Digitization and the revision of the Construction Products Regulation
Aitor Aragón
Standards applied to the digital and green transitions of the construction industry - A tall hobbit
The revision
The Regulation (EU) 305/2011 of construction products (CPR), one of the most important pieces of legislation for the building and civil engineering industry, is currently under revision. In March, the Commission presented a proposal for a new Regulation and launched a public consultation process, that ended in July. This previous post summarised the comments received during the public consultation.
In this article, I draft a summary about digitization for construction materials covered by the CPR, in relation with current trends in industry, like BIM or the Smart CE concept.
Digitization of construction products performance
The new CPR aims to make construction industry contribute to the digital and ecological transition, and promote efficiency in the value chain. Whereas (4) states: It is necessary to establish well-functioning information flows, including via electronic means, to ensure that coherent and transparent information about construction products performances is available along the supply chain.
The significant cost reduction for manufacturers (and the rest of the actors in the construction value chain) obtained by the application of an electronic Declaration of Performance (DoP) was reflected in the report made by the European Parliament for the revision of the CPR:
The volume of product information that has to be communicated to users in accordance with the CPR will in all likelihood increase, especially in the light of sustainability and environmental requirements. Therefore, it is to be expected that the product information can no longer be fully reflected in the CE marking on the product. (...) IT-based methods should be used in order to render the communication between actors within the supply chain more efficient. In this way, the Rapporteur views concepts and methods such as Blockchain and Smart DOP as indispensable developments that should be incorporated into a revised CPR.
The idea behind the Smart DoP referenced in the report above is similar to the Smart CE concept defined by Construction Products Europe aisbl in the document Towards smart CE marking, published in 2015, which proposed an XML-based format for the DoP data.
The Smart CE concept was transformed by CEN and CENELEC in a standardisation document in 2018: CWA 17316.
The Smart CE format was based on International and European BIM standards, such as EN ISO 23387.
UNE - Asociación Española de Normalización published, in 2020, the Spanish standard for the Smart CE concept: UNE 41316. This national standard is not just a translation of the CWA, as it contains non-contradictory clarifications for the XML structure and defines how to communicate additional data (information not included in the harmonised standards, i.e. which can't be included in the DoP). This approach was also intended to be used for the XML structure of construction products not covered by European harmonized standards.
The proposed revision of the CPR contains new environmental parameters, which will be included in the DoP. It will be possible to include a link to a external URL containing the Environmental Product Declaration (EPD), as this information is complex and declared with life cycle modules. It is not defined if the LCA will be made based on the standard EN 15804 or the Product Environmental Footprint (PEF) methodology. More information about this parameters can be found in this article.
The digitization of environmental information will also be required by policies such as circular economy and climate neutrality, included in the EU Green Deal. The proposal of Sustainable products initiative (SPI), defines a digital product passport. It does not cover construction products, except those energy-related, as explained in this article, but the EU product database mentioned below makes reference to this concept.
Digital data of environmental performance will promote a more efficient use of resources considering a life cycle assessment, can reduce the need of packaging or printed accompanying documents and will provide meaningful information for the use, maintenance and deconstruction of the asset, once included in a Digital Building Logbook.
ISO - International Organization for Standardization published, in 2022, a standard defining the data templates for EPDs: ISO 22057. This standard contains and informative annex with the Smart CE format for EPD data. More information, in this article.
It is clear that a data template for this complex product performance data will be needed. Different implementations, based on a GUID identification or by other means. Smart CE is just one of the possible implementations of these data templates, with the advantages of having a published standard. More information about the Smart CE concept can be found in this article, published in the Spanish Journal of BIM: Reliable communication of product performance information in the BIM value chain: Smart CE marking. A summary, in Spanish, can be found below.
Product EU database
Article 78.1 includes a potential mandatory database or system, in which manufacturers will be required to upload data:
The Commission is empowered to supplement this Regulation (...) by setting up a Union construction products database or system that builds to the extent possible on the Digital Product Passport
A central database raises concerns about ownership, maintenance and accountability, and also the potential additional burden for manufacturers. It is not clear (for me) if this data will be publicly accesible and searchable or only for certain economic operators, with a data carrier which allows a controlled access. If accesible, even if not intended to be searched, this data can be scraped and used in applications not intended or approved by the manufacturer, nor required under the new CPR. This applications can be beneficial for all actors in the value chain, but the use should be approved, after a proper assessment made by the owner of the data: the manufacturer.
In addition, this system should be compatible with other EU databases, like SCIP (substances of concern) or EPREL (energy labelling).
In addition to a centralized database, other options can be considered:
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It should be noted that the actual function of the product in the construction asset has a very important role in its sustainability assessment. A direct comparison, without a defined functional unit, can mislead the user of the information and lead to a less sustainable solution. Thus, direct comparison of individual data without a context and appropriate criteria should be avoided. Standards, such as EN 15804, provide rules and criteria for comparison.
Procurement, Building Digital Loogbook and other uses
The performance included in the Declaration of Performance of construction products constitutes the basis of public and private procurement for built assets (buildings or civil engineering works). The characteristics contained are also very important for BIM or digital twin models. Those topics are of high interest for stakeholders in surveys included in the report Digitalisation in the construction sector, published by the ECSO in 2021.
Figure 1. Most relevant digital technologies EU policy intervention should focus. Source: ECSO survey, 2020.
The information of installed products and materials will allow the use of software tools to model energy performance or LCA-based potential impacts identification for construction assets, thus improving the environmental performance. The information about recycle content, recyclability or durability will promote a more circular approach, starting from the design of the building or the civil engineering works. These software tools are necessary for complex assessment at building level, such as EN 15978 or LEVEL(s).
Conclusions
The digitization of product information will promote efficiency in the construction value chain and reduce the environmental impacts of buildings and civil engineering works in their life cycle.
The new CPR (and the SPI) includes requirements and provision to promote a digital product passport and a database to store this data. A standardized format (like Smart CE marking) will be needed to ensure compatibility.
We currently have standards for these formats and the management data, like EN ISO 23387 (under revision) and UNE 41316 for data templates, EN ISO 22057 for EPD data, and EN ISO 19650 series for information management.
New standards will be required to properly implement digitization in the construction products value chain. For its development, CEN/TC 442 BIM and digital twins will be a key standardisation committee.
Related information
The following article discusses how environmental benefits are dealt with in the proposed revision of the CPR.
Current situation is explained in the following article.
Article about the standard UNE 41316 Smart CE in the magazine of UNE (also available in English).
Article about Smart CE in the Spanish Journal of BIM.
Article about standards supporting BIM implementation in the magazine of UNE.
Social strategist, technical writer and facilitator at Just Practising Limited
2yThank you for this detailed and informative analysis Aitor Aragón . The foundations of a digital infrastructure for construction products need to be developed collaboratively, and with the manufacturer in mind as well as other stakeholders. It is good to see the EU community working in this way, and I hope the UK standards community and manufacturing sector participates and signs up to a genuinely European wide approach. Construction Products Association
Head of Digital & ICT @ TROJENA | Digital Strategy, Data, AI, Cognitive
2yproud, I was able to chair the CEN Workshop agreement work and development of SmartCE Marking #SmartCE #standards #CRP