Yes to the partial revision of the Environmental Protection Act gives additional impetus to the circular economy

May 2023

The Swiss Association of Master Builders (SBC) is in favour of the adoption of the partial revision of the Environmental Protection Act, which will be dealt with by the National Council in the special session on 3 May 2023. The chosen regulatory approach consisting of a mixture of incentives, competences for regulation and promotion instruments seems to be purposeful in order to give additional impetus to the Swiss circular economy, which is already well developed today. Contractors offer numerous solutions on how excavated and spoil material can be used as high-quality recycled material in a construction project. A practicable partial revision of the Environmental Protection Act, which also pays a lot of attention to the know-how of the construction industry in the implementation process, can achieve a lot here.

Construction activity in Switzerland produces around 57 million tonnes of excavated material and 17 million tonnes of excavated material per year. The term “waste” should not be used in this context, as it tempts one to confuse the statistics with the volume of rubbish that is disposed of. Rather, this total of 74 million tonnes of material is an indication of how many tonnes of excavated and spoil material accumulates as a valuable resource, much of which can be recycled. In order to make the best possible use of this, ideal legal framework conditions are needed. Such improvements are included in the partial revision of the Environmental Protection Act, which the National Council will deal with on 3 May 2023 during the special session.

SBC already supported the goal of creating an appropriate framework in the Environmental Protection Act for a modern and environmentally friendly circular economy during the consultation process in February 2022. The chosen regulatory approach consisting of a mixture of incentives, competences for regulation and promotion instruments seems to be purposeful. However, it is important to underline that the companies in the construction industry have long since implemented many of the main concerns of the revision on a voluntary basis. In addition, important legal foundations have already been created, such as the Ordinance on the Prevention and Disposal of Waste (VVEA). This gives high priority to the avoidance, reduction and targeted recycling of waste.

Close coordination with the construction industry is important
With life-cycle-optimised buildings, resources and materials can generally be kept in circulation or recycled over several object life cycles without any loss of quality or functionality. The construction industry has already developed many innovative solutions in this regard and will continue to develop them. However, the choice of materials for building projects is made by the clients, architects and planners and not by the building contractors. It is important to convince them to integrate the circular economy at a very early stage in project development. SBC therefore appeals to these stakeholder groups and to politicians to coordinate closely with builders in the implementation of the Environmental Protection Act in order to make use of the know-how of the entire construction industry and to prevent inhibiting framework conditions or false incentives. Another key issue for the SBC is the compatibility of the Swiss Environmental Protection Act with international standards and regulatory requirements. It is explicitly important to take developments in the EU into account in order to prevent a Swiss Finish and the resulting trade barriers.

Abandonment of national limit values for grey energy
SBC suggests that national limit values for grey energy be abandoned. In practice, the correct recording of grey energy in new buildings and renovations is tantamount to a Herculean task that is likely to fail – or worse – could deliver distorting results. The end result would be a de facto ban on certain construction methods and materials, which in turn would lead to immense increases in the cost of buildings. Instead of such limit values, which are unsuitable in practice, the tendering of buildings should always be oriented towards the required or desired function and not towards specific building materials. This is determined by the demands on the building. It is important to consider not only the conservation of resources, but also overall sustainability for the environment, the economy and society.

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