In line with the position of the Finnish Association of Construction Product Industries (RTT) (here enclosed), Concrete Europe would like to raise its concerns about the potential barriers to trade that the proposed Decree would set for the following reasons.
i. EU wide methodologies for the assessment of carbon footprint already exist at standardisation level (EN 15804+A2 and EN 15978); their basic principles should be respected in Member States technical regulations.
ii. EN 15804 is in the process of being harmonised under the Construction Products Regulation (in its Acquis Procedure); it would be better for Member Sates to wait for the finalisation of this process rather then being obliged to adapt to it at a later stage.
iii. Under the Energy Performance of buildings Directive, a methodology for the assessment of Global Warming Potential is under development by the European Commission.
iv. The introduction of the concept of “Carbon handprint” as described now is not in line with the above-mentioned standards. To avoid confusion and misleading environmental information, such concept should be further developed and assessed with experts at European level before being implemented in one Member State.
Following these arguments, we believe that the introduction of the decree would be a barrier for those manufacturers having developed sustainability assessments following the current European Standardisation schemes. Additionally, harmonised methods under development at EU level might finally contradict the principles of the proposed decree thus requiring a modification in the short term with all the negative impacts associated with it.
