Page 27 - European Energy Innovation - winter 2018 publication
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Winter 2018 European Energy Innovation  27

                                                                               COMMUNICATION

established themselves in Germany and throughout
Europe as a voluntary construction industry standard.
In Europe, the basis for EPDs is the European standard
EN 15804:2012+A1:2014, which, as a horizontal standard,
provides basic product category rules that EPDs must
follow for construction products and all types of
construction-related services. According to this standard,
a total of 25 different environmental indicators must
be declared in an EPD: potential environmental impact,
energy and material resource use, output flows, and
waste categories. At a minimum, these must take into
account the production phase ("cradle to gate"). However,
as declaration holder, the manufacturer has the option
of including further life cycle phases, such as the use
phase or the disposal phase ("end-of-life"). Before an EPD
can be published in a dedicated program, it must first be
evaluated by an independent verifier.

At the request of the European Commission, EN 15804             Frank Grootens
is currently being revised. Among other changes,
declarations will now have to take into account the entire      system for the assessment and verification of constancy
life cycle. In addition, EPDs will require a number of new      performance (system 3 or higher) has until now, however,
life-cycle-assessment indicators. Publication of this           been required only when the safety of workers and/or
revised standard is not expected until 2019, at the earliest.   occupants was directly affected.

It can be assumed that, on the basis of the revised             Should the key figures and regulations set forth in EN
standard and with the aim of transferring the                   15804 be converted into harmonised product standards,
environmental performance indicators defined in EN              thus becoming a component of the declaration of
15804 as essential characteristics into harmonised              performance, "ECO Platform", as the umbrella organisation
product standards, the Commission will issue one or more        for the various national EPD programme operators in
mandates to the CEN. The individual CEN-TCs (Technical          Europe, advocates the use of a System 3 assessment
Committees) would then need to develop uniform                  and verification of constancy of performance. To ensure
reference scenarios for the various product groups, e.g.        a consistently high level of quality, a requirement should
for use or end-of-life phases. Because the EN 15804 is          be established that EPD programme operators continue
a horizontal standard for construction products and all         to participate in the verification process. Whether this
types of construction-related services, it cannot provide       will make accreditation and/or notification of the EPD
this itself, but can only provide a standardised framework      programme owner necessary is a topic for further
of conditions for defining the scenarios. However, to           discussion.
enable comparisons of the environmental indicators
contained in the EPDs, the use of standardised scenarios        With regard to the legal formality issue mentioned
is critical. In addition, manufacturers, as distributors,       above, one possible alternative to the direct inclusion of
have no influence over – and cannot be held liable for          individual environmental indicators in the declaration of
– what is done with their products once they leave              performance could be to include a simple reference to an
the factory.                                                    EPD in the declaration. This approach would, in any case,
                                                                likely come closest to fulfilling the original intention of
The politically-driven future focus on the entire product       recital 56. l
life cycle also leads to an issue that is a legal formality. A
key additional question here will be how to maintain the         For further information please contact:
high quality of EPDs, which currently is ensured through
independent verification and publication in an EPD                Frank Grootens
programme, if, in the future, environmental performance           Institut Bauen und Umwelt e.V.
indicators will be required to be stated directly in the          Email: grootens@ibu-epd.com
declaration of performance. This would require the                Web: www.ibu-epd.com
establishment of a AVCP system 3 (AVCP: assessment
and verification of constancy performance) that would
conform to CPR regulations. The recourse to a higher

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