like to underline that building performance varies with workmanship, design, and geographical characteristics.

 

EXISTING LEGISLATION

 

As a cyclical industry, the construction industry requires long-term investments and therefore long-term strategy and regulatory predictability. Resource efficiency is one of the pillars of the Europe 2020 strategy which is the EU's growth strategy for the coming decade. That is why many initiatives have been taken up by the EC on this matter.

 

Coherence between the Sustainable Buildings Communication and the following initiatives need to be ensured:

• The Construction Product Regulation (EU) 305/2011 which includes in its Annex I the Basic Requirement for Construction Work number seven on the sustainable use of natural resources;
• The Ecodesign Directive 2009/125/EC;
• The Ecolabel Regulation (EC) 66/2010;
• The EU Procurement Directives 2004/18/EC and 2004/17/EC (currently under revision) and in particular the part on Green Public Procurement;
• The Energy Performance of Buildings Directive 2010/31/EU;
• The Energy Efficiency Directive 2012/27/EU
• The Roadmap to a resource efficient Europe COM(2011) 571, which sees the construction sector as one of the three targets to reach a resource-efficient Europe in the long-term;
• The soil, water, and waste policies and their possible review;
• The Communication on "Building the Single Market for Green Products” COM/2013/0196;
• The EC 2020 Strategy to re-launch the competitiveness of the construction sector.

POLICY OPTIONS

 

For years now, the European construction products industry has committed itself to increasing the resource efficiency of its products and processes.

 

In our opinion, the setting up of a mandatory assessment scheme as suggested by the consultation would have a very limited impact. However, improving the existing tools together would be very beneficial in reaching sustainability goals in construction.

 

This could be done by enhancing harmonisation between the different methodologies, sources of data and requirements for the voluntary assessment of buildings. The CEN/TC 350 scheme could also be supported and promoted out of Europe, like in the case of Eurocodes.

 

We of course support one of the main objectives of this initiative that aims to raise awareness of and demand for better performing buildings. Improved Business to Consumers communication and simplification of the existing tools would help the final users to make the right decision.

 

When it comes to sustainable construction, another important topic is the creation of a market for secondary materials. More details can be found in our recently released position paper.

 

Construction Products Europe would be keen to support the EC in the implementation of these suggested measures and thereby continue its way towards more sustainable buildings.