Environmental claims & product declarations regarding construction products: New legislation in Belgium

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Environmental claims & product declarations

regarding construction products:

New legislation in Belgium

Federal Public Services of Health, Food Chain Safety and Environment DG5 Environment

Department PRODUCTS POLICY

1 D. De Lathauwer

Scientific advisor – Construction Products: Environment & Indoor Air Quality Federal Public Services of Health, Food Chain Safety and Environment

DG5 Environment

Department PRODUCTS POLICY

Dieter.DeLathauwer@environment.belgium.be

FOD VOLKSGEZONDHEID, VEILIGHEID VAN DE VOEDSELKETEN EN LEEFMILIEU

This presentation Federal public service Background & objectives Content of the decree How much

does it cost Examples Next steps

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Department of product policy

A-F Rihoux

Federal public service Health & Environment

2014 > Dieter De Lathauwer > Royal Decree EPD

3 DG 5 – Environment

Director General R. Moreau

North Sea Climate Change / Register

Market Surveillance

Biodiversity, CCPIE, …

Ecodesign Rohs & Weee Product Environment al Footprint Construction products - Environmental impact - Health impact / indoor

FYI: buildings = regional competency Off road vehicles EU Ecolabel Mobile phones (env & health) Reach Biocides

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BUILDING + PRODUCT

Example

Insulation materials:

Some only in cavity wall, some only in wooden frame construction. But cavity wall might have

another impact than a wooden frame.

5 Material related

environmental impact

of a building

=

Sum of

(LCA all individual

materials)

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Who is addressed?

7

You put an environmental message on your product You put an environmental message on your website and you explicitly refer to it on your product You have an LCA/EPD and want to make it publicly available You have an LCA and want

to make it publicly available

Who is not addressed?

Sustainable forrestry FSC, PEFC, … EU Ecolabel Labels according to NBN EN ISO 14024 Blue Angel, … Regulary obligated labels EU Energylabel , … HVAC, electric and electronical equipment

Two objectives

8

A regulatory framework for green claims and single indicators / a first step against green washing

Mandatory in case of environmental claim on the

product

Facilitate the provision of environmental product

declarations from the construction products

manufacturers

Voluntary Federal database

One database for the three regions

=

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What are environmental claims and EPDs?

9

Environmental claim / environmental message

“environmentally friendly” “low impact”

“sustainable” “low carbon footprint” “carbon footprint 425,3” …

EPD

Environmental product declaration

The results of a life cycle assessment put together in a an easily readible document

Quantified information over the life cycle and for a well determined set of indicators

Obligations I

10

The environmental claim has to be conform with NBN EN ISO 14021

You establish an LCA according to NBN EN 15804

Or you use a collective EPD

A 3rd party verifies the LCA

You declare the results of the

LCA on the federal database You add a link to the federal database adjacent to the environmental claim

You put the product on the market – the LCA is publicly

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NBN EN ISO 14021

ISO 14021:1999 “Environmental labels and declarations – Self-declared environmental claims (Type II environmental labelling). A summary can be found here:

http://ec.europa.eu/consumers/cons_safe/news/green/guidelines_en.pdf

11 Self-declared

environmental

claims shall be

accurate, verifiable,

relevant, … and not

misleading

Example in the standard.

Claims about environmental benefits of a

general nature or about sustainability such as

"environmentally-friendly", "green",

"non-polluting", "ozone friendly",

"environmentally safe", “nature’s friend”,

“ecological” are vague and non-specific and,

thus, must not be made

Obligations II

12

For individual manufacturers, or groups, or federations

You establish an LCA according to NBN EN 15804

A 3rd party verification of the LCA Organized by the owner of the EPD

You declare the results of the LCA on the federal database

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13 No LCA or

declaration in

the database

obligatroy. ‘only’

conformity to

NBN EN ISO

14021.

No LCA or

declaration in

the database

obligatroy. ‘only’

conformity to

NBN EN ISO

14021.

Compostable Compostable Recycled content Recycled content Degradable Degradable Reduced energy consumption Reduced energy consumption Designed for disassembly Designed for disassembly Reduced resource useReduced resource use Extended life product Extended life product Reduced water consumption Reduced water consumption Recovered energy Recovered energy Reusable and refillable Reusable and refillable Recyclable Recyclable Waste reduction Waste reduction

ONE SINGLE DATABASE

WILL BE THE ONLY ONE WITH SPECIFIC DATA USED BY THE REGIONS

POSSIBILITY TO DECLARE TECHNICAL PERFORMANCES

SELF MANAGED ACCOUNTS FOR MANUFACTURERS

RELYING ON VERIFICATION REPORTS FROM ACCEPTED VERIFIERS

NO EXTRA VERIFICATION

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to be

developped

/ under

discussion

to be

developped

/ under

discussion

Belgian program operator Belgian program operator Link with Belgian program operator Link with Belgian program operator Product category rules procedure Product category rules procedure Acceptance procedure for verifiers Acceptance procedure for verifiers Detailed verification rules Detailed verification rules

15

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Why additional indicators?

17 extra indicators

CEN

indicators

OVAM/MMG - English extended summary available:

http://www.ovam.be/jahia/Jahia/cache/offonce/pid/176?actionReq=actionPubDetail&fileItem=3072

Mutual recognition

Detailed rules for verification to be established.

Cradle-to-gate: easy.

Gate-to-grave: verifier needs to verify the validity of the scenario’s for Belgium.

Common digital data format

Belgium checks if it is possible to organize a roundtable with France, Germany,

Netherlands

Member of eco-platform?

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Economic operators

19 EU

OUTSIDE

EU

• Manufacturer • Importer • Distributor

• Making available, placing on the market = CPR definition

Making

available on the

BE

Placing on the

BE market

Use

Responsibilities

20 Manufacturer

The construction product and the environmental product declaration shall be in conformity with this decree

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Responsibilities

21 Importer

Verifies if the environment al product declaration is declared in the database

Any natural or legal person established within the EU, who places a construction product from outside the EU on the BE market.

Verifies if the website reference is put adjacent to the environme ntal claim As long as the product is not conform or he has reasons to think so he does not place the product on the market

Note: This is not the importer as we usually understand it. A Portuguese wholeseller making a product available on the BE market regarded as distributor, not an importer, because it is intra-EU.

If that wholeseller is the manufacturer, than the requirements of a manufacturer shall be fullfilled.

Keeps the information during ten years

Responsibilities

22 Distributor

Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market

In case of non-conformity he takes the necessary corrective measures or does not make the product available on the market

If he markets a product under his own name or modifies the product, he is regarded as a manufacturer

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Market surveillance

23 Yearly inspection campaigns

Product with environmental claim >

database record?

Both random & targeted

Random verification of results

How much does it cost?

Retribution to be payed to the Fund of Raw Materials. Co-managed with industry.

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Quantity (cumulative) Per new environmental profile Per changed environmental profile Per product description

1 to 5 € 150 € 100 € 50 Once for the validity (5 years) of the environmental profile 6 to 10 € 125 € 75 11 to 50 € 100 € 60 51 to … € 50 € 40 Example

A manufacturer wants for 10 products two commercial names to be separately found in the database (for commercial reasons), and for every product he has one environmental profile containing 2 scenario’s.

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Examples (1)

Allowed? LCA/EPD registration mandatory? 1

recycled content, reduced energy consumption, reduced resource use, reduced water consumption

yes No Conformity to NBN EN ISO 14021is sufficient.

2Low environmental impact No - Vague, conform to NBN EN ISO 14021

3carbon footprint yes yes

4EU Ecolabel yes no Out of scope

5EU energylabel yes no Het ontwerp KB voorziet hiervoor reeds een _{uitzondering.}

6Blue Angel, Nature plus, … yes no As soon as the label includes an LCA indicator, a full LCA declaration becomes mandatory

7FSC / PEFC yes no Out of scope of decree

8German EPD conform to EN ₁₅₈₀₄ yes No Conformity to relevant articles in decree_mandatory.

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Examples (2)

Allowed? LCA/EPD in database mandatory? 9

An EPD not conform to EN 15804 on the corporate website. On the product www.corporatewebsite.com

allowed

-10

An EPD not conform to EN 15804 on the corporate website. On the product “environmental information can be found on www.corporatewebsite.com”

Not allowed

-11Email to an architect with an EPD

not conform to the royal decree allowed no

12Mentioning 4 out of 6 indicators of

the EN 15804 on the product Not allowed

-This is considered to be an EPD and therefor shall conform to the EN 15804 which has a mandatory set of indicators. The full set therefo shall be mentioned on the product.

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Next steps

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EU Notification 2013/0301/ B (june 2013) BE Advisory Councils BE Council of Ministers BE Council of the State Signature of the Royal Decree

Publication Entry into

force DONE EU Commission asks attention for mutual recognition. DONE One major comment: No exemption asked for labels such as Blue Angel, … Q1 - 2014 Q1 - 2014 Q1 - 2014 Q1 - 2014 Entry into force January 2015

Additional transition period for products allready

put on the markt before January 2015 the entry into

force date is january 1st, 2016.

Database:

March-april: first test June: fully operational

2nd half of 2014: general test period

28 Summary

Summary

We want to stimulate the creation of manufacturer

specific EPD/LCA profiles. We want to stimulate the

creation of manufacturer

specific EPD/LCA

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