EN 15804:2012 CEN/TC 350/WG 3 status: February 2014
Answers to interpretation requests for EN 15804:2012, Sustainability of construction works - Environmental product declarations - Core rules for the product category of construction products
Clause/ Subclause / Paragraph/ Figure/ Table/ / Question / Answer / No. for internal use / Date /general / Is it the intention, that it should be possible to develop an EPD according to EN 15804, based only on the core PCR? (Without having to develop a PCR specific for that product category) / amended Feb 2014: Yes it is possible to develop an EPD based only on EN15804. Product group specific PCR provide more specific guidance, requirements and rules.
The program operator shall state according to which standard the EPD was made. If the PO that has implemented EN 15804 as PCR document has more specific PCR documents for certain product groups, he may integrate them, as long as they are compliant with EN 15804. / 01_2013 / 08/2013,
amd: 02/2014
general / Does the EN 15804 substitute existing PCRs for construction products and services from other EPD programmes?
We are verifying EPD based just on this standard (EN 15804) without supplement of any other SPECIFIC PCR. So we don´t know if there is a need to supply it with the specific PCR or not. / See answer to 01_2013
added Feb 2014: EN15804 as a voluntary standard is not substituting existing PCRs. / 02_2013 / 08/2013, amd: 02/2014
general / Is it possible to verify a Type III EPD directly to the EN 15804 standard i.e. can a verifier use EN 15804 directly where there is no Country specific PCR to verify against?
Verifiers will typically verify Type III EPD’s to the local PCR, but where these do not exist – can a verifier use EN 15804 for verification instead? / See answer to 01_2013 / 06_2013 / 08/2013
6.3.1 / 6.3.1 of EN 15804 states that “The time period over which inputs to and outputs from the system shall be accounted for is 100 years from the year for which the data set is deemed representative. A longer time period shall be used if relevant”. Does that 100 year assessment period starts from cradle, factory gate or at the end-of-life (start of landfill period)?
6.1.3.3 of EN/TR 15941 states that “Some processes have the characteristics that their environmental impact is happening over a long period (e.g. landfill). For generic data, the integral intervention of the first 100 years should be calculated and taken into consideration.”. We interpreted this as a requirement similar to other standards such as PAS 2050 (5.2 and 5.5.1) and the GHG Protocol. However, UK’s researchers at BRE note that the 100-years under question only start after the Module C and the end-of-life, they referred to clause 10.3 of EN 15978 (which states “emissions from disposal processes shall be accounted for at least 100 years;”) to prove this. However, after looking at the ILCD Handbook, by EC JRC, we appear to have a second interpretation which BRE did not reject or accept: Section 7.4.2.7.2 of the ILCD Handbook (see here) allows for a 100 years assessment period starting from Cradle and extending to beyond landfill. The ILCD Handbook also allows for another 100 years allowance period further into the landfill stage to account for any further delayed emissions or removals happening over a long period of time. In another part of the ILCD Handbook there is a statement asking for any temporary storage or emissions to be ignored as the rule “carbon storage should only be considered quantitatively if this is explicitly required to meet the needs of the goal of the study. Otherwise, i.e. per default, temporary carbon storage and the equivalent delayed emissions and delayed reuse/recycling/recovery within the first 100 years from the time of the study shall not be considered quantitatively (page 247 here)”.
We understand that a question about that statement (from 6.3.1 of EN 15804) was asked at some stage at a recent TC350/WG3 meeting by Denmark. Can someone please help us understand that statement and explain to us if the ILCD Handbook interpretation is relevant? / amended Feb 2014:
The standard does not define the assessment period of the building. However on unit process level the time period over which inputs to and outputs from the system shall be accounted for is 100 years. The years are counted from the time when the material, pre-product or product enters the relevant process (e.g. landfill). The same wording applies in EN 15978.
added Feb 2014: For carbon storage from biogenic material see EN16485 (soon to be published). / 03_2013 / 08/2013, amd: 02/2014
Indicator net use of fresh water / Indicator net use of fresh water: in several discussions in the Netherlands it is not clear how this indicator should be interpreted. What is fresh water? Is it surface water, is it tap water, ground water, industry water, …?
Differences in values occur in the EPDs. This is discussed in the Dutch SBK (who maintains the Dutch national building assessment method), MRPI (the Dutch EPD program). As the chairman of the Dutch NEN mirror committee of TC350 I would like to have this clarified. / Net Use of Fresh Water should follow the approach of ISODIS14046:2013.
Definition of Fresh Water from ISO DIS 14046:2013
Water having a low concentration of dissolved solids.
Note 1 Freshwater typically contains less than 1000 milligrams per litre of dissolved solids and is generally accepted as suitable for withdrawal and treatment to produce potable water.
Added Note 2: Moisture and crystal water in natural materials (like wood, clay, soil, etc.) is not fresh water.
Definition of drainage basin from ISO DIS 14046:2013
Area from which direct surface runoff from precipitation drains by gravity into a stream or other water body.
Added Note 1: Fossil water is ground water that has a negligible rate of natural recharge on a human timescale. Use of fossil water is considered fresh water consumption by default.
Definition of Water Use from ISO DIS 14046:2013
Use of water by human activity
Note 1 Use includes, but is not limited to, any water withdrawal, water discharge or other human activity within the drainage basin including in-stream or in situ uses such as fishing, recreation, transportation.
Definition of Water Consumption from ISO DIS 14046:2013
Water removed from but not returned to the same drainage basin (3.1.8)
Note 1 Water consumption can be because of evaporation, transpiration, product integration or discharge into a different drainage basin or the sea. Evaporation from reservoirs can be included in water consumption.
EN 15804 uses the term “net” (as opposed to gross) in relation to freshwater use, to show both:
· the intention that use of water which it is not consumed (eg. water used for river transport, used to power hydroelectric turbines or used as coolant and returned to the original source) should not be considered within the indicator.
· That water which would have been lost from the original, natural system, eg. from evaporation of rainwater or from a body or water is not considered within the losses from the studied technical system.
· Evaporated fresh water is considered consumption unless it is demonstrated otherwise.
For each process, the water flows should be identified, in terms of volume extracted, volumes discharged and the source or the destination, eg. surface water, ground water, sea water.
Where tap water (water from the public grid) is used, the water treatment and distribution system should be considered as an upstream process which will have its own resource use and discharges. Similarly, where water is discharged to the sewer, then the sewer and water treatment system should be considered as a downstream process with its own resource use and discharges.
Other water flows, for example water which evaporates or water which is incorporated into the product, should ideally be itemised in the process inventory so that a full water balance can be made.
For each process, the water consumed is the sum of the water which is lost from a drainage basin. This may be more easily calculated as the sum of water which evaporates, transpires from biomass, is incorporated into products or is discharged to a different drainage basin. This also, as mentioned, does not need to account for water which would have been lost from the drainage basin in the natural system before the technical system was implemented.
Example: Rainwater would normally be expected to drain to surface or ground water. If a factory or building is placed on the site, then water may instead be directed to the sewer and may be discharged, after treatment, to the sea, surface or ground water. Water which is diverted through the water treatment system from its original drainage basin is consumed. If rainwater is used in the building before discharging it into the sewer then this will be considered no differently than if the water was discharged directly to the sewer. However, if rainwater is used for cleaning and evaporates, then this water is consumed.
Example: For an agricultural process, water that evaporates or transpires from the plants as a result of human activity (irrigation) is considered as consumption. Water such as rainwater which evaporates or goes to the drainage basin in the same way it would if there was no agricultural process is not consumption. The assumption is that natural vegetation would have the same effect.
Example: Additional water evaporation from reservoirs and as a result of the hydrogeneration process downstream which occurs in addition to that from the original natural system will be considered water consumption.
Example: For a quarry, where dewatering takes place, if this water is returned to the same drainage basin it would naturally have drained to, then it is not consumption. If however, it is used in a process and evaporates, then it is consumption. / 05_2013 / 02/2014
Indicator exported energy / Name and description of the indicator can be confusing. Our understanding is that:
Exported energy = energy produced from waste incineration (excl. recovery) + energy produced from waste landfill, declared in C4 (EoL).
Given the following interpretation:
1 - energy produced from waste incineration
We differentiate "Exported energy" from "Materials for energy recovery" from the fact the waste does not AIM to produce/recover energy (is not destined to a storage for its upgrade). Practically, the central that incinerates the waste has a low yield (<60% and/or built before December 31st 2008).
=> to feed this indicator, we sum LHV*0.6 for each non recovered material that is incinerated.
LHV is determined by the properties of the material.
2 - energy produced from waste landfill
We consider that we speak about methanization due to (partial) decomposition of the organic mater. The energy produced by methan captation should be accounted only if the center is not dedicated to methanization.
=> excepted for putrecible mater (bioplastics? wood,), this indicator is set to zero by default.
=> for putrecible mater, the indicator is calculated based on CO and CH4 emissions due to partial decomposition. It should be determined by the properties of the material.
Do you validate this interpretation?
Do you have shared sources that must be used for material LHV and decomposition rates? / See EN15804, 7.2.5, Notes.
The indicator exported energy is described with Note 2, Note 5.
to 1 - Not agreed.
For describing the exported energy the LHV and the appropriate efficiency of incineration applies.
Exported energy produced from waste incineration or landfill is reported in the module where it occurs.
The differentiation between the indicators for materials for energy recovery and exported energy is described in EN15804, 7.2.5, NOTE 4.
to 2 – Not agreed.
In case of waste landfill material properties of the waste should be used to identify the amount of landfill gases (eg. methane) produced. National statistics or other sources should be used to calculate the amount of energy allocated to the waste.
Energy produced from waste landfill is not considered the same as energy produced from a biogas reactor. / 07_2013 / 02/2014
Indicator net use of fresh water / Name of the indicator can be confusing: do you validate that elementary flows that must be included in the calculation are only the “soft” water flows (river, ground, surface, lake)
And NOT the “salted” water flows (marine)
What about the use of “water for cooling” that can be found in LCI databases? / see answer to 05_2013 / 08_2013 / 02/2014
6.3.7 / Should EN 15804’s clause 6.3.7 use the same wording as EN 15978’s clause 10.3 to show that the 100 years relates to disposal?
Or, is it that EN 15804’s clause 6.3.7 is intended to force a fixed 100-year assessment period (as in PAS 2050)?
If a 100-year fixed assessment period is intended, would a fixed 100-year assessment period provide data suitable for use within EN 15978? Particularly, clauses 7.3 Reference study period and 7.4.5.5 Boundary for the disposal (Module C4)?
1. EN 15804
6.3.7 Data quality requirements· The time period over which inputs to and outputs from the system shall be accounted for is 100 years from the year for which the data set is deemed representative. A longer time period shall be used if relevant;
2. EN 15978
10.3 Data quality· emissions from disposal processes shall be accounted for at least 100 years;
· emissions that occur beyond 100 years should be inventoried in a dataset as separate ‘long-term’ elementary flows and included in the impact assessment if relevant; / The requirements on data quality is consistent.