6.2 Legislation regarding chemicals in construction products/building structures in other
6.2.4 Regulated substances in Germany, France and Belgium
The national legislations in force in Germany, France and Belgium regulate emissions of specific substances from construction products. The legislative approach, and the selection of regulated substances, differs between the countries. When it comes to regulated substances, the provisions in Germany and Belgium have great similarities, while France has opted for a different type of solution. The process for selecting substances in the various countries is described below and is summarised in Table 3.
Germany has restrictions relating to both contents and emissions for construction products, while France and Belgium only have restrictions on emissions. The contents requirement in Germany specifies that no substances which are carcinogenic or mutagenic (substances classified as C or M in Category 1A and 1B109) may occur in construction products for indoor use. However, there is no restriction on contents for construction products in the German system for substances which are toxic for reproduction.
Substances producing effects which are toxic for reproduction do not have emission levels regulated in Germany either, whereas carcinogenic and mutagenic substances may not be emitted in concentrations above 1 µg/m3. Belgium also has an emissions limit of 1 µg/m3 for substances of this kind, but substances which are toxic for reproduction are also included in this. In France, emissions for a very small number of substances which are carcinogenic, mutagenic or toxic for reproduction are restricted. These substances (trichloroethylene, benzene, DEHP and DBP) may only be used if emissions are under 1 µg/m3. However, in practice, with a threshold value of 1 µg/m3 it means that these substances cannot be used under the regulation.
VOC emissions are regulated in all three countries, both at a general emissions level based on limit values for total emissions of volatile organic compounds (TVOC, ≤ 1 000 µg/m3) and at a substance-specific level based on LCI values. From a health perspective, individual values are more important than the TVOC, but the TVOC value can be seen as an indicator since low total emissions of VOCs often correlate with a better indoor environment.
A large number of substances have been evaluated at substance-specific level in the German system and LCI values have been derived. These individual values are used in emissions analyses where a ratio is calculated between the measured emissions of a specific substance and a corresponding substance-specific LCI value. The ratios for all the substances emitted from a construction product are summarised and the total, known as the R-value, cannot be higher than 1110. Belgium has a similar system for calculating a total hazard ratio, but based
109 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, Annex VI.
110 The ratio (R-value) is expressed with one significant digit (R≤1), which means in practice that a total ratio up to 1.49 is acceptable (rounded down to 1).
on calculated EU-LCI values (see also section 5.1.1). Belgium has also retained emissions limits for three substances (acetaldehyde, toluene and formaldehyde), which had previously been regulated at regional level.
In Germany there is also an emissions limit for VOCs which do not have an LCI value (≤ 100 µg/m3). The purpose of this emissions limit is to offer manufacturers of construction products an incentive to submit information about substances which are emitted and suggest that these substances should be assessed and have an LCI value derived. It is therefore beneficial for companies to have as many substances as possible with LCI values, which provides
knowledge about chemicals and facilitates the transfer of information, and also discourages substitution with a harmful substance. The push to submit substance information for
assessment also means that the list of substances with LCI values is kept up to date and relevant.
The French system is based on labelling construction products in one of four categories (A+, A, B or C), with the most stringent requirements being set for Category A+, descending in order to Category C, where there are no emissions restrictions at all. In the case of Category A+, the same TVOC limit applies as in Germany and Belgium, but at substance-specific level, there are only provisions on emissions limits for 10 substances (see Appendix 5). The
selection of substances is based on substances which are the most common found indoors in France, along with risks linked to inhalation. No hazard ratios are calculated in France. There is also a total emissions limit for semi-volatile organic compounds (TSVOC ≤ 1 000 µg/m3) from construction products in Germany and Belgium, whereas such substances are not regulated in France. One problem with SVOCs is that there are, to a large extent, no suitable methods for measuring them. This is why the analysis data is often inconsistent and have a large amount of variation (see also section 8.2.4).
Table 3: Comparison of which substances/parameters are included in the national restrictions in Germany, France and Belgium.
Parameter Germany France Belgium
Type Restriction Labellinga Restriction
Timeframe for measurement 3d, 28d 28d 28d R-value (total) ≤1 - ≤1 Number of substances (emissions) 193 10 180
TVOC ≤1000 µg/m3 <1000 µg/m3 (for cat. A+) ≤1000 µg/m3
TSVOC ≤100 µg/m3 - ≤100 µg/m3
CMR 1A/1B (VOC) ≤1 µg/m3 (includes only C&M) -≤1 µg/m3 for – Trichloroethylene – Benzene – DEHP – DBP ≤1 µg/m3 Substance-specific restriction Acetaldehyde ≤200 µg/m3 Toluene ≤300 µg/m3 Formaldehyde ≤100 µg/m3 Other restrictions VOC without LCI ≤100 µg/m3
Contents restriction of CM 1A/1B
aIn France labelling of construction products is required, but there are no restrictions on minimum levels. The labelling system has specified emissions levels for different categories/classes (A+, A, B and C) where the lowest class (C) does not entail any restriction on emissions (apart from the 4 CMR substances).