The Construction Products Regulation (CPR): the right tool for connecting a product’s environmental performance to the EU’s evolving building requirements

DISCLAIMER: All opinions in this column reflect the views of the author(s), not of EURACTIV Media network.

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Since its adoption in 2013, the Construction Products Regulation (CPR) has proven to be a pillar of the European single market. By establishing uniform rules for the CE marking of construction products and materials, industry professionals, public authorities, and consumers alike can now easily compare the performance of different products. For example, for mineral wool insulation product performances are related to thermal, mechanical, fire and acoustic performance.

Vincent Briard is Group Sustainability Director and Katarzyna Wardal is EU Public Affairs Manager at Knauf Insulation.

The focus of the current CPR is to ensure that all products arriving in the European Union (EU) are safe to use and install. While this role is critical to the free movement of construction products within the EU and to the safety and well-being of everyone, we think the regulation has the potential to do so much more.

Take for example Europe’s ambitious climate goal of becoming climate neutral by 2050. With buildings accounting for 40% of the EU’s total energy consumption and 36% of the EU’s total CO2 emissions, Europe cannot achieve its objective without significantly reducing buildings’ energy demand. The biggest potential for doing so is in Europe’s existing buildings, as 85-95% will still be standing in 2050. That’s why energy efficiency renovation should be the backbone of all the EU’s climate actions.

At the same time, to become climate neutral, the EU must take steps to ensure that all construction projects contribute to a fully decarbonised and sustainable built environment fully embracing the principles of circular economy. The way to implement and monitor this is through transparent performance indicators and a harmonised methodology that allows anyone handling a product, at any stage of its life, to easily evaluate and compare its environmental performance.

Sound familiar?

It should – it’s what the CPR aims to do. That’s why Knauf Insulation is convinced that an improved CPR can be the right tool for connecting a product’s environmental performance to the EU’s evolving building requirements.

Our recommendations for including environmental criteria in the CPR

As the European Commission looks to revise the CPR, we think a good place to start is ensuring that the regulation fully addresses the environmental aspects of construction products. The best way for doing this is to incorporate the harmonised EN15804+A2 standard, into the proposed CPR revision as the primary methodology to evaluate the environmental impact of construction products. The common European sustainable buildings framework Level(s) could serve as the basis for identifying the Life Cycle Assessment (LCA) indicators and scenarios. A gradual development and implementation of environmental performance calculations of buildings needs to be supported by substantial deployment of digitalisation.

There are already good examples of this on the market. Environmental Product Declarations (EPDs), for instance, are a proven method based on the EN15804+A2 standard for measuring a product’s environmental performance across its lifecycle, including its recyclability.

The CPR should also be revised to better enable a truly circular economy. This means promoting all construction products made from any recycled material – not just those that use recycled construction waste, but also those that are made from recycled materials derived from other industry sectors. As such, we believe the CPR should be revised to include – even encourage – the use of such materials. In doing so, the EU will achieve not only a circular construction industry but, more importantly, a truly circular economy.

Along this same line of thinking, the CPR needs to make a clear distinction between an original product and a reused one. At the moment, the regulation is limited to product placement. But, in a circular economy, where reuse should be promoted, this is not enough, which is why the CPR’s scope must be expanded to also include the performance of reused products.

We also support a streamlining of the current EU standardisation process. However, this requires:

  1. That the European Commission provide comprehensive guidance that clearly specifies the CPR’s legal boundaries. Doing so will ensure the technical experts involved in the standardisation process are able to develop harmonised technical specifications.
  2. A systematic usage of standardisation requests, including Member State regulatory requirements. This should be done in a clear, precise, and comprehensive manner, thus allowing standardisation experts to translate the requests in a way that meets both EU and national policy objectives. Furthermore, standardisation requests must be periodically assessed and evaluated to ensure they remain relevant to national regulatory needs and that they are based on the latest product knowledge.
  3. A clear commitment from all involved parties (European Commission, Member States, industry, SMEs, NGOs, etc.) to actively participate in the entire standardisation process. Such a commitment will facilitate consensus building and thus the development of harmonised technical specifications.

Finally, the CPR needs to be revised to support the EU’s ‘Fit for 55’ package. Take for example the package’s proposal to update the Energy Performance of Buildings Directive (EPBD) to require disclosures of a construction project’s global warming potential. The methodology currently being proposed is based on the LEVEL(s) voluntary framework for sustainable buildings and EU standard EN15978 for building-level carbon emissions.

Here, Knauf Insulation recommends that the revised CPR introduce harmonised EU standards for calculating and reporting carbon emissions (EN15804+A2 standard) and at building level, to use the EU framework LEVEL(s) based on EU standard EN15978.

The one and only regulation for product performance

All-too-often, the CPR’s potential is handcuffed by different national authorities applying different interpretations to the same regulation. Because the CPR is at its absolute best when it can support a single open market unhindered, we advocate for the use of enhanced market surveillance across Member States and in particular a harmonised enforcement of the regulation. For similar reasons, we question the use of national marks, which could create direct and indirect barriers to trade.

Here, the CPR should look towards such regulations as REACH for inspiration. Unlike the CPR, which lacks consistent interpretation across Member States, REACH uses an enforcement mechanism that has been agreed to by all Member States. As a result, all stakeholders benefit from having legal certainty about its application and enforcement.

The CPR should be the one and only regulation where product performance is accessed and communicated. Anything less would be a failure to manufacturers, regulators, end users, and consumers alike.

Not only does inconsistent and piecemeal enforcement jeopardise the legal certainty of the manufacturer, increase the administrative burden, and force the adoption of national compliance solutions, it guts the very essence of the single market – arguably one of the EU’s greatest achievements. Which is exactly why Knauf Insulation supports revising the CPR in a way that allows it to do its job even better: promoting not only a single open market, but a sustainable one too.

 

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