Småhus, flerbostadshus och förskolebyggnader - Svanen

Nordisk Miljømerking
Hus, leiligheter og barnehager 089/versjon 2
Høringssammenstilling, oppdatert 10. august 2010
exposure scenarios in the extended Safety Data Sheet which is passed down the supply
chain. This risk‐based approach throughout the substance life cycle is the common
ground of the EU chemicals regulation. The Nord Ecolabel prohibits certain substances /
R phrases without verifying whether the use of the substance/ product is leading to risks
for users / the environment. Neither does it assess whether the use of a certain substance /
product improves the life cycle performance of the overall building (durability,
reduced material use etc.). On the other hand, the use / presence of certain substances
which are proven to be carcinogenic is authorised without restrictions. Hence, it is
doubtful whether environmental and health protection was really the main driver for this
Ecolabel. This impression is reinforced by the proposed exclusion of substances for
which scientific evidence shows that they are not dangerous (see following section).
BING calls on the Nordic Ecolabel to put the material criteria on a scientific basis and
apply the approach adopted by European legislation.
European Council for Plasticisers and Intermediates (ECPI)
The creation of parallel initiatives is unnecessary and confusing
Construction chemical products are already covered under the Construction Products
Directive (CPD) and in future under the Construction Products Regulation (CPR). Most
importantly, their use in all applications is now covered under the new European
Chemicals Regulation, REACH.
The REACH regulation was developed over several years together with Government,
industry and non-governmental stakeholders.
On this basis, the REACH process should not be undermined by initiatives which can
lead to confusion in the market place and unjustified deselection with associated socioeconomic
impact for European society.
The European polymer producers (PlasticsEurope), together with the European
PVC resin producers (ECVM), and the European plastics converting industry
(EuPC)
General comments on chemicals/plastics in construction materials :
The EU REACH regulation introduces the concept of chemical risk assessment and
management before a chemical substance is put on the market and shifts the
responsibilities from public authorities to industry. Additionally, the EU Construction
Products Directive and the EU Ecodesign directive are undergoing revision to take into
account sustainability design aspects of construction products in their conformity
assessment. Accordingly, there is no need that the Nordic Swan should contain
requirements for chemicals/polymers in construction materials and buildings.
Comments on chemicals/plastics in construction materials :
The EU REACH regulation introduces the concept of chemical risk assessment and
management before a chemical is put on the market and shifts the responsibilities from
public authorities to industry. Additionally, the EU Construction Products Directive and
the EU Ecodesign directive are undergoing revision to take into account ecological
design aspects of construction products in their Conformity Assessment. Accordingly,
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