UIPI on Draft Environment Act

UIPI comments on Draft Environment Act

May 2023 
Brussels, Belgium

On 3 May, UIPI submitted feedback on the EU’s draft Environmental Delegated Act, which stems from the EU Taxonomy Regulation. This Regulation aims to set out the conditions economic activities have to fulfill to be labeled as ‘sustainable’. The Delegated Act will define technical screening criteria to determine sustainable economic activities for specific objectives under the EU Taxonomy Regulation.

These objectives include sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control or protection, and restoration of biodiversity and ecosystems. The draft Delegated Act includes provisions targeted at the construction industry, such as the construction of new buildings, renovation of existing buildings, demolition or wrecking of buildings and other structures, maintenance of roads and motorways, and the use of concrete in civil engineering works.

UIPI welcomed the recognition of construction and real estate activities as being eligible for the purpose of transitioning to a circular economy under the Taxonomy Environmental Delegated Act. However, we also highlighted the need to consider differences within the construction sector (i.e., contractors as service providers) and the property sector (i.e., investment decision-makers) to ensure the motivation to change/advance to a circular economy is targeted to where decisions are being made.

Moreover, we noted that the recycling rate for construction and demolition materials hardly reaches 50% in most Member States. As such, to meet the proposed value of at least 90% seems, unfortunately, unattainable.

We also expressed concerns regarding data availability in existing Environmental Product Declarations (EPD) regarding Global Warming Potential (GWP) fossil, GWP biogenic, GWP land for Level(s) indicators and the reporting format. We estimate that over 80% of available EPDs do not have this information. We, therefore, requested to allow for a gradual introduction of the proposed criteria.

We also proposed to specify building components, e.g., building frame, façade etc, when determining the level of retaining when renovating buildings.

All in all, while we acknowledge the need for the Delegated Act and welcome it in general, it is important to ensure that relevant actors can effectively and flexibly implement its provisions.

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