METALS FOR BUILDINGS
METALS FOR BUILDINGS
METALS FOR BUILDINGS is the alliance of European Metals Associations active in the building sector that promotes the unique strengths of metal products for recyclable and sustainable buildings.
ID: 84976288959-87
Lobbying Activity
Response to Initiative on EU taxonomy - environmental objective
3 May 2023
METALS FOR BUILDINGS response - Date 3 May 2023 Delegated Act: Taxonomy Environmental Delegated Act - Circular economy Annex II to Environmental Delegated Act (CE) METALS FOR BUILDINGS alliance recommends the following adaptations or additions regarding the technical criteria for Substantial Contribution to the transition to a circular economy related to the Construction of new buildings (Annex II - pages 33-34). Technical screening criteria number 3 (page 33, Annex II) Construction designs and techniques support circularity via the incorporation of concepts for design for adaptability and deconstruction as outlined in Level(s) indicators 2.3 and 2.4 compliance should be linked to a specific target. The provided references are only assessment methods. Therefore, there is not any threshold to comply despite design for adaptability and deconstruction are the most relevant aspect for the transition to a circular economy Technical screening criteria number 4 is inadequate and is discriminating towards metals. Metals are indeed already the most circular materials in the building sectors as reflected by high end of life recycling rates which provide already today significant sourcing fraction of metals issued from scrap. However, setting a much higher recycled content target for metals compared to other materials (which are today much less recycled) risks to exclude metals from the list of major materials effectively used, reducing drastically the circular character of the building. Hence, as an alternative method, METALS FOR BUILDINGS recommends setting an overall target recycled content for the whole bill of materials (BOM) of the building, possible applying a cut of rule for the materials contributing for a small part of the mass of the building. Hence, for example, this criterion could be that 40% or 50% of the bill of materials of the buildings comes from recycled materials. Each material could then contribute to reach this overall target. This type of generic target would secure a fairer level playing field and will generate buildings which are more circular. Additionally to criterion 3, it is also essential to add specific criteria addressing the reusability and recyclability of the building products/materials. It is indeed essential to secure that the building of today does not become the waste of tomorrow. This criterion should reflect the quantity and quality of products/materials which are indeed reused or recycled based on end-of-life scenarios reflecting current practices. In particular, a specific recycling target should be restricted to high quality recycling where the properties of recycled materials are equivalent to the primary materials. These end-of-life criteria/targets addressing the whole bill of materials (BOM) should be subdivided as follow (reported percentages are possible targets to be refined) : - Percentage target of materials/products which are reused, e.g. possibly 10% as reuse target for the full BOM of the building. - Percentage target of materials which are recycled with equivalent properties as primary materials, e.g. possibly 70% as recycling target for the full BOM. - Percentage target of materials which are downcycled or recovered (e.g. backfilling or energy recovery), e.g. possibly 15% as recovery target for the full BOM. These additional criteria will secure that the circularity principle is not only addressed from the production stage but also from the end of life stage, maximizing a more robust circularity based on a whole life cycle perspective.
Read full responseMeeting with Radan Kanev (Member of the European Parliament, Rapporteur for opinion) and The Chemours Company
1 Apr 2022 · EPBD