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Shower enclosures (under development)

EN15804 compliance

by: C Foster (cfoster) 17 May 2016, 2:52:04 PM (GMT +1)

Given that these may be considered as "construction products" will the PCR devel oper ensure compliance with EN15804: 2012 + A1:2013, and PCR 2012:01, basic module for construction products?

Re: EN15804 compliance

by: Kristian Jelse (kristianjelse) 18 May 2016, 12:58:41 PM (GMT +1)

Dear Chris,

It has not been my understanding that this is to be considered a construction product, why the PCR does not claim compliance with EN 15804. I hope the PCR moderator may provide you with some additional information about this.

If you have any references available that this product may be considered a construction product, please share this information.

Best regards,
Kristian

Re: EN15804 compliance

by: C Foster (cfoster) 18 May 2016, 6:24:57 PM (GMT +1)

Dear Kristian,

EN15804 itself offers a rather wide definition:
"item manufactured or processed for incorporation in construction works". One could read that to include shower enclosures, I guess. If I find any further, firmer information I will let you know. Best regards, Chris

Re: EN15804 compliance

by: Kristian Jelse (kristianjelse) 19 May 2016, 11:15:29 AM (GMT +1)

Dear Chris,

I agree the definition is not clear, and we are a proponent of having a shared definition used by all programme operators using EN 15804. For the definition in the International EPD System, we go back to the European construction regulation, which defines construction products as:


"construction product’ means any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works"

See a discussion in this FAQ: http://environdec.com/en/Contact/FAQ/#884

Re: EN15804 compliance

by: Kristian Jelse (kristianjelse) 19 May 2016, 11:17:09 AM (GMT +1)

Product groups that do not fall into this definition are still within the scope of the International EPD System, but they would then not refer to EN 15804.

Best regards,
Kristian

Re: EN15804 compliance

by: C Foster (cfoster) 19 May 2016, 11:49:16 AM (GMT +1)

Dear Kristian,
Reference to the Construction Products Regulation seems very sensible, but there the term "permanent" itself poses some challenges! No problem, of course, for building fabric elements like bricks. But there are many items that are not quite temporary either: floor coverings, partitions, etc. Some of these already have EN15804-compliant EPD. In the case of bathroom fittings, there are IBU EPD for "bathtubs and showers made of steel enamel and acrylic", and "sanitary ceramics" that have taken EN15804 as core PCR (http://construction-environment.com/hp11212/EPD-Overview.htm)
In practice, it would be nice that PCR for these kind of products take heed of EN15804 (for example in selection of LCIA categories and methods) even if they are not fully compliant. Then users can, if they wish, have some possibility to incorporate the indicator values into whole-building LCA.
Best regards,
Chris

Re: EN15804 compliance

by: C Foster (cfoster) 19 May 2016, 12:21:32 PM (GMT +1)

Dear Kristian, one further point on this, which perhaps tilts the balance further in favour of considering it a construction product. I understand that there is "harmonised standard" for shower enclosures - EN 14428:2015 and that a CE mark can be issued for them. Kind regards,
Chris

Re: EN15804 compliance

by: Kristian Jelse (kristianjelse) 19 May 2016, 12:51:05 PM (GMT +1)

Dear Chris,

Thank you for valuable feedback on this topic. With regards to IBU: In my understanding, they apply EN 15804 to both construction products and non-construction products that are "building-related products" as far as possible. This difference between the programmes was identified in our ongoing process of mutual recognition and has not yet been solved.

I agree that compliance as far as possible with EN 15804 would have benefits for whole-building assessment, but it makes the question of where to draw the line very difficult so that EN 15804 does not suddently applies to EPDs of all products.

Best regards,
Kristian Jelse

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