Position Paper
Basic Work Requirement 7 in the
Context of Existing Regulation
Position Paper
Basic Work Requirement 7
in the Context of Existing Regulation
By: Wouter Meindertsma MSc, Jeroen Scheepmaker MSc
Date: 27 September 2013
Version: 1.0
Project number: SPLNL13316
© Ecofys 2013 by order of: The Ministry of the Interior and Kingdom Relations (BZK)
ECOFYS Netherlands B.V. | Kanaalweg 15G | 3526 KL Utrecht| T +31 (0)30 662-3300 | F +31 (0)30 662-3301 | E [email protected] | I www.ecofys.com
Chamber of Commerce 30161191
ECOFYS Netherlands B.V. | Kanaalweg 15G | 3526 KL Utrecht| T +31 (0)30 662-3300 | F +31 (0)30 662-3301 | E [email protected] | I www.ecofys.com
Chamber of Commerce 30161191
Table of contents
1
2
3
4
Introduction
1
1.1
2
Reading guide
Explanation of CPR, BWR3 and BWR7
3
2.1
Construction Products Regulation (CPR)
3
2.2
BWR3 – Hygiene, Health and the Environment
4
2.3
BWR7 – Sustainable Use of Natural Resources
4
Interpretation of the BWR7
5
3.1
Sustainable use of natural resources
5
3.2
Reuse and recycling of the construction works
5
3.3
Durability of the construction works
5
3.4
Use of environmentally compatible raw and secondary materials
6
Influence of BWR3 on BWR7
7
4.1
Scope of BWR3 and BWR7
7
4.2
Lifecycle approach in BWR3 and BWR7
7
4.3
BWR3 definition of exceedingly high impact
8
5
EC Environmental Initiatives Overview
9
6
Overlap between EU Initiatives and the BWR7
12
7
Suggestions for Designing and Implementing the BWR7
16
7.1
Preliminary Scope BWR7 – sustainable use of natural resources
16
7.2
Determining the environmental impacts and indicators
17
7.2.1
Recommendation: use Life Cycle Approach EN 15804:2012
17
7.2.2
EU database
19
7.3
Defining the performance
19
7.4
Product declaration BWR7
20
7.4.1
Match with EU initiatives
21
7.4.2
BWR3 versus BWR7
21
7.5
Next steps
22
ECOFYS Netherlands B.V. | Kanaalweg 15G | 3526 KL Utrecht| T +31 (0)30 662-3300 | F +31 (0)30 662-3301 | E [email protected] | I www.ecofys.com
Chamber of Commerce 30161191
1
Introduction
The EU Construction Products Regulation - which entered into force on 1 July 2013 - set the
provisions for CE marking of building products. Not all CPR provisions are worked out yet. For
instance: Basic Work Requirement nr. 7 (BWR7), which has a direct relation with technical
specifications in the Eco-design Directive, for several products contributing to saving energy, has to
be further developed. The BWR7 states that a building should be designed, constructed and
demolished in such a way that natural resources are used sustainably. This includes making sure that
the building and the materials can be reused or recycled after the building is demolished.
Construction Products Regulation - 2013
The route to an EU-wide standardized methodology for setting up BWR7 ‘Sustainable use of natural
resources’ is in an early stage. Due to interest of DG Environment it is reasonable to think that DG
Enterprise and Industry will be initiating a route to a standardized methodology BWR 7 relatively
soon (after the evaluation of the communication on Sustainable Building). If so it is highly
recommended to have as much common terminology as possible as well as principles with existing
and comparable methodologies and (national) regulations. As an example we mention the Dutch
methodology for determining the environmental impact of buildings and infrastructure works
(Bepalingsmethode Milieuprestaties van gebouwen en GWW-werken). This methodology is based
upon product characteristics and is set up and adapted in the Building Decree 2012 (national building
regulations). From January 2013 it is obliged to deliver a calculation report of the environmental
impact of new constructed buildings (dwellings and office buildings).
In order to limit the workload for product manufacturers, it would be desirable to harmonize the
aspects under BWR7 with existing legislation, to preventing contradictions, ambiguities and
unnecessary administrative procedures. This position paper, which is initiated by the Dutch Ministry
of the Interior and Kingdom Relations (BZK) provides the scope for developing the BWR7 taking into
respect relevant EU and construction related instruments and programs. The purpose is to provide
input for the discussion about the route for developing and implementing the BWR7. Therefore it can
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be used as a subject for discussion within Thematic Group 3, Sustainable use of natural resources
and as input for the public consultation on Sustainable Buildings.
Ideally the outcome of the discussion will be a broad and first consensus among Member States,
associations DG Enterprise and Industry and Environment on how to develop and implement the
BWR7.
1.1 Reading guide
This reading guide gives an overview of the content of this position paper. It starts by giving a
concise explanation of the CPR, the BWR3 and the BWR7 in chapter 2. Chapter 3 provides information
on the interpretation of the BWR7. In chapter 4, information is provided on how the content of the
BWR3 influences the implementation of the BWR7. Chapter 5 describes EU initiatives related to
environmental performance of materials and chapter 6 explains what the overlap is between these EU
initiatives and the BWR7. The final chapter, chapter 7, provides suggestions for designing and
implementing the BWR7.
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2
Explanation of CPR, BWR3 and BWR7
2.1
Construction Products Regulation (CPR)
The purpose of the Construction Products Regulation (Regulation (EU) No 305/2011)1 is to ensure
reliable information on construction products and materials in relation to their performance, which is
used for marketing these products in the EU (European Economic Area). The CPR aims to facilitate
trade of construction products within the EU by offering uniform and transparent methods for the
performance assessment of construction products. This is achieved by providing a “common technical
language", which offers transparent and uniform assessment methods of the performance of
construction products. This facilitates trade, while at the same time granting Member States of the
EU space to specify their own requirements regarding construction safety, health and environment,
etc.
The common technical language is to be applied by:
•
The manufacturers when declaring the performance of their products through a Declaration of
Performance (DoP);
•
•
The national authorities of the Member States when specifying requirements for them;
Their users (architects, engineers, constructors) when choosing the products most suitable
for their intended use in construction works.
The Declaration of Performance (DoP) is the key concept in the Construction Products Regulation
(CPR). The DoP gives the manufacturer the opportunity to deliver the information about the essential
characteristics of his product he wants to place on the market.
The manufacturer shall draw up a Declaration of Performance when a product covered by a
harmonised standard (hEN) or a European Technical Assessment (ETA) is placed on the market. The
manufacturer, by drawing up his DoP, assumes the responsibility for the conformity of the
construction product with the declared performance.
On the basis of the information contained in the DoP, the user will decide to buy, amongst all the
products available on the market, the one which is fit for the use he intends to give to such a product
and he assumes the full responsibility of such a decision.
The DoP then constitutes the key element in the functioning of the Internal Market for construction
products by providing it with the necessary transparency and by establishing a clear system of
allocation of the responsibilities between actors.
1
REGULATION (EU) No 305/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:088:0005:0043:EN:PDF
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The minimum amount of information that the manufacturer is obliged to provide is set up in so called
BWRs. Currently, there are 6 of them. Number seven: ‘BWR 7 Sustainable use of natural resources’ is
added to this list.
1.
Mechanical resistance and stability;
2.
Safety in case of fire;
3.
Hygiene, health and the environment;
4.
Safety in use;
5.
Protection against noise;
6.
Energy economy and heat retention;
7.
Sustainable use of natural resources.
The following two paragraphs show the literal text of the BWR3 and the BWR7:
2.2
BWR3 – Hygiene, Health and the Environment
The construction works must be designed and built in such a way that they will, throughout their
lifecycle, 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 lifecycle, 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
e)
The release of dangerous substances into drinking water or substances which have an
f)
Faulty discharge of waste water, emission of flue gases or faulty disposal of solid or liquid
soil;
otherwise negative impact on drinking water;
waste;
g)
Dampness in parts of the construction works or on surfaces within the construction works.2
2.3
BWR7 – Sustainable Use of Natural Resources
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.3
2
Content of the CPR BWR3 – “Hygiene, health and the environment”. Excerpt from REGULATION (EU) No 305/2011, Annex I, March 2011.
3
Content of the CPR BWR7 – “Sustainable Use of Natural Resources”. Excerpt from REGULATION (EU) No 305/2011, Annex I, March 2011.
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3
Interpretation of the BWR7
For the interpretation of BWR7, the following statements and necessary clarifications should be kept
in mind:
3.1
•
Sustainable use of natural resources
The concept of natural resources should be clearly defined in order to determine which
resources should be considered in the BWR7 context. Do natural resources include all
resources extracted from earth, scarce resources or resources available in society, which can
also relate to the ‘resource’ land, for example?
•
The concept of sustainability within the context of sustainable use of natural resources should
be clearly defined.
3.2
Reuse and recycling of the construction works
•
Reuse and recycling should be clearly defined.
•
Reuse and recyclability are not goals in themselves, but a means for ensuring that the use of
natural resources is sustainable. As a consequence, sustainability aspects of the recycling
process (energy use, emissions etc.) shall be taken into account.
•
Taking the entire lifecycle into account during the design phase of a construction work, leads
to a more sustainable resource use. The type of materials and products selected in the design
phase influence the level of sustainability during the construction, use and the demolition of
the construction work as well as the possibilities for recycling and reuse of materials.
•
When considering recycling or reusing, the lasting of or the new functionality of a material or
product should be considered. Reuse and recycling should not result in a non-complying
performance of a product.
3.3
•
Durability of the construction works
Durability should be clearly defined.
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•
Durability has so far mainly been referred to in the light of the BWR1 (Mechanical resistance
and stability), i.e. to the technical performance of a product or material during the use phase.
In this perspective durability relates to the length of the service life of the product. High
durability, for instance, indicates a long lasting construction works. In certain cases it might
be more sustainable to design a construction in a light way with limited durability if it is
expected that options for innovations in a number of years may improve the sustainability of
the construction dramatically. The same holds if it is expected that the use of the
construction will change dramatically in a number of years.
•
However, as is the case with reuse and recycling, simply making a material or product more
durable does not inevitably lead to a more sustainable use of natural resource. Durability
should therefore not be a goal in itself. Implications of the use of a material during its full
lifecycle should be taken into account when considering the durability of a product or
construction work. It could be, for example, that the choice for a more durable material or
product leads to additional emissions during the demolition phase of the construction.
Reuse and recycling
3.4
•
Use of environmentally compatible raw and secondary materials
Environmentally compatible materials cannot be quantified or qualified with one indicator. It
should be clear that accepted indicators (preferably taken from the “basket” of 22 impact
indicators used in the CEN/TC 350 system) for expressing the environmental compatibility are
needed.
•
In order to assess the environmental performance of buildings or works, it is important to
have accurate and accessible information on the environmental performance of the
components, e.g. Environmental Product Information, which takes the entire lifecycle of
products into account.
Sustainability: people, planet and profit. People (social aspects) is not worked out, profit is
partly worked out (in aspects like: recyclability, durability)
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4
Influence of BWR3 on BWR7
Because BWR3 and BWR7 contain aspects which are quite similar in nature, it is important that BWR7
is defined keeping the content of BWR3 in mind. The purpose is to avoid overlap and ambiguity. This
chapter provides an interpretation of how BWR3 can influence the definition of BWR7 by focussing on
their similarities and differences.
4.1
•
Scope of BWR3 and BWR7
BWR3 and BWR7 both apply to construction works, including construction products and
materials used in construction works.
•
BWR3 and BWR7 both include environmental performance of construction works and
construction materials and products. But the environmental performance of BWR3 is mainly
focused on the reduction of dangerous emissions of substances/gasses to indoor air, soil,
water and outdoor air (greenhouse gasses). And BWR7 is focusing on reducing the depletion
of raw materials and natural resources.
•
BWR7 only covers the aspect of sustainability of works and has a “main focus” on efficient
use of resources, as is evident in its title. BWR3 takes health and safety into account and
considers environmental aspects such as emissions of greenhouse gasses, toxic gas, the
emissions of dangerous substances, etc.
•
An important link and potential overlap between BWR3 and BWR7 concerns the concepts of
reuse and recycling of the construction works, the materials or parts of the construction
works after the demolition. Reuse and recycling fit in the scope of BWR3 because it can
reduce the impact on environmental quality and climate change during the lifecycle of the
product and in the scope of BWR7 because it can improve the efficiency of natural resource
use.
4.2
Lifecycle approach in BWR3 and BWR7
Under the CPD, the predecessor of the CPR, BWRs were referred to as Essential Requirements or ER.
ER3, which was the equivalent of BWR3 in the CPR, focused on health and the environmental aspects
specifically during the use phase of a building. In the new CPR, however, BWR3 extends to the whole
lifecycle of a product or material. This has implications for the application of BWR3.
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The implications of this lifecycle approach for BWR3 are also relevant for BWR7, which also takes the
entire lifecycle of the product or material into account. In the design of BWR7, future lessons learned
and best practice from BWR3 with regards to the lifecycle approach should be taken into account.
4.3
BWR3 definition of exceedingly high impact
The definition of the term ‘exceedingly’ in the BWR3, currently phrased as “Exceedingly high impact,
on the environmental quality” can influence the design of the BWR7. ‘Exceedingly’ is a subjective
term that needs to be further defined in order to prevent ambiguity and should be linked to criteria
like:
•
•
•
•
Potential emissions;
Minimised and efficient use of natural resources;
Input and output of energy;
Secondary products from waste products.
Since the design of BWR7 should be made largely by trying to prevent any overlap and ambiguities
between the two BWRs above, the definition aspect should be taken into account.
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5
EC Environmental Initiatives Overview
The European Commission is the initiator of many policy studies, environmental roadmaps,
harmonisation programs and labelling systems aimed at improving the sustainability of Europe. Many
of these environmental initiatives appear to have overlap with the purpose of the BWR7: sustainable
use of natural resources.
The Ministry of the Interior and Kingdom Relations, Directorate-General Housing/Building sector
(BZK-WB) has, in cooperation with Ecofys, created an overview of these initiatives. The
environmental initiatives which are targeted at waste, recycling, sustainable use of natural resources
and life cycle assessments have been researched, because these are most likely to have overlap with
the BWR7. The next chapter will go into detail on how these initiatives can influence the design and
implementation of the BWR7.
The goal of this reflection is not to be complete and all-encompassing in its overview. It is rather
intended as a first look at relevant initiatives which might be of use for, or influence directly, the
development and implementation of BWR7. The EC Environmental Initiatives which warrant further
investigation are as follows:
•
The Ecodesign Directive - This directive provides EU-wide rules for improving the
environmental performance of energy related products (insulation, windows, shower heads)
through Ecodesign.
•
Sustainable consumption and production (SCP) - The objective is to provide a package of
measures to improve the environmental performance of products and to stimulate the
demand for more sustainable goods and production technologies.
•
The Product Environmental Footprint (PEF) - PEF is a multi-criteria measure of the
environmental performance of a good or service throughout its lifecycle.
•
Ecolabel – This label is a policy tool which is part of the Sustainable Consumption and
Production policy. The primary goal for establishing an Ecolabel for Office Buildings is
reducing their environmental impacts by increasing the performance of the building.
•
The Resource Efficiency Platform (the Roadmap to a Resource Efficient Europe) - The
roadmap aims to provide a framework for the transformation of the economy by promoting
the shift in consumption and production patterns towards a scheme where sustainable
management of environmental resources, greater reuse, recycling and substitution of
materials and resource savings are rewarded while stimulating the growth and
competitiveness of EU economy.
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•
The Waste Framework Directive - Proper implementation, application and enforcement of EU
waste legislation are among the key priorities of EU environmental policy.
•
Registration, Evaluation, Authorization and Restriction of Chemical (REACH) - The European
Community Regulation on chemicals and their safe use.
•
The 7th Environment Action Programme (7th EAP) - The EU's policy program for the
environment. There is a proposal for a new (7th) EU Environment Action Programme to 2020.
The Commission's proposal will be considered through the ordinary legislative procedure by
the European Parliament and the Council of the European Union. Once agreed, the new EAP
will become EU law.
•
ECO-Innovation Action Plan (EcoAP) - EcoAP is a comprehensive set of initiatives to improve
the market’s uptake of eco-innovation.
The initiatives mentioned above are shown in the image on the next page. The image shows whether
DG Enterprise and Industry or DG Environment is responsible for setting up and/or implementing the
initiative. Secondly, the image provides information on whether they are prescriptions or guidelines,
their implementation year, their fundaments, whether they are included in the building sector and/or
in other sectors, and where they overlap with the BWR 7.
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Figure 1: Overview of EC Initiatives with possible overlap with the BWR7. (NA = Not Applicable. Mainly the case
with EU roadmaps and action programmes.)
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6
Overlap between EU Initiatives and the BWR7
The following initiatives from the overview in chapter 5 do have in some particular matter (in)direct,
overlap with the BWR7:
1
Sustainability of construction works
CEN/TC 350 "Sustainability of construction works" is responsible for the development of
voluntary horizontal standardized methods for the assessment of the sustainability aspects of
new and existing construction works and for standards for the environmental product
declaration (EPDs) of construction products.
The existing standards provide the horizontal standardised methodology and indicators for the
sustainability assessment of buildings using a lifecycle approach in a transparent way. Last
year CEN/TC 350 finalised EN 15804 ‘Sustainability of construction works - Environmental
product declarations - Core rules for the product category of construction products’ as well as
EN 15978 “Sustainability of construction works — Assessment of environmental performance
of buildings — Calculation method“ which governs the scope and the requirements for the
application of EPD in Building Assessment.
Overlap:
2
+
Lifecycle approach (natural use resources, recycling included)
+
Purely construction related
+
Broad scope: Sustainability of construction works
Action Plan for sustainable consumption and production (SCP) and sustainable
industrial policy (SIP)
SCP and SIP are intended to create a package of measures and methods for reducing the
environmental impact of products and to stimulate the demand for sustainable goods. Two
environmental initiatives will be mentioned: the Ecolabel and the Ecodesign Directive.
2a
The Ecolabel
The Ecolabel will complement the information provided to consumers, as a voluntary label.
It will act as a "label of excellence" to signal to consumers those products that perform at
such a level when many environmental criteria are considered over the whole lifecycle. The
Ecolabel Regulation will be revised to simplify and streamline the process of obtaining an
Ecolabel, and extend the product coverage. The Ecolabel criteria will continue to cover a
broad range of environmental aspects. Furthermore, Ecolabel criteria may also be developed
to cover those products for which Ecodesign requirements have not yet been set. Indicatively,
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the Ecolabel criteria for a product group will be established so that 10% of products available
on the market at that time will meet them.4
Overlap:
2b
+
Whole lifecycle (natural use resources, recycling included)
+
Broad range of environmental aspects
-
Consumer based (B2C, BWR7 is B2B oriented)
The Ecodesign Directive
The Ecodesign Directive (part of Action Plan for sustainable consumption and production
(SCP) and sustainable industrial policy (SIP) contains regulation on the improvement of the
environmental performance of products. At the moment, several construction components
have been selected for further development (so called ERPs5).
Since the recast of the Ecodesign Directive in 2009, the EC has adopted the Europe 2020
flagship 'A Resource Efficient Europe’ and ‘the Roadmap to a Resource Efficient Europe’ to
define its objectives and means. The Roadmap calls for boosting the material resource
efficiency of products and set material efficiency requirements in the framework of the
Ecodesign Directive. In this respect, increased attention will be paid to the identification of
Ecodesign requirements on material resource efficiency in forthcoming preparatory product
studies and reviews, when these aspects are found to be significant, as foreseen in Annex I of
the Directive.6
Overlap:
3
+
Related to construction products, ERPs
+
Increased attention to material resource efficiency. Not developed or planned yet
Product Environmental Footprint
Product Environmental Footprint (PEF) is a Life Cycle Assessment (LCA) based method to
calculate the environmental performance of a product. It was developed by the European
Commission's Joint Research Centre based on existing, extensively tested and used methods.
The Commission promotes its voluntary application in policies and by private actors, including
companies.
In its conclusion on the "Sustainable Consumption and Production Action Plan", the European
Council invited the Commission to develop PEF together with OEF (Organisational
Environmental Footprint). The recent publication of the Resource Efficiency Roadmap has
further strengthened and defined the future role of the environmental footprint methodology.
4
Ecodesign Working Plan 2012-2014
5
Other energy related products (ERPs) which do not use energy but have an impact on energy and can therefore contribute to saving ener-
gy, such as windows, insulation material, shower heads, taps etc. [http://ec.europa.eu/enterprise/policies/sustainablebusiness/ecodesign/index_en.htm]
6
Ecodesign Working Plan 2012-2014
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Overlap:
+
Broad range of environmental aspects
+
Lifecycle approach (natural use resources, recycling included)
+
PEF and Sustainability of construction works: EN 15804:2012. Standard is often seen
as the sector approach of PEF7
4
Resource Efficiency Platform
The Roadmap to a Resource Efficient Europe outlines how we can transform Europe's
economy into a sustainable one by 2050. It proposes ways to increase resource productivity
and decouple economic growth from resource use and its environmental impact. It illustrates
how policies interrelate and build on each other. The Resource Efficiency Roadmap provides a
framework in which future actions can be designed and implemented coherently.
Overlap:
5
+
Same topic: resource efficiency
-
Framework/roadmap which means an abstract level
Waste Framework Directive
The Waste Framework Directive sets the basic concepts and definitions related to waste
management, such as definitions of waste, recycling and recovery. It explains when waste
ceases to be waste and becomes a secondary raw material (so called end-of-waste criteria),
and how to distinguish between waste and by-products.
The Directive introduces the "polluter pays principle" and the "extended producer
responsibility". It incorporates provisions on hazardous waste and waste oils, and includes
two new recycling and recovery targets to be achieved by 2020: 50% preparing for re-use
and recycling of certain waste materials from households and other origins similar to
households, and 70% preparing for re-use, recycling and other recovery of construction and
demolition waste. The Directive requires that Member States adopt waste management plans
and waste prevention programmes.
The Joint Research Centre (JRC) has issued a "Technical guide to Life Cycle Thinking (LCT)
and Life Cycle Assessment (LCA) for waste experts and LCA practitioners" aimed at
supporting environmentally sound decisions and complementing the waste hierarchy.8
Overlap:
+
Same topic: resource efficiency: resource recycling, re-use and recovering
+
Directive with recycling and recovery targets
+
Guidelines Lifecycle approach for waste management has been set up
7
CEN/TC 350 Seminar, Implementation of EN 15804, Building the Single Market for Green Products: PEF and construction products
8
http://ec.europa.eu/environment/waste/construction_demolition.htm
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6
7th EAP
The European Commission has proposed a new Environment Action Programme for the EU.
Entitled "Living well, within the limits of our planet", it will guide environment policy up to
2020. The proposed programme draws on a number of recent strategic initiatives in the field
of environment, including the Resource Efficiency Roadmap, the 2020 Biodiversity Strategy
and the Low Carbon Economy Roadmap.
Protecting natural capital, encouraging more resource efficiency and accelerating the
transition to the low-carbon economy are key features of the programme, which also seeks to
tackle environmental causes of disease.
Overlap:
+
Same topic: resource efficiency
-
Framework/roadmap which means an abstract level
The majority of the EU Initiatives have some form of overlap with the BWR7. The most important
overlap concerns taking the entire lifecycle into account when considering the
sustainability/environmental performance of a product and the focus on resource efficiency.
Performing an in-depth analysis of each of the individual EU Initiatives is beyond the scope of this
paper. However, the above list gives us a good indication of the nature of the overlap between the
BWR7 and these initiatives and provides a good starting point for the design and implementation of
the BWR7.
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7
Suggestions for Designing and Implementing
the BWR7
Chapter three describes the questions and remarks, that need to be answered or considered before a
detailed design and implementation of the BWR7 can start. Taking care of these questions and remarks is required to set up the necessary scope for the BWR7. In this chapter, however, we will go
ahead and set out a possible route for the design and the implementation of BWR7.
7.1
Preliminary Scope BWR7 – sustainable use of natural resources
Resources are the backbone of every economy. In using resources and transforming them, capital
stocks are built up which add to the wealth of present and future generations. However, the dimensions of our current resource use are such that the chances of future generations - and the developing countries - to have access to their fair share of scarce resources are endangered. Moreover, the
consequences of our resource use in terms of impacts on the environment may induce serious damages that go beyond the carrying capacity of the environment. These effects risk being aggravated
once the developing world has taken up growth and resource use similar to the industrialised countries. [EU, DG Environment: Sustainable Use of Natural Resources 9]
This introduction describes the broad scope and consequences of resource use in terms of impacts on
the environment. Environmental impacts can be defined as a change in the environment caused by
human activities that have a negative effect on the ecosystem, human health and resources. Life
Cycle Assessments (LCA) provide a good framework for determining the environmental impacts of
currently available products during the complete lifecycle10.
Taking the entire life cycle of a product into account by using a LCA should also qualify the environmental benefits or impacts of reusing or recycling construction products. The type of materials and
products selected in the design phase, influence the level of sustainability during the construction,
use and demolition phase of the construction work. The type of material and product also determine
the possibilities for recycling and reuse of materials.
As is the case with reuse and recycling, simply making a material or product more durable does not
inevitably lead to a more sustainable use of natural resources. For this reason, the implications of the
use of a material during its entire life cycle should be taken into account when considering the durability of a product or construction work. It could be, for example, that the choice for a more durable
material or product leads to additional emissions during the demolition phase.
9
Introduction sustainable use of resources, http://ec.europa.eu/environment/natres/.
10
In its Communication on Integrated Product Policy (COM (2003)302), the European Commission concluded that Life Cycle Assessments
provide the best framework for assessing the potential environmental impacts of products currently available.
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Paragraph 7.2 will describe existing Life Cycle Assessments which can be used for determining the
environmental impacts related to the use, reuse and recycling of natural resources and construction
products.
7.2 Determining the environmental impacts and indicators
In respect with determining the environmental impacts
of a product or material, we recommend considering
using a LCA and the ‘EN 15804:2012 - Sustainability of
construction works’ and the EU program ‘Product Environmental Footprint’. Both are setting a standard for
calculating the environmental impacts11 of products
during their lifecycle. Both are using so called Life Cycle
Assessments12 for calculating the environmental impacts of products during the total life time. During the
process of a life cycle assessments several assumptions
and considerations should be made. The purpose of the
standard EN 15804:2012, which describes the rules for
performing a life cycle assessment for construction
products, is to limit the number of these assumptions.
Figure 2: Lifecycle approach, JRC
7.2.1 Recommendation: use Life Cycle Approach EN 15804:2012
For calculating of the environmental impact of the ‘use of natural resources’ we recommend to use
the life cycle assessment methodology according to the rules described in the standard EN
15804:2012. This can also be seen as a PEF for construction products. A life cycle assessment according to this standard will give a solid overview of the different environmental impacts and relevant
indicators of a construction product.
At the next page the 24 environmental indicators used in EN 15804 compliant EPD13 are shown.
There are seven environmental impact indicators, ten resource indicators, three waste indicators, and
four output flow indicators.
Environmental Impact indicators
• Global Warming Potential (GWP)
•
•
Ozone Depletion Potential (ODP)
Acidification potential (AP)
11
Examples of environmental impacts: climate change, ozone depletion, particulate matter, human toxicity, eutrophication, ….
12
LCA is a methodological tool that applies life cycle thinking in an quantitative way on environmental analysis of activities related to pro-
cesses or products (goods and services). More information: http://lca.jrc.ec.europa.eu/lcainfohub/introduction.vm#
13
Environmental Product Declaration
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•
•
•
•
Eutrophication potential (EP)
Formation potential of tropospheric ozone (POCP)
Abiotic depletion potential for non-fossil resources (ADP-elements)
Abiotic depletion potential for fossil resources (ADP-fossil fuels)
Resource Use Indicators
• Use of renewable primary energy excluding renewable primary energy resources used as raw
materials
•
•
Use of renewable primary energy resources used as raw materials
•
Use of non-renewable primary energy excluding non-renewable primary energy resources
used as raw materials
•
•
Use of non-renewable primary energy resources used as raw materials
•
•
•
•
Use of secondary material
Total use of renewable primary energy resources (primary energy and primary energy resources used as raw materials)
Total use of non-renewable primary energy resources (primary energy and primary energy
resources used as raw materials)
Use of renewable secondary fuels
Use of non-renewable secondary fuels
Use of net fresh water
Waste Category Indicators
• Hazardous waste disposed
•
•
Non-hazardous waste disposed
Radioactive waste disposed
Output Flow Indicators
• Components for re-use
•
•
•
Materials for recycling
Materials for energy recovery
Exported energy
The second recommendation is to select for BWR7 relevant environmental impact indicators, resource
indicators, waste and output flow indicators. It makes sense to select those impact indicators which
are related to or part of EU policy. Think of Climate Change (EU Climate Roadmap 2050), the group
‘waste category indicators’ (Waste Framework Directive), and those impact categories (Global Warming, Ozone Depletion, Acidification, Eutrophication) linked to endpoint bio-diversity as part of the 7th
EAP. Paragraph 7.4 presents a pre-selection based on the match with BWR7 and relevant EU initiatives.
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7.2.2 EU database
Performing a full life cycle assessment for each construction product will be a time consuming and
expensive exercise. Especially for those parties not familiar with life cycle assessments. This includes
small and medium-sized enterprises (SMEs).
A solution can be to create a database at EU level with environmental impacts of construction materials and products based on secondary data (generic data from the literature or from databases) and
data from the industry. SMEs can compare their products with existing and implemented products
and use that general secondary data. The keyword should be access of use, without compromising
accuracy and integrity. Small and medium-sized enterprises should be able to use the method without incurring large costs. An EU database would have that advantage.
Rules for delivering and submitting data in the database should be set up and managed by an independent authority.
7.3
Defining the performance
“It should be kept in mind that construction products are intermediate products for incorporation in a
permanent manner in construction works or parts thereof. This means that environmental performance of construction products have only their meaning, when they are as assembled systems in the
construction works. Therefore, setting requirements on the environmental performance of products
without its context is totally arbitrary and potentially misleading.” [Quote by: Ari Ilomäki, CEN/TC
350 chairman].
Taking the previous quote into account, setting so called thresholds levels (values) for the environmental impacts of products is not recommendable. Judging and selecting products based on their
environmental impacts, not considering the total environmental impact of the construction work is, as
mentioned by Ari Ilomäki, totally arbitrary and potentially misleading. We recommend not to implement thresholds for the environmental impacts and the indicators of construction products.
A better approach is to define the essential environmental impacts of the construction product related
to the intended use or uses as mentioned in the CPR, article 3, 1 (The basic requirements for construction works set out in Annex I shall constitute the basis for the preparation of standardisation
mandates and harmonised technical specifications.)
Challenging part of this approach is the variety of intended uses of construction products. Brickwork
for instance, can be assembled in many different ways. Think of the different sub-materials to connect bricks (glue, types of mortar, frameworks) or how the bricks are laid. These varieties will influence the environmental impacts of the wall. The manufacturer of the wall should take these varieties
into account by declaring the environmental performance of the wall, based on the gathered impacts
of the individual products used and based on the declared use of the wall.
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7.4
Product declaration BWR7
At the next page you can find a table, based at the environmental indicators used in EN 15804 compliant EPD14, relating to the basic requirements of the BWR7.
Basic Work Requirement 7: Sustainable Use of Natural Resources
CharacterPerformance
(per kg product) istics
Basic Requirements
1 Environmental Impacts
•
•
•
•
•
•
•
Global Warming Potential (GWP)
kg CO2 eq
Ozone Depletion Potential (ODP)
kg CFC 11 eq
kg SO2 eq
Acidification potential (AP)
kg (PO4)3- eq
Eutrophication potential (EP)
Formation potential of tropospheric ozone (POCP)
Abiotic depletion potential for non-fossil resources (ADP-elements)
Abiotic depletion potential for fossil resources (ADP-fossil fuels)
kg C2H4 eq
kg Sb eq
MJ
2 Resource Efficiency Indicators
•
•
•
•
•
•
Total use of renewable primary energy resources
MJ
Total use of non-renewable primary energy resources
MJ
Use of secondary material
kg
Use of renewable secondary fuels
MJ
Use of non-renewable secondary fuels
MJ
Use of net fresh water
m3
3 Waste Category Indicators
•
•
•
Hazardous waste disposed
kg
Non-hazardous waste disposed
kg
Radioactive waste disposed
kg
4 Output Flow Indicators
•
•
•
•
Components for re-use
kg
Materials for recycling
kg
Materials for energy recovery
kg
MJ per carrier
Exported energy
Table 1: Example declaration BWR7, bases at EN 15804:2012.
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Environmental Product Declaration
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7.4.1 Match with EU initiatives
We linked the different type of indicators to the different European initiatives mentioned in chapter 6.
Basic Work Requirement 7: Sustainable Use of Natural Resources
Basic Requirements BWR7
EU initiatives chapter 6*
• Product Environmental Footprint
• EcoDesign (under development)
• 7th EAP
1 Environmental Impacts
• EcoDesign (under development)
• Resource Efficiency Platform
• 7th EAP
2 Resource Use Indicators
3 Waste Category Indicators
• Waste Framework Directive
• 7th EAP
4 Output Flow Indicators
• Waste Framework Directive
• 7th EAP
Table 2: Relation basic work requirement and EU intiatives.
* Ecolabel is excluded due to its consumer approach. Sustainability of construction works (EN 15804:2012) is the
bases of this table and therefore not specifically included.
7.4.2 BWR3 versus BWR7
BWR3 and BWR7 both include environmental performance of construction works and construction
materials and products. But the environmental performance of BWR3 is mainly focused on the reduction of dangerous emissions of substances/gasses to indoor air, soil, water and outdoor air (greenhouse gasses). And BWR7 is focusing on reducing the depletion of raw materials and natural resources.
Potential overlaps between BWR3 and BWR7 concern the environmental impact assessment suggested and described at previous pages and the concepts of reuse and recycling of the construction
works, the materials or parts of the construction works after the demolition.
•
The environmental impact assessment defines the ‘environmental quality’ as stated in the
description of the BWR3 as well as the ‘use of environmentally compatible raw and secondary
materials’ and the ‘sustainable use of natural resources’ expressed by the BWR7.
•
Reuse and recycling fit in the scope of BWR3 because it can reduce the impact on environmental quality and climate change during the lifecycle of the product and in the scope of
BWR7 because it can improve the efficiency of natural resource use.
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During the process of developing the BWR7 the potential overlaps should be addressed. In addition
the overlaps should be analysed more thorough and a choice must be made what is under BWR3 and
what should be expressed under BWR7. This analyse can be done by the European Commission in
close cooperation with the Member States and should lead to a report in which it is expressed how
BWR3 is changed by the CPR and what BWR7 is about in relation to BWR3. This report can deliver
input for the discussion how to fill in this new basic work requirement no. 7.
7.5
Next steps
It is unlikely that any of the EU Member States has put significant effort into designing and implementing the BWR7. Nevertheless we suspect exploratory studies have been made in some countries
on environmental impacts related to recycling and the use of resources for construction materials. A
survey of a number of Member States has indicated that there is interest in the content of this position paper.
Due to the several EU environmental initiatives and developments, some of them directly related to
the construction sector, we recommend remaining pro-active and aiming to crosslink the several initiatives. This should ideally result in one integrated environmental assessment system which can
function as the basis for, and replace different instruments related to, the environmental performance
of buildings, products and construction materials. In addition, it is undesirable to invest time and
money in developing new methodologies when existing elaborate methods are already now, or in the
nearby future, available.
For BWR7 it is important that there will be a document with a similar statue like the basic documents
which were set up in the past for the other essential requirements under the CPD.
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