The EU legislative framework for the sustainability
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Presentation for the Romanian products manufacturer association APMCR, at their seminar during the Romanian national building exhibition Construct'14 , April 2014.
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The EU legislative framework for the sustainability
- 1. The European legislative framework for the sustainability of construction products, buildings and civil engineering works Chris Hamans 1
- 2. the overlap between EU Legislation & initiatives in sustainability (sustainability of construction works) 2
- 3. Rules and Tools Regulations – Directives - Communications • CPR 305/2011 • Ecodesign Directive: 2009-125/EC • Ecolabel Regulation: 66/2010 • Energy labelling Directive: 2010-30 • Green Public Procurement (communication) • Waste Framework Directive • Communication Sustainable Building • Flagship resource efficiency • REACH • ...etc. Standards – Voluntary tools • Harmonised Product Standards – hEN = product standards – EADs (ETAs) • Standards – CEN/TC 350 – Sustainability Assessment Buildings-Products – CEN/TC351 – Measuring Dangerous Substances • PEF - Product Environmental Footprint • BREEAM, LEED, DGNB, HQE…… • ....etc. 3 ** Apply to all construction products * Today relevant for (some) construction products * * * * * * * * *
- 4. Sustainability: growing mushrooms Too many initiatives
- 5. Sustainability: missing coherence 5 CPR – BWR#7 EcoDesign for buildings Green-It DG ENVIRONMENT DG ENTERPRISE DG ENERGY DG SANCO
- 6. Construction products are intermediate products 6 • The end use product is the building (works) Product performance is defined in the building ? one layer-two layer ? climate indoor-outdoor ? type of building ? building life time ? application ? maintenance scenario ? end-of-life scenario ? ………
- 7. Rules and Tools Regulations – Directives - Communications • CPR 305/2011 • Ecodesign Directive: 2009-125/EC • Ecolabel Regulation: 66/2010 • Energy labelling Directive: 2010-30 • Green Public Procurement (communication) • Waste Framework Directive • Communication Sustainable Building • Flagship resource efficiency” • REACH • ...etc. Standards – Voluntary tools • Harmonised Product Standards – hEN – EADs • Standards – CEN/TC 350 – Sustainability Assessment Buildings-Products – CEN/TC351 – Measuring Dangerous Substances • PEF - Product Environmental Footprint • BREEAM, LEED, DGNB, HQE…… • ....etc. 7 The CPR is probably the most important Regulation for the construction sector: Its basic starting point is the building.
- 8. Product related initiatives 8 • Aim direct product comparison • Do not take into account the products role in the building • .......... *) there is/was an initiative for an ECOLABEL for BUILDINGS *
- 9. If only we could .... • Make all understand that – Sustainability it self cannot be a uniform performance over Europe – Sustainability has global, national, regional, .. and private policies – Construction products are not fast moving consumer goods • Have the DG’s cooperate and not compete on sustainability – Stop double initiatives, developing new methodologies and policies before results and experiences with the previous ones have been gained • Use the standards the EC has mandated: CEN TC350 standards 9
- 10. Rules and Tools Regulations – Directives - Communications • CPR 305/2011 • Ecodesign Directive: 2009-125/EC • Ecolabel Regulation: 66/2010 • Energy labelling Directive: 2010-30 • Green Public Procurement (communication) • Waste Framework Directive • Communication Sustainable Building • Flagship resource efficiency • REACH • ...etc. Standards – Voluntary tools • Harmonised Product Standards – hEN = product standards – EADs (ETAs) • Standards – CEN/TC 350 – Sustainability Assessment Buildings-Products – CEN/TC351 – Measuring Dangerous Substances • PEF - Product Environmental Footprint • BREEAM, LEED, DGNB, HQE…… • ....etc. 10
- 11. standards - rating tools - regulations 11
- 12. Delivering Sustainability how standardised methodologies, building rating tools and building regulations should be interlinked 12 DGNB
- 13. positioning standards and tools 13
- 14. Sustainability has • many dimensions • many aspects • aspects are all interlinked 14
- 15. 15 SOC ENV ECON BUILDING-WORKS • we want to quantify the sustainability of buildings or works • not: • we want to quantify the contribution of construction products to sustainability
- 16. 16 SOC ENV ECON CEN TC 350 standards BUILDING-WORKS
- 17. principles 17
- 18. ENV SOC ECON CEN TC350 Standards for works CEN TC350 Standards only quantify aspects and impacts 18 Sustainability No qualification, No benchmarks, No rating Sustainability is built on 3 Dimensions (equivalent to People , Planet, Profit)
- 19. CEN TC350 standardisation ENV SOC ECON Technical Design Funktional Design CPR 305/2011 EuroCodes CEN TC350 Standards for works CEN TC350 Standards only quantify aspects and impacts 19 Sustainability A prerequisite for sustainability are the 6 Basic Requirements for Construction Works • Without meeting the functional needs there is no sustainability • Without meeting the technical needs there is no sustainability
- 20. overview CEN TC350 standards 20
- 21. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework STATUS 03-2014 CEN TC350 Standards 21 a logical and practical structure of standards
- 22. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework 22 Framework level
- 23. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework 23 Building level Framework level
- 24. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework 24 Building level Product level Framework level
- 25. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework 25 Building level Product level Information flow Modular information: allowing the use of product data in all building assessments, aggregation and tracing back contributions
- 26. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework ENVIRONMENT 3 Dimensions assessed EN15978 EN15804 EN15942 TR15941 27 ENVIRON.
- 27. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework SOCIAL 3 Dimensions assessed EN16309 28
- 28. Environmental Performance Social Performance Economic Performance Technical Performance Functional Performance EN 15643-2 Framework for Environmental Performance EN 15643 - 3 Framework for Social Performance EN 15643 - 4 Framework for Economic Performance Technical Characteristics Functionality Building level EN15978 Assessment of Environmental Performance - Calculation Method - FprEN16309 Assessment of Social Performance - Calculation Method - FprEN16627 Assessment of Economic Performance - Calculation Method - EN15804 Environmental Product Declarations - core rules for the product category of construction products - (see Note below) (see Note below) EN 15942 Environmental Product Declarations - Communication format - Business to Business CEN/TR 15941 Environmental product declarations – Methodology for selection and use of generic data - Product level Note: At present, technical information related to some aspects of social and economic performance are included under the provisions of pr EN 15804 to form part of the EPD Concept level Integrated Building Performance Framework level EN 15643 - 1 Sustainability Assessment of Buildings - General Framework ECONOMIC 3 Dimensions assessed FprEN16627 29
- 29. standards, tools and regulations 30
- 30. BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 standardisation programs regulators clients 31 Product info - EPD Product assessment Building info – quantified ! Building assessment
- 31. BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 Other supporting standardsCEN TC350 standardisation programs regulators clients 32 Product info - EPD Product assessment hEN product standards What indicators will be Essential Product Characteristics to be included in Annex ZA ?
- 32. BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 Other supporting standardsCEN TC350 standardisation programs regulators clients 33 building assessment : DGNB BREEAM HQE ........ ........ etc.
- 33. BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 Other supporting standardsCEN TC350 standardisation programs regulators clients 34 QUANTIFICATION RATING
- 34. rating weighting BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 Other supporting standardsCEN TC350 ? standardisation programs regulators clients decide – select methodology benchmarking ? ? 35 1 setting performance requirements Another methodology ? 3 BUILDING: calculation aggregation – EN15978 EN16309 EN16627 PRODUCT: EN15804 weighting benchmarking rating 2 hEN product standards
- 35. rating weighting BUILDING: calculation aggregation – EN15978 EN16309 EN16627 CEN TC350 CEN TC350 PRODUCT: EN15804 Other supporting standardsCEN TC350 ? standardisation programs regulators clients decide – select methodology benchmarking ? ? 36 1 setting performance requirements Another methodology ? 3 BUILDING: calculation aggregation – EN15978 EN16309 EN16627 PRODUCT: EN15804 weighting benchmarking rating 2 NO development of new methods! There are well working systems operational based on CEN TC350 standards PEF
- 36. 37 My personal opinion: EcoDesign, Ecolabelling, Energy Labelling and Green Public Procurement will not work for construction products. but if ,... then by EN15978 (building) and EN15804 (product)
- 37. Consistent & Coherent 38 BWR 1 BWR 2 BWR 3 BWR 4 BWR 5 BWR 6 BWR 7 CPR Harmonised information hEN Product Standards CEN TC351 standards CEN TC350 Standards EN15804 EN15978
- 38. 39 Thank you ! Chris Hamans email: esc@hamans.com more info: www.hamans.com more presentations: www.slideshare.net/chrishamans-esc
Notes de l'éditeur
- Good afternoon, ladies and gentlemen! My name is Chris Hamans and I come from the Netherlands. I am working as an independent consultant after my retirement from the Rockwool International Group. I was working 30 years for Rockwool in several positions. The last 15 years I was responsible for Rockwool’s involvement and engagement in European regulations and standardisation on energy and sustainabilty related issues. I feel very pleased to share my view with you, on the present EU legislation and other related developments in sustainability
- To say it in a friendly way: there is some overlap in the abundant number of initiatives! This is not new! This was already the case 5 years ago and it just continues!
- There are many initiatives that have faced us already with Regulations and Directives and socalled Communications . And Regulations and Directives also need standards, parameters and methodologies. & (Click) Not all of the listed Regulation and Directives exclusively apply to construction products or to buildings. & (Click) In this list of rules that relate to sustainability, the most important and prominent certainly is the CPR, the Construction Product Regulation. Also The Waste Framework Directive and Reach relate to construction products and are linked to sustainability. All these (double crossed) pieces of legislation are already today applicable to construction products. & (Click) All the other European Commission initiatives are trying to make their own sustainability rules for construction products. Most of the initiatives now experience that construction products are much more complex to assess then the consumer products. Originally EcoDesign, Ecolabelling, Energylabelling, etc. are established for consumer products. At present windows are subject to a first pilot project to set EcoDesign criteria for them. & (Click) On the right side we have to measure sustainability performances. We know European product standards that provide us a “common language”: harmonised product standards en ETA’s. But they do not deal yet with the sustainability information of the product. This most probably will change in the very near future, as I will show you later on. For measuring sustainability performance meanwhile a whole set of sustainability standards is developed in CEN TC350, the European standardisation body. But then there is PEF, the Product Environmental Footprint. This is another , and new initiative of the European Commission to measure the environmental performance of whatever product (so including construction products). The aim: productcomparisson and selection. DG ENTERPRISE mandated in 2006 the CEN TC350 standards. DG ENVIRONMENT is now competing with a new methodology: PEF and did not want to exclude construction products. But then we also see that some Member States in their regulations and subsidy rules, apply or intend to apply, private building-rating tools like BREEAM, LEED, DGNB, etc. So there are many activities going on.....
- There are just too many initiatives! & Click Private and public initiatives. Non coherent initiatives. All at the end, having however a very good intention: improve the product or a building, in terms of environmental performance or in sustainability in general. But too many initiatives are not productive! It will delay improvements and progress, in stead of speeding it up!
- It is growing like mushrooms! & Click It is not coordinated and its overlapping. & Click And the worst thing is, the non-coordinated initiatives of many DG’s (Directorate General) in the European Commission: : without specific expertise of the construction sector they compete each other on sustainability. My personal view – my preference: let DG Enterprise deal with works-buildings and construction products. Because DG ENTERPRISE is best known with construction products and the construction sector.
- Construction products are intermediate products. Construction products are no end-use products, but intermediate products. The end-use product is the building, the road, the bridge, etc. & Click A refrigerator for instance is different: it is an end-use product. But what about a construction product? (most construction products) & Click It can be applied in different ways, have different functions, different exposures, maintenance, lifetime, etc. Its environmental contribution all depends on the role in the building, the specific situation and conditions.
- The CPR is probably the most important Regulation for the construction sector: And .... its basic starting point is the building. ( I have shown you this earlier this afternoon)
- What about the other listed initiatives then? Their aim is selecting and comparing PRODUCT performance on selected criteria. Not within an holistic analyses of the products role and contribution to the building. & Click There is one initiative that wants to give an ECOlabel, on the entire building. This could work under certain conditions. But whether someone is really interested in comparing building performance by means of Ecolabels in different countries and different situations ….? I doubt; what may be the real use of it?
- If only we could .... Make all understand that Sustainability it self cannot be a uniform performance over Europe Sustainability has global, national, regional, .. and private policies Construction products are not fast moving consumer goods If only we could .... Have the DG’s cooperate and not compete on sustainability Stop double initiatives, developing new methodologies and policies before results and experiences with the previous ones have been gained If only we could .... Use the standards the EC has mandated: CEN TC350 standards
- But what about the standards and tools? How do they relate or could they be related to the rules and regulations?
- No comment
- How are standards and regulations linked? What to do with building rating tools?
- It is important to know where to position standards and tools
- Sustainability has many dimensions, many aspects and most aspects are interlinked. It is like the pieces of an endless puzzle. All what we do has consequences and impacts, for instance to the environment: The CO2 – emissions of a building have a global impact and the trafic generated by the users of a big office building, have an impact on the transportation system. And the use of the office building perhaps generates an important impact on the economic business aspects of the nearby restaurants and other shops in the neighbourhood. We could set the boundaries of the office building that also includes the public transport system, the economic impacts on the district, etc.... but
- We want to quantify the sustainabilty of the building it self. Not its impact on the public transportation, the electricity supply, etc. For this we want to quantify the contribution of a construction product to this sustainability performance.
- It should be clear: an assessments according to the CEN TC350 system, is limitted to the sustainability assessment of the building and this requires specific data from the construction products and from the processes.
- Please follow me on some principles which justify the use of these data in a regulation like the CPR, the Construction Products Regulation
- Sustainability is based on three pillars: environmental, social en economic performance. This is a parallel to the well known People, Planet , Profit. The sustainability assessment quantifies impacts and aspects on the environmental, social and economic performance of buildings, using quantitative and qualitative indicators. This is a pure measurement of performance on defined criteria without value judgements: no qualifications, no benchmarking or rating.
- Basic for any building or construction is the functional design. without meeting the functional needs there is no sustainability ( if this meeting room is not suitable to hold meetings like this, then the room or even the building is or becomes useless. It is not sustainable then.) If then the technical design is not fulfilling the envisaged lifetime and collapses or if it burns down already within a few years, then building will not be sustainable! If the acoustics are so bad that a meeting becomes a discomfort or even a health risc, then it is not sustainable! So, without meeting the technical needs there is no sustainability. All functional and technical needs are covered by the 6 Basic Requirements for Construction Works, as defined in the CPR. We have Eurocodes for designing and measuring the performances related to the 6 Basic Work Requirements. It is here (on the blue line) where the sustainability assessment starts: We measure the environmental, social and economic impact of the functional and technical solutions of the building and of the use of the building over a chosen lifetime.
- What standards do we have for measuring this?
- There is a logical and practical structure of standards.
- We have standards on the Framework level: These standards define the principles and the relations between the different standards that follow.
- Then, most important, we have the standards that define the methodologies - the calculations – for measuring the BUILDING performances
- And as this requires data, that fit into that building calculation, there are a few standards that define the rules how to assess the product performance. On this level we produce also the EPD’s – the Environmental Product Declarations.
- The building defines the need for data. The data-flow goes bottum-up. The information, both on product and building level, is modular. This allows: the use of product data in all building assessments, The aggregation of the data of all products and processes and tracing back their contributions or if you want, their role or importance on the building performance.
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- I have shown before the 3 dimensions of sustainability: Environmental, Social and Economic aspects of sustainability. We have 3 sets of standards for it: Here you see the group of environmental standards. All standards are published. EN15978 is the standards for the environmental Building assessment. EN15804 for the product assessment and other supporting standards, like the use of databases and the communication.
- Then there is the social pillar with the standard EN16309 And ...
- The economic pillar with the standard that defines the methodology and conditions for the Life Cycle Costing, EN16627.
- And how is this all interlinked ?
- We have standards, programs (or tools) and we have a regulator (“the government or the public authority”) or a private client.( the building owner or the investor) We have European standards now, as explained, and with the product information we are able to aggregate all product information into a building performance. The system and the methodology allows to use the product information of a product assessed in Rumania and applied in a building in the Netherlands because we communicate now in a “common language”.
- Now the CPR comes in: Member States in the EU now have to agree what information (environmental product information) will be allowed to demand from a product so it can be applied in that Member State. This process of defing the so-called Essential Product Characteristics on environmental performance has started now! I assume it still will take some time before we all agree on the essential characteristics and a decission is made. But finally this will result in a mandate of the European Commission. The mandate orders to include a selected set of environmental indicators in the Annex ZA of a harmonised product standard. That is what started now for the Basic Works Requirement nr. 7 :”the sustainable use of natural resources”. So the CEN TC350 standards are needed for measuring the performances for the indicators that are defined in the product standards. At the end this also means that the environmental performance of the product is to be declared under the CE-marking and is to be listed in the Declaration of Performance (the DoP) for the product.
- And what are the building rating tools doing? Meanwhile tools like BREEAM, DGNB in Germany and HQE in France and many more, are implementing the CEN TC350 standards in their methodologies.
- A building rating tool always starts quantifying the (e.g. environmental-) performance of the building by aggregating all the data related to the products and processes. After the quantification the rating or benchmarking is carried out. The quantification will be based on the standard EN15978 and requires product data declared on the basis of EN15804.
- And then there is the client who orders a specific performance of the building. Or, like we know from the Netherlands already, the regulator has a requirement of performance for the building. A performance requirement (like the depletion of natural resources that are used, or the total amount of CO2 over the buildings lifetime – two performance indicators that are mandatory to declare to a building permission in the Netherlands) , then requires also the choice of a methodology. Germany, has specified for all its governmental buildings that EN15978 shall be used for the calculating the performance. The Netherlands have a specified a methodology that related very much to the BREEAM methodology. But Member States are free to assign a methodology for the assessment of their buildings. Not for the products, as this would create a barrier to trade for products. But is there really a need for a 3rd. type of methodology?
- Some Member States say: let us wait for the PEF methodology. &click the methodology applies other principles of measuring environmental performance and is noit suitable for aggregating the data into a building performance. PEF is intentionally made for product comparison. Something that does not work for construction products. &click My personal opinion therefore: No, we do not need another methodology. Use the data that we have now and use the methodologies that we have defined in the CEN TC350 standards.
- And do we then still have a need for Ecodesign, Ecolabelling and Energylabelling of construction products? It could be a commercial label for marketing purposes of your product that is interesting you. & click But apart from the fact that the European Commission, all their consultants and industry, are still puzzling how to get this working for construction products, I think it is a waste of money! That on it self is not sustainable!
- If, And only if, they may succeed to have a system for fair labelling etc, then please use the CEN TC 350 standards. So that it does not require another additional assessment and additional costs for the sector!
- Of course this subject “sustainability” has many more angles to regulations and standards, but please accept that the APMCR and I had to amke a selection. You find more and more detailed information on my website and on slideshare.net Thank you!