Småhus, flerbostadshus och förskolebyggnader - Svanen

Nordisk Miljømerking
Hus, leiligheter og barnehager 089/versjon 2
Høringssammenstilling, oppdatert 10. august 2010
environmental indicators were developed against which all construction products need to
be assessed. These indicators are agreed by industry, consumers, environmental groups
and regulators and cover all aspects related to the environmental performance of the
product. The most prominent activity currently underway is the standardisation work
undertaken by CEN/TC350 and mandated by the European Commission. The standards
will also include the measurement methods developed by CEN/TC 351 on the release of
dangerous substances to the indoor air and to soil and ground water. RT believes that the
standards of TC 350 and 351 provide the most appropriate framework for the Nordic
Ecolabel, as they provide a holistic view and allow the assessment of products at the
building level.
A building is not a simple product but a complex assembly of hundreds of different
products, materials and systems, which interact amongst each other and with the indoor
and outdoor environment. Experts across Europe agree that the environmental
performance of construction products can only be assessed at the building level in a given
end‐use design, i.e. when the above mentioned interactions are known and can be
examined. A recent study conducted by the EU Joint Research Centre shows that the use
phase accounts for 98 % of the environmental impacts of buildings in the case of existing
buildings and about 80 % in the case of new buildings. In other words, material‐related
indicators must focus on the environmental performance of products in a given end‐use
application over their life cycle.
The European polymer producers (PlasticsEurope), together with the European
PVC resin producers (ECVM), and the European plastics converting industry
(EuPC)
General comments on restrictions on the materials and chemicals used in
construction
The plastics industries fully support … a major contribution to achieving overriding goals
such as climate protection. For buildings, life-cycle environmental impacts are largely
associated with the use phase, and therefore particular emphasis should be placed on usephase
performance.
The current Nordic Swan draft does indeed propose numerous use-phase criteria, but at
the same time is proposing restrictions on the materials and chemicals used in
construction. Where no risk is associated with the use of these materials and chemicals,
no benefit can be attained by restrictions. On the contrary, the proposed restrictions could
lead to technical barriers in achieving the use-phase performance goals and ultimately
promote less sustainable construction material and buildings, which would undermine the
credibility of the Type I ecolabels in general, and the Nordic Swan in particular.
The authors should be aware of the great newly developed energy saving materials and
equipment and the document, as it stands now, will prevent these materials/equipments
from being used, with a clear negative impact on the environment
Although exceptions on the restrictions are highly needed, we notice that no such
exceptions are foreseen !
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