Position papers

Read the full position paper - Shaping EU legislation for building circularity

As the EU prepares its forthcoming Circular Economy Act, the debate around circular construction is gaining momentum. Yet focusing solely on secondary materials and increasing recycled content risks missing a much larger opportunity.

EU policies for circular construction should go beyond recycled-content requirements and promote a broader approach based on durability, adaptability, design for disassembly, reuse, and high-quality recycling.

A key recommendation is the consideration of Module D.1 in Whole Life Carbon assessments under the EPBD, as it captures the environmental benefits of future reuse and recycling beyond a building's lifetime. The alliance also advocates for the development of circularity criteria under the CPR, covering durability, adaptability, disassembly, reuse potential, and high-quality recycling.

Overall, METALS FOR BUILDINGS calls for EU legislation that recognizes the full life-cycle value of circular construction solutions and better supports resource efficiency, decarbonisation, and material recovery.

Read the full technical paper - Module D & circularity

Moving towards more circular buildings and construction products is essential to reduce the environmental footprint of the built environment. Today, the construction sector is responsible for approximately 40% of the total waste generated in Europe. Achieving greater circularity will not only require increasing the incorporation of recycled materials and reused products in new buildings, but also integrating circular design principles from the earliest stages of project development. Such principles can facilitate and promote high-value end-of-life scenarios, ensuring that materials and products remain in productive use for as long as possible.

Within the EN 15804 framework, Module D provides a mechanism for capturing these benefits beyond the system boundary and reflecting material value retention from a life cycle assessment (LCA) perspective. However, the calculation of Module D remains complex and is not fully prescribed by EN 15804, leading to varying interpretations and implementation approaches.

This Q&A technical paper aims to clarify the scope and purpose of Module D, review the main calculation methodologies, and provide practical recommendations from the perspective of the metals industry.

Circularity & WLC

Today, the debate on whole carbon life cycle impacts in the building sector tends to be restricted to the embodied carbon related to initial production, the operational carbon and the end-of-life impacts without considering the additional environmental benefits resulting from products and buildings designed for reuse or for recycling. It also neglects the high durability of some products which can last much longer than the reference service life of a building.

This position paper describes why carbon savings resulting from durability & end-of-life circularity should be considered in the whole life-cyle carbon assessment method to secure consistency and convergence between circularity & decarbonisation objectives. It is then essential to acknowledge design-for-reuse and design-for-recycling by integrating complementary end-of-life GHG savings into the life-cycle carbon assessment as it is considered, for metals, in the Product environmental Footprint methodology.

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Moving to a more circular and a less carbon intensive building environment are the two main challenges that are fully embraced by policy makers and the metal construction industry alike. Today, the debates on carbon impacts in the building sector tend to be restricted to the embodied carbon related to initial production and to the operational carbon related to the use-stage, which can mean that the end-of-life stage is neglected. This restrictive approach cannot properly consider the efforts made to design products for reuse or for recycling or to design buildings for adaptability, flexibility or dismantling. Hence, to avoid that the products of today become the waste of tomorrow, the metal industry recommends using a full life cycle approach as described in the attached paper.

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In EN15804 (product level) or in EN15978 (building level), Module D provides complementary information to the production stage about the additional environmental aspects resulting from reuse & recycling at the end of life stage. Hence, it is a key piece of information for the full product or building life-cycle assessment supporting an environmentally-sound circular economy in the building sector.

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Construction and Demolition Waste represents about 30% of the waste produced in Europe. Hence, developing legislation promoting good practices for this waste stream is essential. Unfortunately, there is no re-use & recycling target for Construction and Demolition Waste today, but only an overall “recovery” target. The problem with the overall recovery target is that waste that is re-used or recycled, such as metal scrap, is included along with other waste that is used for backfilling and not re-used or recycled further. As well as being unfair to metals, this overall recovery target is not supporting the circular economy as much as it could. Hence, METALS FOR BUILDINGS asks the European Commission to consider setting an overall re-use and recycling target for CDW by December 2024

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Metals contribute to the structural and functional performance of a building ensuring integrity, security and well-being for the user.

A well run Circular Economy requires the management of earth’s limited resources and their efficient use and sustainable deployment to minimise environmental impact. Using materials efficiently and productively delivers real value for society in terms of its sustainability goals. Metals used in buildings are perfectly suited for a circular economy as they can be infinitely recycled, retain value and as such are true enablers of a circular economy supporting growth, innovation, competitiveness and jobs.

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METAL FOR BUILDINGS welcomes the initiative of the European Commission and JRC to harmonise the methodology and indicators to assess the resource efficiency at building level. METALS FOR BUILDINGS has expressed recommendations int the attached position paper

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The European metals industry looks forward to an ambitious Circular Economy Package supporting growth, innovation, competitiveness and jobs. The metals industry recommendations are summarised in the attached position paper.

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Metals have already long upheld this concept since they have been efficiently and systematically recycled for many decades. After the withdrawal of the initial Commission proposal, METALS FOR BUILDINGS looks forward to a more simplified, less prescriptive and in particular a sectorial approach. METALS FOR BUILDINGS identified several issues in the previous communication and legislative proposal addressing resource efficiency in the building sector. These issues and related recommendations are detailed in the attached position paper.

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The application of general toxicity criteria within the life cycle impact assessment (LCIA) of metals, i.e. related to emissions of metal and metal compounds, currently poses significant methodological and scientific problems

With the current state of development and scientific understanding, the existing indicators for Human Health and eco-toxicity of metals are not sufficiently robust to be used in a LCIA. Today, the use of LCA-based methods to calculate biological or human health impacts of metals leads to misleading and poorly reliable information. Hence, the metals industry is strongly opposed to the use of these indicators and methods to assess the potential toxicity impact of metal emissions to the eco-system or to human health in the life cycle assessment context

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As part of the “Sustainable Buildings” initiative of the European Commission and the related public consultation, METALS FOR BUILDINGS published a position paper stressing the need to :

• Implement economic instrument to stimulate the renovation sector;
• Promote a European harmonisation of assessment methodologies and schemes;
• Consider properly the benefits of the end of life recycling of metal product from renovation and demolition sites;
• Optimise deconstruction and demolition practices in order to maximise the environmental benefits from the secondary materials resulting from such operations.

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The Roadmap to a resource efficient Europe, published in September 2011 by the European Commission stresses the need to turn waste into resource. Construction and Demolition Waste (CDW) contributes to one third of the waste generated in EU. Considering the huge Building stock in Europe, the construction sector will continue to produce significant quantity of waste from construction, renovation and demolition sites. Turning CDW, including renovation waste, into resource is then particularly relevant for Europe. These aspects should be considered in the revision of the EU waste recovery and recycling targets.