Småhus, flerbostadshus och förskolebyggnader - Svanen

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Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Nevertheless, we would like to express our surprise to the development of a Nordic ecolabelling of houses, flats and pre-schools, while an European ecolabel for buildings is being developed since 2008. EFCC supports the Commission’s initiative to harmonize existing eco-labelling schemes, and does not support the creation of parallel initiatives that will confuse consumers without helping them to make informed choices. The European polymer producers (PlasticsEurope), together with the European PVC resin producers (ECVM), and the European plastics converting industry (EuPC) We are surprised to hear about the development of a Nordic ecolabel for houses, flats and pre-schools, while a European ecolabel for buildings is being developed since 2008. We do not support the creation of parallel initiatives that will confuse consumers without helping them to make informed choices. General comments on the procedures followed by the Nordic Swan : The Nordic Swan draft published is dated 4 June 2009 which means that the development must have started in the end of 2008 or before. During that period the plastics industry has not been informed of this development. We are not surprised by this because this is standard procedure in the Nordic ecolabel, but we do strongly protest against this lack of transparency. Referring to national ecolabel schemes, such as the Nordic Swan, we would like to underline that the new Ecolabel Regulation, adopted in the European Parliament on 2 April 2009, requests that the criteria are determined on a scientific basis, considering the whole life cycle of products, and are adopted with the participation of all stakeholders. The regulation in article 7 §2 also states that : “Where criteria have already been developed under another Ecolabel scheme complying with the requirements of environmental EN ISO 14024 type I labels for a product group for which no Community Ecolabel criteria have been established, any Member State in which the other Ecolabel scheme is recognised may, after consulting the Commission and the EUEB, propose those criteria for development under the Community Ecolabel scheme.” Considering this and the fact that Public Authorities may use not only criteria of the European Ecolabel, but also the ones of national eco-labels when they lay down public tenders (Directive 2004/18/EC), it is of crucial importance that also the developers of national ecolabels, such as the Nordic Swan, fully respect the provisions of the new Community Ecolabel regulation because these national ecolabels can be proposed to the Commission to become EU Ecolabels and, as a consequence, become a reference for all the other European countries. This could avoid that Public Authorities consider (in their tenders) criteria which are based on societal concerns and without the involvement of all the interested parties. We consider that a national ecolabel should only be taken as reference for EU ecolabel or EU Public Procurement if recognised at the European level following the way established in the new Ecolabel Regulation. 18 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 The Nordic Swan criteria are not fit for use at the EU level as long as the Nordic Swan keeps on : • following un-transparent procedures; • not informing industry from the early stages of development; • excluding the participation of stakeholders; • disrespecting the provisions of the Community Ecolabel regulation. Construction polyurethane industry of Finland (CPIF): + BING, Europe Summary: Whilst CPIF fully supports sustainability initiatives for buildings based on coherent and generally recognised indicators, this initiative cannot be supported for the following reasons: • Our societies must aim for sustainability which is based on a balance between the environmental, social and economic development. The Nordic Ecolabel proposal does only cover the environmental part and is therefore not designed to achieve a truly sustainable society. • Even the environmental pillar of sustainability is only partially covered, as the proposed Nordic Ecolabel does not allow an assessment of the performance of building materials at the level of the building over their whole life cycle. In other words, the proposal does not allow choosing the best performing materials for a given end-use design. • The proposal does not take account of existing legislation and risk assessments. • The proposal does not look at the best possible health and environmental protection as it bans substances that are not dangerous, whilst authorising proven dangerous substances. This is illogical and discriminates against some of the best performing products on the market. • The proposal confuses brominated and halogenated flame retardants. Introduction Sustainable development can be defined as “a continuing process of economic and social development, in both developing and industrialised nations, that meets the needs of the present without compromising the ability of future generations to meet their own needs.”1 1 Brundtland Commission, United Nations Commission on Sustainable Development – 1987 CPIF fully supports efforts to increase the environmental performance and sustainability of buildings. An ambitious and coherent set of measures can lead to a triple win situation: providing sustainable buildings for users, protecting the environment and offering new business opportunities to industry. Nordic Ecolabel does not provide for sustainable buildings The draft Nordic Ecolabel does not look at the economic and social pillars and the longterm sustainability of labelled buildings can therefore not be guaranteed. Several national and international initiatives were undertaken to develop indicators for sustainable buildings. They aim to assess the three pillars of sustainability 19 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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