Småhus, flerbostadshus och förskolebyggnader - Svanen

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Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 The proposal treats different construction materials unequally. Of all the primary construction materials, requirements are only set for timber. As far as the label is concerned, for instance, no significance is attached to where and in what conditions steel and cement are produced, nor to the fact that the environment impact of manufacturing these materials is many times greater compared to producing timber. Furthermore, the proposal takes no stance on the depletion of natural resources or on the carbon dioxide emissions caused by the manufacture of building products and by buildings, even though carbon dioxide emissions are regarded as the prime cause of climate change. The same criteria should be applied to different materials. The criteria should be based on the CEN TC 350 standard being developed by the EU, which will create harmonised European criteria for comparing the environmental impacts of construction works. Different environmental labels, and the rationale for them, should be harmonised. At present there are too many labels for the consumer to be aware of the differences between them. The proposal is incoherent in structure. It will create a partly overlapping and even conflicting system alongside normal building supervision. The criteria for the label should be based on construction in conformance with the requirements in force in different countries, in addition to which the main convergent requirements for environmental sustainability should be presented for the Swan ecolabel. Thus the Swan ecolabel would be an indication of construction according to requirements that address environmental issues. For example, Finland’s energy efficiency refers to obsolescing regulations as regards requirements. This should be phrased so that the currently valid regulations are specified when applying for building permission. Otherwise, early next year the Swan ecolabel could be granted for a building that contravenes regulations. Construction polyurethane industry of Finland (CPIF) The Nordic Ecolabel proposes chemical material indicators without reference to the enduse application (O14-O21) and without assessing what benefits / negative effects these substances provide over the whole building life cycle. This will lead to material choices which may neither provide the most environmentally friendly nor the most sustainable solution for a given building over its life cycle. CPIF calls on the Nordic Ecolabel to establish a scientifically sound method to assess the life cycle performance of construction products at the building level. TC350 and TC351 will provide the tools to do this. The European polymer producers (PlasticsEurope), together with the European PVC resin producers (ECVM), and the European plastics converting industry (EuPC) Comments on material requirements for chemical building products: Despite the Nordic Swan publication on 29 May 2008 of 30 pages on “Swan-labelling of Chemical building products”, the current document contains four more pages on … chemical building products. 58 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Comments on the selected materials to put requirements on : The chapter 3 on “material requirements” shows a very biased and unbalanced approach to putting requirements for houses. • First, there is too much emphasis on criteria for materials instead of the building as a whole. • Second, the kind of materials selected to put criteria on is limited to mainly : • “Chemical building products”, • “Chemical substances in permanent building products” and • “Timber and fibre-based materials”. In most European countries, many other materials are used in buildings, in much, much higher quantities, tonnages and volumes than the 3 categories mentioned. However no requirements are put on these other categories. For these reasons and the for the reasons explained before in our general comments, we urge the deletion of the material requirements made on chemical building products, chemical substances in permanent building products and plastics in the sections 3.1 and 3.2 and ask to delete these sections and the corresponding subsections. Comments from Nordic Ecolabelling The Nordic Ecolabel agrees that the use phase accounts for the major environmental impact, and as buildings are becoming more insulated this share is decreasing. However, many of these types of studies do not properly take environmental impact from hazardous chemicals into account. The Nordic Ecolabel prohibits certain substances related to environmental and health problems. We regard these substances to pose a risk in production/installation, in the user phase and in the waste management. Although the main criteria are set on the energy performance of the building in the use-phase, we will encourage the development of energy saving materials without conflicting health and environment in other areas. We cannot require only use of Swan labelled building products, and therefore, we need to make specific criteria for hazardous chemicals to ensure a certain environmental and health standard. There are alternative materials in the market with less environmental impact, and the criteria can also encourage the use and development of more sustainable materials. If a chemical building product already carries a Swan Labelled there is no need for further documentation of the requirements. We agree with Plastics Europe that the materials selected for requirements are limited. The criteria are most thorough for timber, where the demands are put all the way back to the forest. For plastics and metals the demands are not including the extraction of the starting material. Material manufacturers in general are very protective of their product information and often do not give specific values of their products, but rather present average European or global data. We are constantly seeking to obtain knowledge and will put demands on more materials in the next revision. 59 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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