position letter ecolabel for buildings-final

8/2/2019 Position Letter Ecolabel for Buildings-Final

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Dear

As World GBC Europe Network we have written this letter to the European Commission regarding the development of

the EU Ecolabel for Office Buildings. Hereby we express our concerns about both the process of the development and

the content of the EU Ecolabel which does not respond to the present market needs and reality.

The World Green Building Council is a coalition of national Green Building Councils, making it the largest international

organization influencing the green building marketplace. Its mission is to facilitate the global transformation of the

building industry towards sustainability. The European Network of the WorldGBC consists of over 32 national Green

Building Councils and represents the interests of more than 3,500 companies across Europe, including building and

construction industry, investors, suppliers and users/consumers representatives.

Regarding the project of Ecolabel for buildings, our main areas of concern are:

1. Risk of being a limited instrument, failing to encourage building performance:

The EU Ecolabel is a voluntary scheme established to encourage manufacturers of mass production and great

consumption products to generate goods and services that are environmentally friendlier. Nevertheless, each building

is a single and unique Product, submitted to specific local conditions, regulations and climate features. Its environmental

performance doesnt only depend on the features of the individual assembled elements, but mainly on the integral

approach of design, construction, operation and use conditions. This approach is not being followed in the current

Ecolabel project, which mostly looks at the Building Elements performance instead of the Buildings global performance ,

during all its life-cycle.

2. No proper harmonisation between Ecolabel and existing schemes, standards and legislation:

The World GBC European Network strongly supports solid legislation and standardization to drive improvement in thebuilding industry and to promote harmonisation of the practices and the building assessment calculation methods. The

development of initiatives and assessment labels that do not fully relate to existing standardization works distorts the

market and will be counterproductive in the harmonization process. The CEN TC 350 Standards is in our opinion the tool

to execute a harmonisation approach throughout Europe. The CEN TC 350 is also the reference standard to promote the

integration of Building life-cycle considerations as an integral part of evaluating the sustainability and impact of our built

environment, and shall be complemented by market driven mechanisms; this comprehensive approach is missing in the

current Ecolabel development. Indeed, the Ecolabel for Buildings is established without a clear global link to the CEN TC

350 standards requirements nor to the existing Directives, or rating schemes which have already market recognition, and

are more demanding and more performance oriented in terms of building Assessment.

We also draw your attention to the fact that currently we assist with a range of European financed projects (research

projects, voluntary energy or building assessment labels, new Building Directives, Standardization works) and that it may

be hard for the market to follow and understand the strategic link and correlation between all these works, some of themseeming to follow the same targets, but with no related connection. A clear and coordinated strategy at the EU level

(between all DGs) is necessary within this field to avoid duplication of efforts and unnecessary funding.

3. Promote Common indicators approach

The EU Ecolabel initiative could benefit from the use of an over-arching framework of common indicators or to recognize

bodies that are already developing that work (e.g: UNEP-SBCI, SB Alliance). This will avoid duplication of efforts, time

and costs, but assist in promoting European convergence, harmonisation, while keeping aspects of national relevance.

4. Risk of low credibility and accuracy implementation difficulties and uncompetitive awardingprocess

We state that EU market needs valuable, reliable and accurate recognition of sustainable Building. The current Ecolabel

document refers that the benchmarking will be calculated based on the energy performance of the 20% best energy

performing office building across Europe. There currently is insufficient information on the performance of new and


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existing building stocks, to accurately allow identification of the best performing buildings. The lack of clear and

harmonized indicators, verification processes and recognized assessment skills will lead to low credibility.

Please note that the EC should be cautious around the extreme responsibility that is being transferred to the national

competent bodies in terms of carrying out performance and building assessments. Some of these organisations arent

currently experts in many of the issues referred to in the Ecolabel criteria. Such an evaluation structure is a hardly

feasible challenge not only because of the necessary competence (skills are more important than the experience), but

also because of the low fee structure settled. The only way to respond to this challenge is to be based in the existing

schemes already operating in the market.

5. Availability of GBCs to discuss and strategically contribute for this matter

Some fundamental and strategic harmonisation issues should be raised and resolved before any Ecolabel development

can proceed. During the development process of the EU Ecolabel for Office Buildings, several countries have raised

similar concerns, but the response so far is still unsatisfactory. Therefore, as World GBC European Network, we would

like to express our position and availability for discussion regarding the most efficient ways to promote high performance

of buildings, while considering the overall life-cycle approaches, and following a real stream of European harmonisation

processes.

As Dutch Green Building Councilsupported by World GBC Europe Network we express our concern regardingthe existing status of Draft Criteria for awarding the EU Ecolabel for office buildings. We suggest official entities (ex.

National competent Bodies and Member State representatives) to consider the points above when expressing their vote

about this matter in 2012, and ask DG Environment and JRC to organise additional stakeholder meetings to redefine the

target and content of the EU Ecolabel for buildings. This would enable the development of a strategy that is compatible

and coordinated with other European initiatives aiming to achieve a similar goal, and really responding the current and

future market needs.

Knowing that our previous letter (as well as those from our member GBCs) didnt receive any official response from JRC

to the expressed positions, we would acknowledge any kind expression of interest from you to discuss this matter, with

more detailed material.

We look forward to meeting you.

Yours sincerely,

______________________________________ ____________________________________

Jane Henley, Paul King

CEO Chair

World Green Building Council World Green Building Council Europe Network


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