During its upcoming Trialogue, the European Parliament, Commission and Council will be discussing the Construction Product Regulation (CPR). This is the EU legislation that looks to harmonise rules for construction product marketing in the European Union.
Up for discussion is a proposal that would require manufacturers of construction products to disclose only one environmental impact indicator, Global Warming Potential (GWP), on their products. It would leave it up to manufacturers whether or not to disclose any of the other 14 indicators the EU recognises.
Good intentions gone awry
Supporters of the proposal say it is meant to simplify the regulation. On the surface, that makes sense – one disclosure is indeed very simple. But if the goal is to protect consumers, it should also be effective. And one data point is not good enough.
To illustrate what consumers would be up against, let’s look at the food industry. It’s a good example because we all buy food and as consumers we benefit from the requirement that food producers disclose the same standard information on their nutrition labels. It means that no matter what product you pick up, you will see the same multiple data points, which make product comparisons easier – and thus also easier to make informed choices.
But what if food manufacturers had the same ‘simplified’ regulation offered by this CPR proposal? What if, as a substitute for overall nutrition, they were required to disclose only calories on product nutrition labels, and could add other info if they wanted to? Calories are important, but alone they don’t give us a full picture of a product’s nutrition.
Surely, many companies would choose to disclose everything even if not required. But would they all do that? And if a company chose not to disclose everything, which information would they be more likely to leave out – that which makes their product look better or worse?
And who would lose with such a “simplified” disclosure? The consumer. With no guarantee that the same information will be on all products, the consumer would not be able to consistently compare products or make the same well-informed choices as is currently possible.
This is the situation construction product consumers would face under the current Construction Product Regulation proposal.
Disclosing all 15 indicators protects consumers – and puts no extra regulatory burden on product manufacturers
No one wants the CPR to be complicated, but the impact of this proposal would not be simplification. With Global Warming Potential as the only required disclosure and an option to add others, consumers wouldn’t consistently get a full picture of a product’s sustainability. They would get what companies want them to see, either by adding in or leaving out information to influence the consumer’s perception of their product.
Global Warming Potential (like calories) is important, but the consumer would benefit from the more complete picture provided by all 15 recognised environmental impact indicators. As proposed, the CPR would, for example, deprive the consumer of valuable insights on freshwater use, ozone depletion potential or over extraction of fossil fuels.
From the perspective of product manufactures, requiring 15 indicators adds no more burden than GWP alone would. How? Because companies collect all of this information anyway to calculate GWP.
Requiring disclosure of all 15 indicators would better protect consumers, enhance transparency, and create a level playing field for manufacturers, all without creating a regulatory mess. Simple and effective.