Getting ready for EN 15804+A2:
Getting ready for EN 15804+A2: what’s changed and how to prepare for it.
Summary of changes coming with EN 15804+A2
2. Biogenic carbon emissions and storage handling are fully revamped – for the better
3. 19 environmental impact categories and 17 other reporting categories are now required
4. All products must declare an end-of-life scenario and module D, with more complex rules
5. In addition to the new standard, also a new EN 15804+A2 compliant PCR is required
6. Data must also be available in ILCD format (but no requirement to share to third parties)
1. The EN 15804+A2 amendment and what it means for businesses
In the eight years since its inception, the standard has been amended twice. The much-needed first amendment, or EN 15804+A1, made it mandatory to apply a common set of characterisation factors, based on the so-called CML methodology developed by the University of Leiden. This ensured a reasonable level of comparability across environmental impacts in most impact categories for EPDs.
Largely owing to the quality of the standards, ISO also decided to create a mirror standard of its own for EPDs. The International Standard ISO 21930 Sustainability in buildings and civil engineering works — Core rules for environmental product declarations of construction products and services is basically mirroring the most important provisions of EN 15804+A1. But EN 15804+A2 no longer complies with ISO 21930:2017 in terms of the impact categories it reports on. This creates a potential trade barrier, unless ISO 21930 is harmonized.
“EN 15804+A2 no longer complies with ISO 21930:2017 in terms of the impact categories it reports on. This creates a potential trade barrier, unless ISO 21930 is harmonized.”
The prevalence and quality of EPDs complying with EN 15804 has not gone unnoticed on the market. All public procurement bodies in the EU and EEA are bound to use EPDs complying with this standard, and they are also recognized by LEED and BREEAM, among other market-based systems. In the North American context, the standard is sometimes used with the TRACI 2.1 impact category reporting, a methodology developed by the US Environmental Protection Agency.
However, since then, the European Commission has developed a new approach to quantifying the environmental performance of products called Product Environmental Footprint (PEF). To align the environmental reporting approaches, the European Commission issued an amendment mandate to require the revision of EN 15804 to align with the PEF methodology. The irony in this is that, unlike EPDs, the PEF methodology has not taken off on the marketplace.
However, the mandate was completed, and the result of the work is EN 15804:2012+A2:2019 Sustainability of construction works. Environmental product declarations. Core rules for the product category of construction products, or to be short, EN 15804+A2.
Amendment 2 was approved by the European Committee for Standardization (CEN) on 21 July 2019. Every organisation issuing EPDs in compliance with EN 15804 needs to get their systems and processes aligned with the amendment within three years of its issuance. Unlike with standard revisions, the old version cannot be used after this date. But until July 2022 most people are expected to continue to use EN15804+A1 based data.
“Every organisation issuing EPDs in compliance with EN 15804 needs to get their systems and processes aligned with the amendment within three years of its issuance. Unlike with standard revisions, the unamended version cannot be used after this date.”
This enables all users to be served by the same EPD that is valid 5 years from the date of publishing.
Your new EPD can be used both inside Europe (benefiting from EN 15804+A2 conformity with European regulation) as well as globally (benefiting from EN 15804+A1 conformity with ISO 21930).
2. Biogenic carbon emissions and storage handling are more transparent and fully revamped
In EN 15804+A2, the climate impact category is split into four different reported categories. The previous single Global Warming Potential category is no longer provided. The new categories are:
- Climate change – total (sum of subcategories)
- Climate change – fossil
- Climate change – biogenic
- Climate change – LULUC (land use and land use changes)
Reporting the biogenic carbon storage contained in the product and its accompanying packaging is required. However, if biogenic carbon containing materials are less than 5 % of the product and packaging mass, the reporting for the product is optional.
This basically means that your EPD has global passporting rights for its whole five-year validity.
3. Three times more impact categories, twice the fun
The EN 15804+A2 does away with the former environmental impact categories, and requires no less than 13 core environmental impact indicators to be reported, and provides 6 additional environmental impact indicators (optional for the EPD, mandatory for the project report). The North American TRACI 2.1. itself reports yet another 6 impact indicators.
All of which works out to 49 reporting categories. If that sounds like a lot, it is. The total number of reported categories is more than is needed, and all of it may not be useful, but considering the effort you put in to develop the EPDs in the first place, why take any chances of being caught short or having to redo it all in a year’s time?
4. All products must declare end of life and a more complex recycling benefits calculation is required
At the same time, the rules for calculating the benefits for module D after end-of-life is now defined in a significantly more complex manner. The new calculation rules follow the PEF methodology. The calculation rules are provided in annex D of EN 15804+A2.
The end-of-life scenarios can be a novelty and create a lot of work in documentation and declaration for manufacturers and consultants who did not have to work with them before
Each client is provided with the end-of-life templates for their sector.
5. All Product Category Rules need to be revised
Not all program operators are yet ready for this, and some have part of their PCRs based on A1 and part of them based on A2. So, which PCR should you choose for your EPD?
If you only have an A1-based PCR, you may risk having to redo your EPD sooner than you’d like. But not all product categories have an EN 15804+A2-compliant PCR available.
The approach we have chosen with the One Click LCA Pre-verified EPD Generator is to prioritize generic Product Category Rule operators with an A2-based generic PCR for all impact categories.
Such generic PCRs inevitably do not provide detailed rules for accounting use phase impacts, however, reporting those is not productive nor useful for most product categories.
6. Data must be available in International Reference Life Cycle Data System format
Is the EN15804+A2 a change for the better? And how do I deal with it in practise?
To show what the outcome looks like in practise, we created a sample EPD for Rearden Steel, a fictive Pennsylvania-based manufacturer for their new product innovation, Rearden Metal
If you have any questions, we’re happy to answer you at firstname.lastname@example.org.
How to make an EPD and how it helps your business