Positionspapier zum Product Environmental Footprint (PEF)

Comments of Deutsche Bauchemie on the ‘Legislative Proposal on Substantiating Green Claims‘

Deutsche Bauchemie fully supports the aim to provide consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions. As a sector, we firmly condemn any misleading claims and “greenwashing”. As a basis for achieving these goals, it is useful and necessary to create a consistent evaluation framework. However, the focus on only one single method for all sectors is problematic.

When it comes to construction products – which are intermediate products - the assessment regarding the sustainability of alternative solutions can only be meaningfully carried out at building level and not at product level. For the same reason benchmarking systems should apply only at building and not at product level. To be able to do the assessment at building level the supply chain communication of absolute values of construction products in a harmonised format is needed.

Within the construction sector, the increasing need for reliable information was met with the development of Environmental Product Declarations according to EN 15804. EPDs according to EN 15804 have been established in the construction sector for years as a scientifically sound standardized method. EN 15804 was recently revised according to a mandate of the European Commission, whereby EN 15804 was as far as possible aligned to the PEF methodology. Any remaining differences between the revised EN 15804 and PEF are due to the sector-specific conditions in the construction sector. Therefore, EPDs according EN 15804 should be accepted as the PEF approach for construction products. An EPD provides a credible, product related set of data in a standardised format. This set of data, which is verified by third parties, is then used to perform and assess the life cycle assessment of a building.

There is no need to create additional legislation for the environmental information of construction products. BRW 7 of the Construction Products Regulation (CPR) already addresses these aspects and only needs to be implemented. The upcoming revision of the construction products regulation offers a good opportunity to drive the implementation forward and to establish a European harmonised method for construction products based on EN 15804+A2.

The system of notified bodies, which exists already under the CPR, should be used for the verification of EPDs. For this purpose, the system of notified bodies must be expanded to involve bodies with the required expertise. Furthermore, it is needed to clarify which system for the “Assessment and Verification of Constancy of Performance” (AVCP) should apply. In addition, the tasks of the manufacturers and the notified bodies need to be clarified.

Enforcement should also take place within the CPR-framework via the national market surveillance bodies.

To ensure that the application of a harmonised LCA method according to EN 15804 leads to comparable results the harmonisation of background data is required. It should be provided by a freely accessible common EU database. In addition, a freely accessible tool for the EPD calculation would simplify the implementation in particular for SMEs.


Deutsche Bauchemie e.V.

Frankfurt am Main

26 November 2020


As an industry association, Deutsche Bauchemie represents the entire construction chemicals industry in Germany. In 2019, the more than 130 member companies with around 32.000 employees generated sales of 8.5 billion euros. This corresponds to half of the European market volume and about a quarter of the world market. Under the umbrella of the German Chemical Industry Association (VCI), Deutsche Bauchemie has been representing the interests of its member companies for over 70 years, towards the public, political actors, authorities, other industry sectors, science and the press.

Your Reference Person

Martin Glöckner
Director Regulatory Affairs

Phone: +49 69 / 25 56 - 16 33
E-mail: martin.gloeckner[at]vci.de