Published 12 July 2022

Product level information is required to measure building performance

In 2019, the European Commission (EC) published the EU Green Deal that has been the cornerstone
of our 2050 climate neutrality strategy. The construction ecosystem played its part, with the Renovation
Wave, the revision of both the Energy Performance of Buildings Directive (EPBD) and the Construction
Products Regulation (CPR).

For over a decade, our industry has made great use of the Environmental Product Declarations (EPDs)
scheme to deliver product information to the market on a voluntary basis. EPD indicators are based on
a European standard (EN15804+A2) and allow for a holistic assessment at building level. Like its
customers, SMEs and multinational companies have embraced EPDs, which are now part of the
construction ecosystem.

As EPDs are voluntary, the information is excluded from the products Declaration of Performance (DoP),
a legal document defined by the CPR. This dual approach, mandatory and voluntary, has impacted the
credibility of the EPD data, and for many years we have called for the implementation of the CPR Basic
Requirements for Construction Works number 7 (BRCW 7) in compliance with EN15804+A2. This would
allow designers and architects to make holistic, whole lifecycle assessments of building.

The revision of the Construction Products Regulation (CPR) launched in April 2022 proposes to solely
include Global Warming Potential (GWP) in the DoP. Climate Change is indeed our biggest challenge,
but we believe that focusing on a single environmental performance may lead to misleading conclusions
in terms of sustainable construction, and potentially fail to achieve other environmental targets.

We recommend that the full set of the EN15804 indicators be made mandatory in the revised CPR
(Annex I part B), as requested by the European Parliament Environment Committee, and urge the
European Parliament to support these amendments at the Plenary vote scheduled for July.

We remain at the disposal of Members of the European Parliament for further information ahead of the
plenary vote scheduled for July.