Positionspapier zum Product Environmental Footprint (PEF)

Comments of Deutsche Bauchemie on the Initial Impact Assessment ‘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 the construction sector, the assessment regarding the sustainability of alternative solutions can only be meaningfully carried out on building level and not on product level.

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. The EN 15804 was recently revised according to a mandate of the European Commission, whereby the 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 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.


Deutsche Bauchemie e.V.
Frankfurt am Main
28 August 2020