Product and Organisation Environmental Footprint (PEF and OEF)- Answer to EC consultation

While PEF is being developed by the European Commission as a useful instrument to evaluate and benchmark the environmental impacts of final products in the EU, Glass for Europe stresses, alongside Construction Products Europe, that PEF’s application to construction products would not be necessarily desirable nor useful.

In the construction sector, the final product whose environmental performance can be best assessed is the building itself rather than the myriad of individual construction products that compose it. In this respect, construction products must rather be seen as intermediary products for which PEF was not designed in the first place.

Environmental performance assessment is of high importance to the flat glass industry. Members of Glass for Europe are already editing European Product Declarations (EPD) of their flat glass products following the rules set in the European standard EN 15804. This standard, developed at EU level by CEN TC 350 is today the basis to evaluate construction product’s environmental impacts in Europe.

Glass for Europe members are in favour of a single European methodology to evaluate construction products. For this reason, Glass for Europe supports the progressive convergence of PEF and EN 15804 methodologies in the middle term.