8.4 Identication and assessment of impacts
8.4.1 Cost impacts
The proposed regulation resembles in many respects the rules which have been introduced in Belgium, France and Germany. The cost impacts of these countries’ regulations have been examined to some extent in connection with them being notified to the EU Commission153. Just as Belgium argued in its notification to the EU Commission, the cost- impacts of the Swedish regulation can be described as being of minor significance as the rules:
· Are based on existing regulations in other Member States and on recommendations from the WHO;
· Contain health-based criteria drawn up by the EU Joint Research Centre; · Comply with European harmonised standards for test methods (TC 351);
· Have a similar scope, to a certain degree, to existing regulations which have been notified and apply in other EU Member States (France, Germany and Belgium). However, unlike the Belgian regulation, the proposed Swedish regulation does make tests mandatory for the products mentioned in section 8.3. Furthermore, the scope of the proposed regulation is broader than that in the above-mentioned countries as construction products used to construct walls and ceilings are also subject to emissions and documentation requirements. Based on the consequences described by Belgium in its notification to the EU Commission, we believe that the cost impacts of the proposed regulation will be as described in Table 10 below.
153 See notifications 2009/701/F (France), 2009/167/D (Germany) and 2012/568/B (Belgium). The notifications from France and Belgium respectively included impact assessments in the enclosed documents.
Table 10: Cost impacts of the proposed regulations for companies, users and consumers affected by it
Nature of cost for companies, users and consumers affected
Calculated size of costs as total and per company or product
Costs for testing, according to the forthcoming harmonised VOC standard, to ensure that
construction products placed on the market in Sweden meet proposed emissions requirements.
The costs of tests for VOC emissions are calculated, according to the French regulations154, at approx. EUR
3,000 per test (excl. taxes). Assuming that all products need to be tested, this would entail for the French market costs equivalent to approx. 0.1% of the affected companies’ turnover.
Based on our contacts with the German and Belgian authorities, they specified costs for tests on VOC emissions of between EUR 1,500 and 2,000 per test.
The French notification discusses costs from industry (EUR 3,300- 4,500) and from the companies offering the services for VOC testing (EUR 2,000-3,000). It can be assumed that the costs for tests will be lower as a result of harmonising test methods and of increased supply and competition between testing companies. These costs were calculated in 2009. More recent information from the German and Belgian authorities supports the assumption that the actual cost per test is lower nowadays155.
Administrative costs for compiling documentation and providing it to the market surveillance authority on request
The additional cost involved in compiling and providing the documentation is unknown.
The documentation must be provided in a language which the market surveillance authority can understand, which may entail translation costs if imported products already have documentation produced in a different language.
The CPR already stipulates the requirement that construction products covered by a harmonised standard must have a declaration of performance and be CE-marked so that they can be sold. The proposed emissions requirements will be essential characteristics and will therefore be reported in the declaration of performance.
Costs of measures taken in the form of product development for the construction products which do not meet the emissions requirements. In some cases, this may incur increased costs for raw
The additional cost involved in product development is unknown. The number of products which may be affected by product development depends on how many products are identified with an inadequate emissions
performance by the manufacturers
Viewed in comparison with the reference alternative, with existing and developed voluntary systems and rules in other EU countries, we believe that many construction products on the Swedish market already meet proposed emissions requirements now. Therefore, the
154 See notification 2009/701/F.
155 However, this conclusion is contradicted by the Flooring industry (GBR), which refers to a number of operators in the materials sector and gives a calculated cost of EUR 5,000 per test. The GBR also points out that there is no calculation for the test capacity available in Europe and that the lack of availability of such test capacity may present an obstacle for companies with affected construction products.
materials and production. of construction products. need for product development will probably affect a certain
proportion of the total number of products on the market.
Many Swedish companies are currently selling construction products to other EU countries which have already introduced different forms of emissions requirements, and these products’ performance should be adequate in relation to the proposed Swedish rules.
Reduced benefit for users and consumers in the case of construction products being withdrawn from sale due to the emissions requirements or based on product development delivering a poorer performance and quality than the original product.
The potential reduced benefit for users and consumers in Sweden is unknown.
We have not learnt of any significant adverse effects reported for users and consumers as a result of the national regulations introduced in France, Germany and Belgium.
The proposed regulations entail in several respects harmonisation of emissions requirements compared with national regulations in other EU countries. The provisions in the Construction Products Regulation already stipulate a requirement for declarations of performance, which is likely to mean that any degradation in performance can be identified if it results from additional provisions in Sweden.
The cost impacts of regulation are likely to be less significant with regard to VOC emissions from construction products intended to be used in flooring in the indoor environment. This category of construction products is already covered by provisions in Germany, France and Belgium. Therefore, there should be products available on the market which can meet future Swedish requirements without any major adaptations. Construction products intended to be used in the construction of walls and ceilings are also covered by the market-based labelling system in France. However, only certain types of these construction products are covered by provisions in Germany. Belgium does not have any provisions which apply to walls and
ceilings (but this matter is being examined). In a study carried out by Vito156, commissioned by the Belgian authorities, the envisaged extension of the regulation in Belgium is described (mentioning that it will also apply to walls and ceilings) as the most ambitious and stringent in the EU. The study discusses the feasibility of these extended requirements, on the one hand, based on how far existing voluntary standards have gone and, on the other, based on an assessment of emissions data for construction products inside and outside the EU. The conclusion drawn by the authors is that most products in the categories of wallpaper, ceiling boards and panels, (water-based) paints and primers, plasterboards and plaster, adhesives and sealants seem to be able to comply with the health-based limit values. In the case of another group covering construction products in the categories of walls and ceiling covering materials (lye, coatings, plaster, wall panels and varnishes), the data available is described as inadequate in terms of assessing the feasibility of the provisions. In the case of a third category covering particle board, fibreboard and plywood, most materials are not expected to fulfil the Belgian provisions. For these products, the hazardous substances need to be replaced through product and/or process development in order to meet the emissions requirements. In the consultant’s report it is indicated that any extension of the Belgian provisions would incur increased costs for the industry in terms of tests, development and investments. It was not possible to quantify these costs and they are expected to vary between different product types and sectors.
8.4.2 Consequences for companies’ competitive conditions and trade in