Openbare Vlaamse Afvalstoffenmaatschappij
OVAM
De OVAM spant zich dagelijks in voor een kwaliteitsvol en efficiënt afval-, materialen- en bodembeheer in Vlaanderen.
ID: 594435418712-96
Lobbying Activity
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
17 Mar 2021
The Public Waste Agency of Flanders (OVAM) underlines the importance of amending the EPBD (option 3). We agree that the EPBD should include the actions proposed in the Renovation Wave and the ambition towards building decarbonisation. However, besides a focus on the operational energy performance of buildings and decarbonization by means of improving the operational performance, we believe there is great potential in reducing the carbon impacts even further – and perhaps more efficiently and in a more sustainable way - by addressing the embodied impacts at the same time. For each (deep) renovation or new construction according to energy performance standards, materials will be required to execute these renovations. The production, transportation, etc. of these materials have also a significant impact on the environment. Therefore, OVAM advises to evaluate the whole lifecycle carbon, both direct (during a building’s operation) and indirect (embodied in the building materials), in order to achieve the most optimal solution for each renovation/new construction. This is the only way to achieve higher levels of decarbonization and avoid burden shifts from operational towards embodied impacts. The inclusion of lifecycle carbon could also provide a first step into broadening the lifecycle approach towards the inclusion of other environmental impacts, such as human toxicity, eutrophication, etc.
In addition, circularity principles such as durability, adaptability, designing for disassembly, etc. should be incorporated in the renovation and construction of buildings, as this provides the potential to even further reduce the lifecycle carbon of buildings. These circularity principles are a means to assure that the whole lifecycle carbon equivalent is effectively reduced instead of the emission merely being postponed until the next conversion of the building. Possible changes in the function of a building (caused by demographic changes for example), and providing buildings with adaptable and dismountable materials and solutions, could avoid unnecessary deconstruction of existing buildings and construction of new buildings, and thereby reduce or completely avoid environmental impacts such as carbon emissions. Furthermore, future renovation works can be executed in less time, with less waste and less use of (virgin) resources, and the life span of materials and buildings can be increased, which also means less financial impact in the long term. When taking into account multiple functions for the same building (e.g. a school during the day and a sports center in the evening and weekends), the operational energy will be reduced since only 1 building has to be heated, illuminated, etc. instead of 2.
OVAM supports the Commission’s intention to further explore Building Renovation Passports as well as Building or material passports in general. Standardized building passports could be digital, transparent datasets that describe energetic, material as well as circular aspects of the buildings. Such passports could contain data related to the quality, quantity, origin, location, environmental impact, energy performance, reversibility, disassembly, … of materials, elements and products in buildings. Such a building passport could provide for an adequate estimation of the renovation potential of buildings, as well as an evaluation of the need to either renovate or demolish. Furthermore, it could include a step-by-step renovation approach. Building passports allow an efficient repair, replacement and maintenance of buildings. A building passport could also provide the data necessary for efficient urban mining, when the building is renovated or demolished. Vice versa: it provides data regarding materials being re-used in new buildings. It enables the identification of hazardous materials, and thus also becomes a safety instrument. Lastly, building passports provide the data necessary for calculating the sustainability score of buildings.
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
18 Nov 2020
In annex the feedback of Belgium on the Inception Impact Assessment for the revision of the ELV Directive.
Read full responseResponse to Ecodesign requirements for electronic displays
18 Jan 2017
OVAM welcomes the inclusion of resource efficiency aspects in this respective ecodesign regulation, taking into account the EU action plan for the Circular Economy and the new Ecodesign working plan 2016-2019. However, OVAM would like to voice two comments regarding the exemptions formulated in the resource efficiency requirements of Annex III.
First, Annex III section 2 discusses the requirement of the marking of plastic parts heavier than 50 mg and possible exemptions. We are concerned with exemption iii, exempting plastics marking when technically not possible because of the molding method. We are not aware of any molding methods which would make marking impossible, and are therefore concerned that this exemption could create a loophole.
Second, Annex III section 2 also excludes packaging and stretch wraps. We do not understand why these two categories are exempted, and as they constitute very broad categories, this exemption could create a loophole as well.
Read full response