SIST-TP CEN/TR 18043:2024
(Main)Construction products - Assessment of release of dangerous substances - Pros and cons of methods for communicating the potential release of dangerous substances into soil, groundwater or surface water and indoor air
Construction products - Assessment of release of dangerous substances - Pros and cons of methods for communicating the potential release of dangerous substances into soil, groundwater or surface water and indoor air
This document describes the pros and cons for the different methods for reporting the potential release of dangerous substances into soil, groundwater or surface water and indoor air, which are:
— level (or declared values); and
— classes;
as defined in the Construction Products Regulation (CPR).
In addition, the pros and cons of additional methods based on discussion in CEN/TCs and WGs are described, which are:
— categories; and
— manufacturer’s declaration.
Bauprodukte - Bewertung der Freisetzung von gefährlichen Stoffen - Vor- und Nachteile von Verfahren zur Kommunikation der möglichen Freisetzung von gefährlichen Stoffen in den Boden, das Grund- oder Oberflächenwasser und die Innenraumluft
Produits de construction - Évaluation de l’émission de substances dangereuses - Avantages et inconvénients des méthodes de communication de l’émission potentielle de substances dangereuses dans le sol, les eaux souterraines ou les eaux de surface et dans l’air intérieur
Le présent document décrit les avantages et les inconvénients des différentes méthodes de présentation de l’émission potentielle de substances dangereuses dans le sol, les eaux souterraines ou les eaux de surface et dans l’air intérieur, qui sont les suivantes :
- le niveau (ou les valeurs déclarées) ; et
- les classes ;
tels que définis dans le Règlement sur les produits de construction (RPC).
De plus, les avantages et les inconvénients de méthodes supplémentaires basées sur les discussions des CEN/TC et des groupes de travail sont décrits, lesquelles sont :
- les catégories ; et
- la déclaration du fabricant.
Gradbeni proizvodi - Ocenjevanje sproščanja nevarnih snovi - Prednosti in slabosti metod za poročanje o morebitnem sproščanju nevarnih snovi v tla, podzemno ali površinsko vodo in notranji zrak
Ta dokument opisuje prednosti in slabosti različnih metod za poročanje o morebitnem sproščanju nevarnih snovi v tla, podzemno ali površinsko vodo in notranji zrak, in sicer:
– stopnja (deklarirane vrednosti); in
– razredi;
kot jih opredeljuje uredba o gradbenih proizvodih (CPR).
Poleg tega so opisane prednosti in slabosti dodatnih metod, ki temeljijo na razpravah odborov CEN/TC in delovnih skupin, in sicer:
– kategorije; in
– deklaracija proizvajalca.
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
01-april-2024
Gradbeni proizvodi - Ocenjevanje sproščanja nevarnih snovi - Prednosti in
slabosti metod za poročanje o morebitnem sproščanju nevarnih snovi v tla,
podzemno ali površinsko vodo in notranji zrak
Construction products - Assessment of release of dangerous substances - Pros and
cons of methods for communicating the potential release of dangerous substances into
soil, groundwater or surface water and indoor air
Bauprodukte - Bewertung der Freisetzung von gefährlichen Stoffen - Vor- und Nachteile
von Verfahren zur Kommunikation der möglichen Freisetzung von gefährlichen Stoffen in
den Boden, das Grund- oder Oberflächenwasser und die Innenraumluft
Produits de construction - Évaluation de l’émission de substances dangereuses -
Avantages et inconvénients des méthodes de communication de l’émission potentielle
de substances dangereuses dans le sol, les eaux souterraines ou les eaux de surface et
dans l’air intérieur
Ta slovenski standard je istoveten z: CEN/TR 18043:2024
ICS:
13.020.99 Drugi standardi v zvezi z Other standards related to
varstvom okolja environmental protection
91.100.01 Gradbeni materiali na Construction materials in
splošno general
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
CEN/TR 18043
TECHNICAL REPORT
RAPPORT TECHNIQUE
February 2024
TECHNISCHER REPORT
ICS 13.020.99; 13.040.20; 19.040; 91.100.01; 13.060.45
English Version
Construction products: Assessment of release of
dangerous substances - Pros and cons of methods for
communicating the potential release of dangerous
substances into soil, groundwater or surface water and
indoor air
Produits de construction: Évaluation de l'émission de Bauprodukte: Bewertung der Freisetzung von
substances dangereuses - Avantages et inconvénients gefährlichen Stoffen - Vor- und Nachteile von
des méthodes de communication de l'émission Verfahren zur Kommunikation der möglichen
potentielle de substances dangereuses dans le sol, les Freisetzung von gefährlichen Stoffen in den Boden, das
eaux souterraines ou les eaux de surface et dans l'air Grund- oder Oberflächenwasser und die Innenraumluft
intérieur
This Technical Report was approved by CEN on 5 February 2024. It has been drawn up by the Technical Committee CEN/TC 351.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2024 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 18043:2024 E
worldwide for CEN national Members.
Contents Page
European foreword . 3
Introduction . 4
4.1 Construction Products Regulation. 5
4.2 National provision/existing regulations . 6
4.3 Test data . 6
4.4 Declaration of results . 7
4.5 Interaction with other directives and regulations . 8
5.1 Horizontal test procedures . 9
5.2 Relevant scenarios . 9
5.3 Expression of test results: declared value . 9
6.1 General. 10
6.2 Unbalanced list of parameters – technical versus environmental. 10
6.3 Competition . 16
7.1 General. 16
7.2 “Level” or “declared value” . 16
7.3 “Classes” . 17
Annex A (informative) Special remarks for construction products from secondary sources . 20
Annex B (informative) Proposals for declaration of results via categories or a manufacturer’s
declaration . 21
Annex C (informative) Summary of declaration of results via categories or a manufacturer’s
declaration . 24
Annex D (informative) Example on how results of emission testing of floor covering products can
be declared in CE marking . 26
Bibliography . 29
European foreword
This document (CEN/TR 18043:2024) has been prepared by Technical Committee CEN/TC 351
“Construction products: Assessment of release of dangerous substances”, the secretariat of which is held
by NEN.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN shall not be held responsible for identifying any or all such patent rights.
This document has been prepared under a standardization request addressed to CEN by the European
Commission. The Standing Committee of the EFTA States subsequently approves these requests for its
Member States.
Any feedback and questions on this document should be directed to the users’ national standards body.
A complete listing of these bodies can be found on the CEN website.
Introduction
Since 1 July 2013, the Construction Products Regulation (CPR) is fully in force replacing the former
Construction Products Directive (CPD). The goals of the Regulation are the same as those of the Directive:
to foster the free movement and use of construction products in the internal market.
The CPR requires, inter alia, the implementation of Basic Work Requirement No 3 on Hygiene, Health and
Environment into harmonized product standards. Such requirements are not new and known to
construction products also under the former Construction Products Directive (CPD). In single countries
in Europe, manufacturers of construction products are required by law to comply with limits for the
potential release of dangerous substances. These limits are notified and therefore existing.
The implementation of BWR3 into harmonized product standards (hEN) under the CPR is very much
depending on horizontal European test standards, which are under development by CEN/TC 351. They
will replace the test procedures used by now in national regulations regarding BWR3. The horizontal test
procedures for BWR3 today are published as CEN/TSs and will be available as EN in autumn 2023. As a
result, the implementation will need to be considered in the revision of harmonized product standards.
According to Article 6 (d) of the CPR the results can be expressed by “levels”, “classes” or in a
“description”. Due to existing requirements with limit values in the Member States the expression of
results via levels or classes will result in long lists of regulated substances compared to relatively small
lists of technical parameters. The use of descriptions for the communication of results on BWR3 is
unlikely to be accepted due to the nature of existing requirements with limit values on content and
release.
The options for declaring results on BWR3 will impact the competition of construction products as not
for all materials requirements exist or are not required for regular testing in the single Member States,
and unified limits are not likely to be defined by the EC. Only in one Member State all construction
products need to be tested. Results on BWR3 are provided in all Member States in a neutral format, mostly
in form of a test report, which allow an acceptable proof of performance on one hand and
non-stigmatizing information on the other hand.
The examples in this report are based on requirements for fly ash for concrete based on preparatory work
in CEN/TC 104/WG 4 to implement BWR3 requirement for release into soil and ground into the
harmonized standard. For the communication of test results it serves as an example for all construction
products with testing needs due to existing requirements.
This report is to inform about pros and cons of communication systems as defined in the CPR by focusing
political, technical and market related aspects with political aspects covering requirements on EU and
national level, technical aspects dealing with test procedures and markets aspects dealing with fulfilling
legal requirements (parameters, test procedures) and offering materials to customers. When the single
actors (EC on CPR; CEN/TC 351 on horizontal test procedures; Member States on requirements) are
legally correct and consistent in itself, the outcome of all works will result in distortion of markets and
acceptance problems of well-known resources.
1 Scope
This document describes the pros and cons for the different methods for reporting the potential release
of dangerous substances into soil, groundwater or surface water and indoor air, which are:
— level (or declared values); and
— classes;
as defined in the Construction Products Regulation (CPR).
In addition, the pros and cons of additional methods based on discussion in CEN/TCs and WGs are
described, which are:
— categories; and
— manufacturer’s declaration.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— IEC Electropedia: available at https://www.electropedia.org/
— ISO Online browsing platform: available at https://www.iso.org/obp
4 Political aspects
4.1 Construction Products Regulation
The Construction Products Regulation’s (CPR) Basic Work Requirement 3: Hygiene, health and the
environment, states the construction works must be designed and built in such a way that they will,
throughout their life cycle, not be a threat to the hygiene or health and safety of workers, occupants or
neighbours, nor have an exceedingly high impact, over their entire life cycle, on the environmental quality
or on the climate during their construction, use and demolition, in particular as a result of any of the
following:
a) the giving-off of toxic gas;
b) the emissions of dangerous substances, volatile organic compounds (VOC), greenhouse gases or
dangerous particles into indoor or outdoor air;
c) the emission of dangerous radiation;
d) the release of dangerous substances into ground water, marine waters, surface waters or soil;
e) the release of dangerous substances into drinking water or substances which have an otherwise
negative impact on drinking water;
f) faulty discharge of waste water, emission of flue gases or faulty disposal of solid or liquid waste;
g) dampness in parts of the construction works or on surfaces within the construction works.
The CPR states further that the declaration of performance must:
— express the performance of construction products in relation to the essential characteristics of those
products in accordance with the relevant harmonized technical specifications (Article 6 Clause 1.);
— list the essential characteristics as determined in the harmonized technical specification for the
declared intended use or uses (Article 6, Clause 3 (b));
— contain, where applicable, the performance of the construction product, by levels or classes, or in a
description, if necessary based on a calculation in relation to its essential characteristics determined
in accordance with Article 3(3) (Article 6 Clause 3 (d));
— contain the performance of those essential characteristics of the construction product which are
related to the intended use or uses, taking into consideration the provisions in relation to the
intended use or uses where the manufacturer intends the product to be made available on the market
(Article 6 Clause 3 (e)).
Article 6, Clause 3(d) provides options to declare the performance of a construction by levels or classes
or in a description. The definitions are given in Article 1:
— ‘level’ means the result of the assessment of the performance of a construction product in relation to
its essential characteristics, expressed as a numerical value;
— ‘class’ means a range of levels, delimited by a minimum and a maximum value, of performance of a
construction product.
For the declaration of the performance on BWR3 ‘level’ is similar to ‘declared value‘. In both cases, with
declared values as well with classes, all parameters given in the provisions at the place of use (see
Article 6, Clause 3(e)) must be declared (see Figure 1 and Figure 2).
The third option given in the CPR to declare the results via ‘description‘ is not defined and normally only
used when no test procedures are available.
4.2 National provision/existing regulations
In single Member States there are specific regulations on the potential release of dangerous substances
into soil, groundwater or surface water and indoor air. The relevant safety levels are either laid down in
the relevant European legislation (chemicals, workers protection, environment) or in national laws
(i.e. building codes, specific requirements for construction products or materials) (see [CP-DS]). There
are only two EU countries, Germany and the Netherlands, which have notified regulations placed on the
DG GROWTH website (https://ec.europa.eu/growth/tools-databases/cp-ds/index_en.htm).
The notified regulations in the CP-DS database include the Dutch Soil Quality Decree system, which is a
statistically based system where the rate of testing is a function of the closeness of the measured values
to the regulatory limit value, and the German Administrative Provision – Technical Building Rules” which
include “Requirements on constructions regarding impact on soil and water” specifying requirements on
constructions regarding environmental protection. The German Regulation defines an evaluation based
on content and release (not a constant between different products) and the product needs to meet
defined limit values. This system is also used in other Member States. Beside parameters and limit values,
also the conformity evaluation systems in CEN Member Countries with notified regulations are
significantly different.
4.3 Test data
To be able to declare a performance for an essential characteristic test data are needed with test
procedures defined the in the harmonized product standard and listed in the Declaration of Performance.
Such testing will need to be undertaken in competent laboratories. Depending on the level of the
Assessment and Verification of Constancy of Performance (Annex V of the CPR) accreditation of the
laboratory is required.
4.4 Declaration of results
The Construction Products Regulation [EC/305/2011] defines the ways in which the manufacturer
declare performance by levels or classes. In national regulations parameters and limit values are defined
which must be met to place a product on the market. If the producer declares a value, the value will not
exceed the declared value.
If classes for dangerous substances were to be introduced, they would comprise the upper limit values
(the lower values would always be zero) agreed at the European level and if a producer declares a
particular class, the product does not exceed the limit value associated with the class. It has to be noted
that for majority of the regulated substances classes have not been defined. By this, the declaration via
“levels” or better “declared values” is the only option (see Figure 1).
Figure 1 — Example of a declaration of performance using declared values for fly ash according
to EN 450-1
NOTE Classes on release into soil and ground do not exist for construction products.
Figure 2 — Example of a declaration of performance using classes for fly ash according to
EN 450-1
4.5 Interaction with other directives and regulations
Aims for protection of health and safety of workers and of the environment are not only defined for
products but also to waste materials covered by the Waste Directive [2008/98/EC]. The Directive sets
the basic concepts and definitions related to waste management, including definitions of waste, recycling
and recovery. The use of waste materials as construction materials is practiced in the Member States
since decades and due to the new definitions for by-products and end-of-waste in the Directive are also
subject of requirements of the REACH Regulation [EC/1907/2006]. Waste management and use of
secondary material are also covered in the new Circular Economy Action Plan of the European
Commission [COM/2020/98].
The existing experiences for use of secondary materials are part of the notified regulations. At present,
the information regarding BWR3 is communicated in test reports which is considered a “neutral format”.
With the requirements for communication via levels and classes the use of such materials is possible but
will be impacted as not for all materials (natural as well as secondary) requirements exist, except in one
Member State. In addition, acceptance problems need to be considered for marketing aspects such as
serving tenders and acceptance in decision making processes at customer side as they need to check
whether declared values are fit for use in the Member State. The informative Annex A provides additional
guidance.
By this, aims defined in especially the EC Regulation on Circular Economy are counteracted. To avoid such
a situation industry proposes to express the results via “categories” or via a “manufacturers declaration”.
The informative Annex B provides additional information.
5 Technical aspects
5.1 Horizontal test procedures
CEN/TC 351 “Construction products: Assessment of release of dangerous substances” developed
Technical Specifications for harmonized test methods over the past years which are necessary for the
implementation of BWR3 into harmonized product standards (e.g. EN 450 for fly ash for concrete or
EN 13242 for aggregates for unbound and hydraulically bound materials). For the basic evaluation of
bound and unbound products three horizontal test methods are developed in the EN 16637 series.
EN 16637, Construction products: Assessment of release of dangerous substances, consists of the following
parts:
— Part 1: Guidance for the determination of leaching tests and additional testing steps;
— Part 2: Horizontal dynamic surface leaching test;
— Part 3: Horizontal up-flow percolation test.
Before the test methods could achieve the status of European Standards (EN), robustness testing and
round robin tests were necessary [Wiens et al., 2019].
Another method handles the testing of the release of volatile organic compounds into indoor air
(EN 16516). For testing radioactivity a horizontal test standard was developed and published as
CEN/TS 17216 which will become an EN after validation. Also a method on dose assessment of emitted
gamma radiation from construction product was developed and published as EN 17637.
This document does not cover fully with emission to indoor air and ionizing radiations but the declaration
methods in this document are also relevant to the declaration of performance of these emissions. An
example for declaration of results on indoor air for floor covering is given in the informative Annex D.
5.2 Relevant scenarios
To have the potential to release dangerous substances into soil, groundwater or surface water and indoor
air, the tests need to be carried out taking into consideration relevant scenarios of release. EN 16637-1
provides a guidance for selection of basic test procedures for assessment of the release of monolithic (e.g.
in concrete) and granular construction products (e.g. as aggregate for filling). Also existing requirements
indicate the test principles to be used for evaluation
With this, it has to be noted that the way of evaluation is partly based on testing constituents although
considering the final use in products. As such constituents can be used in many different products, it
makes economic sense to test the constituent in, for example, a set concrete matrix and not the numerous
concretes in which it will be used.
5.3 Expression of test results: declared value
Although the CPR provides for the declaration of the performance by level (i.e. declared value) there is
no consensus on the meaning of ‘level‘ or ‘declared value’. Some countries such as the Netherlands treat
declared values in a statistical way and the declared value is a value that is unlikely to be exceeded.
However, in other Member States, e.g. Germany, the declared value is a hard limit that must not be
exceeded. With both approaches, the manufacturer is expected to have information to justify the use of
the material in the place of use.
Where there are notified regulations, if the declared value is above the national limit value, this product
cannot be legally placed on that market. Consequently, declared values are unlikely to be above the legal
limit values for the intended markets. One established method for the assessment of the declaration by
the producer is described in detail in CEN/TR 16797.
In principle, a manufacturer is free to select the performance to be declared, but if they are placing it on
a market that has legal requirements, the product needs to comply with these requirements.
The manufacturer is also free to use the ‘No performance determined’ (NPD) option where the
performance is not subjected to a regulatory limit.
NOTE This report provides additional information neither on the value to be declared (e.g. based on statistics,
single value, limit value) nor on the number of tests needed for the evaluation. As long as the hEN do not contain
specific information the requirements from regulations at the place of use need to be considered.
6 Market related aspects
6.1 General
All construction products need to meet requirements of the CPR and by this need to be assessed for
characteristics and respective test procedures in product standards. The values are decisive for use of the
products. For the characteristics defined in the mandate and evaluated according the standards the way
to express results via declared values or classes is performed in the same way in all Member States.
However, for characteristics only briefly defined in the mandate (e.g. dangerous substances) and
considering existing requirements in single Member States the situation is different. The list of
parameters to be investigated for the evaluation of BWR3 vary from country to country. In addition, not
for all construction products test requirements exist in all Member States. In case that product follow the
“deemed to satisfy” approach due to no requirements there is no need to declare results. This leads to
unfavourable market situation for materials with testing needs and being in competition. This is
especially as under the CPR the customer needs to decide about the use of materials and needs to check
the declared values against the limit values in national regulations. Although one could consider that only
values are declared which are meeting such requirements it is an additional burden as for the competing
materials there is no need for such a list.
This is of special importance for secondary materials which are used since decades as construction
products and where environmental requirements exist for proof whether the use is lawful, i.e. the
substance or object fulfils all relevant product, environmental and health protection requirements for the
specific use and will not lead to overall adverse environmental or human health impacts (Article 5 and 6
of Waste Directive 2008/98/EC). Such requirements are not only important for evaluation of the use-
phase, but also to verify recycling options as e.g. for recycled aggregates from Construction and
Demolition Waste.
6.2 Unbalanced list of parameters – technical versus environmental
The characteristics in product standards and respective requirements are to guarantee the correct
performance of the product and later on – in case of concrete – the lifetime and durability of the buildings
or constructions. The chemical, physical and technical characteristics are basis for technical evaluation
of the product performance, the environmental characteristics are basis for the legal evaluation for use
due to content and release.
The present situation in use of construction materials is based on standards according to the Construction
Products Regulation resulting in technical characteristics in the Declaration of Performance and
additional proofs for environmental performance based on national requirem
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