AO’s Collection of environmental and sustainability related data for products and construction materials.
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As the demands on construction and civil engineering companies in Denmark continue to increase, it has now become crucial for the sale of building materials to have proper documentation in order.
AO is experiencing a significant increase in the demand for environmental and taxonomy-related documentation, which they must be able to provide in order to make sales. Therefore, AO has initiated a project aimed at collecting as much environmental and sustainability-related data as possible about the products in their range.
What do the requirements mean for suppliers and wholesalers?
It means that craftsmen and contractors could potentially avoid using products that AO distributes, as the documentation requirements in their construction projects require information that is currently not available for the product.
What environmental and sustainability related information is AO looking for?
AO is seeking a variety of environmental and sustainability related information. Initially, this can be divided into 4 categories:
EPD data about the products (Environmental Product Declarations).
The products' potential eco-labeling such as: the Nordic Swan Ecolabel, the Indoor Climate Label, the EU Ecolabel, EMICODES, etc.
The products' compliance with the DGNB system's ENV 1.2 & ENV 1.3 criteria.
Whether the products comply with the relevant EU taxonomy requirements.
This page has been prepared to guide AO's suppliers towards a better understanding of the requested data. If you need further assistance in compiling the information, we are available to help.
EPD Data
The information about the environmental impact of products is largely presented through Environmental Product Declarations (EPDs).
These are developed in collaboration with organizations such as EPD Denmark, EPD International, German IBU etc., where third-party verification is ensured. Additionally, each EPD organization places the product's environmental impact data digitally in a database. From there, the individual EPD data can be retrived digitally by AO.
AO aims to present as many EPDs as possible in their product portfolio, which means that AO tries to collect the correct link to the digital EPD.
To be able to pull the specific data about your particular product(s), AO needs to know the product's unique EPD key. This key is called UUID, which stands for "Universal Unique Identifier", and is created by the individual EPD organizations in connection with the release of the EPD.
The UUID is a 36-digit code that can look like this: 0a127f35-4f2b-47f1-ae8f-3e2533ae2510. In AO’s spreadsheet, The UUID is entered along with the product's name and the product's EAN code. This provides a full link between product and environmental data.
If your product does not have an EPD, this work can omitted."
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The UUID can be obtained by contacting either the EPD organization or the person/organization that prepared the EPD for you. Alternatively, the UUID can also be pulled through the EPD organizations' API.
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EPDs tend to be updated or changed. Therefore, AO prefers to obtain the direct link to the EPD information from the EPD organization. This saves time and energy with future maintenance and uploading of the latest EPDs.
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Yes, we are happy to help obtain the necessary UUIDs for your products' EPD. Contact us and let us know how we can assist.
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If you don't have any EPDs, you don't need to do the exercise. However, you risk that your product is already being excluded in the store by craftsmen, as it lacks the necessary documentation.
Our recommendation is to get the EPD made as soon as possible. In short, it is a crucial competitive advantage.
Eco-Label
There are a variety of eco-labels that demonstrate a product meets a set of criteria. Typically, these criteria for eco-labels include, for example, the emission of hazardous substances into indoor or outdoor air.
It is particularly certification systems such as DGNB, LEED, and BREEAM that require products to have specific eco-labels. The most common ones are: the Nordic Swan Ecolabel, the Indoor Climate Label, Blauer Engel, the EU Ecolabel, Indoor air Comfort, GUT Certification, EMICODE, and M1 classification.
The important thing about this type of labeling is that there is not yet a third-party verified database that contains the necessary documentation for the achieved eco-labels. Therefore, when submitting information to AO, the following should be included:
Which eco-label(s) the product has.
Documentation for the eco-label, either as a PDF or a link to the document.
If your product has multiple eco-labels, all these should be listed and linked to the corresponding documentation.
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In that case, enter this eco-label at the end of the tab/document, and link to the documentation.
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No problem. This information is just as useful as information about eco-labels.
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In that case, Hein would like to help you with the process in collaboration with our partners. Please feel free to contact us for a non-binding discussion about various eco-label.
DGNB ENV 1.2 information
The ENV 1.2 criterion is for many contractors and suppliers the most challenging and complex criterion in the DGNB certification. This is because it imposes a wide range of chemical restrictions on what the products may contain. There are 42 different focus points (called indicators), which set requirements for various products/building materials in construction. Additionally, there are 4 different quality levels, which dictate what the product may and may not contain. Quality level 1 is the least strict, while quality level 4 is the most strict.
The link below leads to a direct excerpt of the ENV 1.2 criterion from the DGNB manual, where one can see the requirements applicable to different types of products.
Note: the above is an snip from the Danish DGNB 2020 manual for new buildings and extensive renovations.
Which products fall under ENV 1.2?
Our recommendation is to assume, as a starting point, that all products are 'regulated' in ENV 1.2. Having said that, it primarily includes all products that people can come into contact with, or can see inside the building, under the framework requirements in ENV 1.2.
How to find out what requirements apply to my product, and whether it contains the 'prohibited' chemicals or not:
Review the ENV 1.2 table's 42 indicators to identify which indicator(s) may apply to your product(s). Here, the table's columns "product type" and "the product is used at/on" can help identify relevant indicators.
Note the indicators' identified problematic substances.
Review the product/products' safety data sheets for information on whether the harmful substance is present in the product or not. Often, the safety data sheet will not contain any information about the problematic substance if it is not present in the product/products.
If your product(s) meet the requirements for e.g. quality level 2, but not quality level 3 in the relevant indicator, your product should be noted as complying with quality level 2. If your product meets quality level 4, it automatically meets the other requirements and can be noted for complying with quality level 4.
After the product is noted for complying with the relevant quality levels, documentation for the product/products is attached. This is typically in the form of safety data sheets or similar. In certain cases, a "manufacturer's declaration" may be necessary. The manufacturer's declaration is a sworn statement that the product meets the given requirements, which the manufacturer of the product can sign.
In connection with the DGNB manual, RFBB has published the following template which can be used as a Manufacturer's Declaration. (The declaration is in Danish):
If you are still unsure whether your product complies with the relevant indicators' quality levels or not, we are happy to help you clarify the content of chemicals in your product(s).
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In this case, quality level 0 is entered as input.
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Yes, one product can be covered by multiple indicators if the product can be used in multiple places in the building. An example could be paint, which can be used both inside and outside. In this case, the product could be covered by indicators 1, 2, 5, and 21.
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It is difficult to evaluate all possible scenarios where craftsmen will be using one's product - some situations will definitely not be as intended.
Therefore, one should only relate to the indicators that cover the areas/conditions where the manufacturer has intended the product."
DGNB ENV 1.3 information
The DGNB ENV 1.3 criterion concerns the documentation that both wood and natural stone are produced responsibly.
Wood
In DGNB, points are given for wood being either FSC or PEFC certified. Non-certified wood can still be used, but it does not earn points. Additionally, many clients require certified wood. The requirements apply to both construction wood, kitchens and all other products that contain wood.
It is not sufficient to resell wood purchased as FSC or PEFC certified without being a part of these organizations. Companies must be a part of the FSC or PEFC organizations to market their products as containing FSC/PEFC certified wood. This method attempts to minimize the exploitation of FSC’s and PEFC's 'brand' to sell false goods consisting of non-certified wood. Every organization that is part of FSC or PEFC receives either an FSC Certification Code or a PEFC TM License Code. AO requests this code to ensure their suppliers are involved in promoting sustainable forestry.
FSC and PEFC use what is called a COC number. COC stands for ‘Chain of Custody’, and is a unique code created for a batch of wood harvested from a specific forest at a specific time. The code varies for each batch of wood but ensures that the wood can be traced from forest to construction site.
Therefore, deliveries to AO should include information about the wood's COC code in the products. This enables AO to continue documenting that the wood comes from sustainable forestry.
Natural stone
In the case of natural stone, DGNB requires that suppliers or manufacturers can document that the social conditions in production are in order. This is referred to as "Documented Responsible Origin." It is often taken for granted for production within the EEA's borders, but is particularly important for products coming from outside the EU.
For natural stone from non-EEA states + Switzerland, it must be documented that the requirements in ILO Convention 182 are met, and that unannounced, independent inspections are conducted in the quarries. Products with a blue label from the Stonemason Guild in Denmark, TFT Responsible Stone Programme, XertifiX, or Fair Stone labels also meet these requirements. Other labels must be specifically approved by RFBB."
The EU Taxonomy
The EU Taxonomy is a classification of the environmental sustainability of economic activities. It establishes criteria for what companies can designate as 'sustainable' and simultaneously aims to promote transparency in green investments by requiring all listed companies, loans, and bonds in the EU to be classified according to the taxonomy.
The taxonomy classifies companies' economic activities into 61 different categories, with varying requirements for the 6 different assessment points:
M1 - Climate Change Mitigation - Link to requirements
M2 - Climate Change Adaptation - Link to requirements'
M3 - Water and marine ressources
M4 - Circular Economy
M5 - Pollution Prevention
M6 - Biodiversity and ecosystems
For an economic activity to be classified as 'sustainable', the activity must achieve a "Significant Contribution to sustainability" for at least one of the 6 assessment points, and at the same time avoid being classified as causing "Do No Significant Harm" in the remaining assessment points.
Currently, only the requirement descriptions for M1 and M2 have been developed, not for the other 4. Therefore, we can only make a taxonomy assessment of economic activities on M1 and M2, while the full taxonomy assessment must wait until the requirement descriptions are ready.
Lastly, the EU taxonomy contains a "knock-out" criterion, or a prerequisite in Danish. The prerequisite is that the social conditions in the economic activity are in order and that a series of "protective" activities are carried out regularly. More on this later under "Social Minimum Standards".
Who are required to report?
As it stands, only large publicly traded companies in accounting class D with 500+ employees are required by law to report. The specific requirements for who must report are being progressively tightened. Companies in Large C accounting class must report on their 2023 fiscal year once it is completed.
However, smaller companies are not exempt from the requirements if they work for larger companies. This is because their economic activities are often considered to be part of the larger company's overall activity.
In reality, this means that a wide range of smaller companies, which perform work for larger ones, will also have part of their work covered, and therefore will experience that the larger company demands documentation for the EU taxonomy, so the larger company can meet the reporting requirements.
Therefore, AO is in the process of collecting the necessary information about the products they distribute, so that their customers, big and small, can meet the documentation burden they face.
What Documentation Should Small Companies Prepare?
The short answer is: It Depends! The challenge is that, depending on the reporting company's activities, different documentation may be required. The figure below illustrates the situation in a context for AO."
As seen from the figure, different large companies may need different documentation. Therefore, as a small business, one should investigate which taxonomy categories their customer needs to report on, and then prepare the necessary documentation. The full list of taxonomy categories can be seen in the individual requirement descriptions for both M1 Climate Change Mitigation and M2 Climate Adaptation, as shown further up.
Social Minimum Standards
OECD Due Diligence Guidance for Responsible Business Conduct (OECD RBC DD Guide) - Link
Within this, there are six different steps that employers need to perform and adhere to. They can be briefly summarized as follows:
A responsible code of conduct is incorporated into policies and governance systems in the company.
Ongoing risk analysis of critical issues in one's own business, supply chain, and other collaborations is conducted.
The company has a systematic plan to reduce risks of human rights violations, as well as how critical situations are handled.
The company performs ongoing measurement/assessment of its effectiveness with Due Diligence work. Essentially, self-monitoring of one's ongoing risk analysis and assessment.
The above-mentioned measures are reported and communicated externally.
The company establishes a whistleblower mechanism (complaint mechanism) that both internal and external parties can use.
This work may seem like an administrative burden, invented just to be a nuisance - but in the requirements lies the opportunity for employees, partners, investors, etc., to scrutinize companies for their approach to employees. Moreover, it is also an attempt on a European level to define a set of clearer requirements for how we should behave towards each other.
The actual product of the above six points can vary in size. Small businesses are not expected to produce large reports on the above requirements. Instead, it is expected that companies can document that they have addressed the requirements and conduct ongoing follow-up. (Would you do a math problem in elementary school that you didn't have to submit? No, right!)
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Yes. Going forward, there will only be a greater need to document the products used in construction, and products without documentation will be excluded, as there is no available information on whether they can be used or not.
That being said, the specific requirements are limited for each individual product, and for some products, there are no requirements at all. However, this knowledge can also make your product more likely to be chosen.
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You can find various examples online, but we are happy to present and illustrate examples of documentation in context for you.
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It depends on the number of products and the type of documentation that needs to be prepared for your products. As a starting point, it can be anything from 50,000 to 200,000 DKK depending on the missing documentation and the number of products.
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Have a conversation with your customers, or try to map the product's journey down through the supply chain, as well as the companies in the chain + the end customer. Which companies are large enough to be covered by the taxonomy.
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Currently, AO only requires their suppliers to submit documentation for the categories: 4.9, 4.16, 7.1, 7.2, 7.3, 7.4, and 7.6.
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Yes, typically they will be. However, note that the code of conduct, for example for your company, often does not present the requirements that the taxonomy asks for.
The same applies to the Code of Conduct for partners. Here it is your declaration that your partners are doing the work properly, but the EU taxonomy requires documentation that this is fulfilled.
This page has been prepared to guide AO's suppliers towards a better understanding of the requested data.
If you need further assistance in compiling the information, we are available to help.
NOTE
The Danish DGNB certification scheme is an adaption of the German, meaning there will be variations between those two.
Generel F.A.Q
Below you can find some Frequently asked questions regarding reporting to AO:
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Ask your contact in AO. What will happen is that craftsmen will avoid picking your product, as they are unable to comply with the documentation requirements related to the project they are working on.
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If your products are not approved according to the specific documentation points, you can either choose to leave the point unanswered (i.e., leave it blank) or specifically answer no.
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It varies by area:
For the EPDs, no documentation is required, only the UUID.
For the Eco-labels, documentation is required to prove that the individual eco-labels have been obtained.
For DGNB, documentation is needed that shows the given requirements in DGNB ENV 1.2 or 1.3 are met.
For the EU Taxonomy, the area is still so new that there is not yet a specific way to submit documentation that sets a precedent. Therefore, the documentation can vary significantly. It is not AO that needs to approve the documentation, but AO’s customers.