New building regulation DM 23 June 2022

Construction represents one of the sectors with the greatest environmental impact; therefore, the Minimum Environmental Criteria set by the new decree, through the analysis of the life cycle of the building as a whole and of the individual elements that compose it, aim to orient the processes towards a circular economy.

The innovation brought by CAM concerns the evaluation of the life cycle of buildings prior to design and material choices. The new construction CAMs, in fact, encourage the use of Life Cycle Assessment (LCA) evaluation methodologies aimed at optimizing design choices for sustainability.

The topic of sustainability does not only concern design measures and energy efficiency technologies, but affects various aspects of the environmental, economic and social sphere of a product or building.

The objective is to reduce the environmental impact of buildings as much as possible by using resources in an efficient and circular way, from the composition phase to use, management and disposal or recycling, containing carbon emissions through green infrastructures and materials from eco-friendly.

With the new CAM provisions, the guidelines on minimum requirements change and are precisely defined.

CAMs are structured into 3 “macro-categories”, depending on the assignment phase:

  • Criteria for the assignment of the design service for building interventions – selection of candidates, contractual clauses, technical specifications, award criteria;
  • Criteria for the awarding of works for building interventions – contractual clauses, reward criteria;
  • Criteria for the joint assignment of design and works for building interventions – technical design specifications, contractual clauses (for the assignment of works), rewarding criteria for the recycled content present within the products.

It is also important to remember that CAM is a report and the term is an acronym for Minimum Environmental Criteria and is not a certification, just as 110% certification does not exist. Even the correct use of terminologies is in fact fundamental to better understand the legislation, how much it complies with it and what does not.

The correct definition for a construction product that complies with the regulations in force is the following: “Produced in compliance with the building regulation DM 23 June 2022, which meets the required CAM criteria.”

The formal characteristics that the recycled content certifications must possess are expressly provided for in the following sections of the CAM EDILIZIA:

  • Point 1.3.4 Verification of environmental criteria and means of proof. It contains general provisions on the means of proof, valid, applicable and superior to all other parts of the document.
  • Point 2.2.1 CAM report. It describes the content of the CAM Report that must be presented to describe, justify and prove compliance with each environmental criterion required as mandatory. Regarding the criteria on recycled content, the means of proof are reported for each material, product or packaging.

In particular, compared to what was published in the Official Journal of 06/08/2022, the only admissible certification is the EPD type III – EN ISO 14025 (or the Remade in Italy certifications, or PDR/88).

These provisions make all certifications or sworn statements definitively non-compliant that are not in conformity with what is expressed above. ISO 14021 sworn self-declarations are tolerated until expiry if drawn up before the release of the decree.

As is known, in fact, these self-declarations do not fall within the scope of certifications under accreditation (and are not creditable). Following the entry into force of the new CAMs on 4 December 2022, the construction CAMs referred to in the Ministerial Decree of 11 October 2017 were definitively repealed. In other words, the self-declarations issued by 4 December 2022 (date of entry into force of the CAM EDILIZIA) will be valid until their expiry, after which they can no longer be used as a means of testing for the recycled content during the tender.

Therefore, from 4 December 2023 self-declarations pursuant to 14021 will be definitively excluded from the scope of procurement.

Who issues these certifications?

The platforms accredited and recognized by the ministry are Epd System international, Epd Italy, Remade Italy, and bodies accredited for PDR/88.

What documentation have we produced and what are the present and future scenarios?

  • Documentation of the entire life cycle of the product was produced and proof of the declared recycled percentage was provided, through EPD.
  • The EPD certification can therefore now be used to access LEED, BREEAM, the new CAM and also abroad, as evidence of traceability and guarantee and of the Carbon footprint from the cradle to the exit gate of the factory.
  • Furthermore, in 2024, EPD certification will be preparatory to compliance with the new European regulation 305 where EPD type III environmental certification will be required. The new European regulation for reuse, reuse and recycling is expected to be released in February 2024 (and provides for the obligation to possess EPD for the export of products).

Why require all the documentation and what are the consequences if non-compliant materials are used?

Firstly because, according to article 57 of Legislative Decree 36/2023, the technical specifications and contractual clauses must be included in the project and tender documentation, and are therefore now mandatory!

In detail:

  • All bonuses in the construction sector require that the CAM for the materials used must be verified.
  • In particular, the aforementioned decrees have made their application mandatory by all contracting authorities in the design and tender documents for the new construction, renovation and maintenance of public buildings.
  • CAM compliance is in all respects mandatory in the case of tenders. The contracting authority, in the tender documents, must also provide a “Technical report and related CAM application documents”, in which the designer indicates, for each criterion, the design choices relating to the methods of application, integration of materials, components and technologies adopted , the list of graphic works, diagrams, calculation tables, lists etc. in which the pre-operam state, the planned interventions, the consequent achievable results and the post-operam state are highlighted and which highlights compliance with the criteria contained in the legal provisions.

But what should be requested from the manufacturer to verify compliance with the EPD regulations in force?

  • In the case of sandwich panels, it is of fundamental importance that a certification is presented that indicates the cumulative content of recovered, recycled material or by-products, not only of the ferrous components (steel, aluminium…) but also of the insulating core used. For example, rock wool must contain a minimum of 15% of recycled material at the source, while rigid polyurethane foam (PUR or PIR) must contain a minimum of 2% – “pre-consumer” recycled percentage. Furthermore, the materials must be indicated with their clear and complete name (for example, PU does not mean PUR but is the generic acronym for Polyurethane, so a declaration containing this definition is to be considered unreliable). A document that has a technical and legal value must precisely specify the materials to which it refers. Furthermore, in the presence of product variants (different thicknesses, models or combinations), it is necessary to indicate the percentages present in each macro type and in each layer.
  • The document presented must clearly indicate compliance with EN ISO 14025 (all previous ones, such as UNI EN ISO 14021:2016, as indicated above, will cease to be valid at the end of the deadline).
  • The documentation must also indicate the recyclability of the product at the end of its “post consumer” life.
  • Generic certifications not better specified (e.g. Product Certifications) have no validity with respect to the regulation in question.

By choosing Isolpack, in the entire range produced in our five factories, you can have the guarantee that all our products are suitable for every type of specification or tender, since they are produced in compliance with the building regulation DM 23 June 2022, which meets the CAM criteria expected as they have EPD type III certification according to EN ISO 14025.

Furthermore, they respond to many other parameters capable of maximizing 360° acceptance, such as reflectance, REACH compliance, the absence of harmful blowing agents and catalysts and many others which are clearly indicated in the reports issued.

In detail, all the macro-categories that have the EPD type III – EN ISO 14025 certification:

  • Wall sandwich panels with double steel facing sheets and insulating core in PIR or PUR foam.
  • Wall sandwich panels with double aluminium facing sheets and insulating core in PIR or PUR foam.
  • Wall sandwich panels with single steel facing sheet with insulating core in PIR or PUR foam.
  • Wall sandwich panels with single aluminium facing sheet with insulating core in PIR or PUR foam.
  • Roofing sandwich panels with double steel facing sheets and insulating core in PIR or PUR foam.
  • Roofing sandwich panels with double aluminium facing sheets and insulating core in PIR or PUR foam.
  • Roofing sandwich panels with single steel facing sheet with insulating core in PIR or PUR foam.
  • Roofing sandwich panels with single aluminium facing sheet with insulating core in PIR or PUR foam.
  • Wall sandwich panels with double steel facing sheets (standard and micro-perforated version) with insulating core in rock wool (all densities).
  • Roofing sandwich panels with double steel facing sheets (standard and micro-perforated version) with insulating core in rock wool (all densities).
  • Corrugated steel sheets.
  • Corrugated aluminium sheets.

All documentation can be consulted and downloaded from the official portal:

https://www.environdec.com/library

Which declares and formalizes the veracity of the certification and allows any comparison of environmental performances.

For each type of certificate, the English or Italian version can be downloaded from the site.