18 Responsible Sourcing of Construction Products

Broken chain of custody for legally harvested timber - KBCN1321

The Government website referred to in the ‘Legally harvested and traded timber’ definition in the Responsible sourcing issue, provides the necessary guidance for demonstrating compliance with the prerequisite for this issue, which follows the Central Point of Expertise on Timber (CPET) report on the UK Government Timber Procurement Policy. The ‘Timber Procurement Advice Note (TPAN)’ provides a checklist (Annex E) for evidence of certified timber (category A evidence). You can find this here: https://www.gov.uk/government/publications/timber-procurement-advice-note-tpan-comply-with-tpp Annex F of this document gives further guidance if the supplier isn’t directly certified and there is a broken chain of custody. It notes that ‘As soon as ownership of products is taken by a non-CoC-certificate holder, the products cease to be 'certified'. However, if the evidence is credible, you can make a claim of legal or sustainably sourced products.

Design stage evidence – Responsible sourcing of construction products assessment - KBCN0831

At design stage, a letter of commitment from the design team confirming that the products shall be procured from suppliers capable of supplying products covered by the required responsible sourcing certification scheme is acceptable. The letter must confirm the responsible sourcing certification schemes of the proposed products.

Early product procurement policy - KBCN1309

A documented product procurement policy and procedure needs to be in place by RIBA stage 2, which sets out the requirements for all suppliers and trades to adhere to in relation to responsible sourcing of products. However, this policy and procedure can be fairly high-level at RIBA stage 2, as long as all other criteria are met, including dissemination and the encouragement of products that have responsible sourcing certification over products that don’t. At this early stage, the policy is likely to contain overarching principles and policies that later feed into a more detailed plan or strategy, further into the design stage. BS8903:2010 and BS8900-1:2013, provide guidance on what is considered good practice. Our experience with BREEAM has shown that considering the potential for responsibly sourced products early on makes procurement of these products more achievable, which in turn makes the associated credits for this more likely to achieve. This principal extends to the other issues in the Materials category as well.

Evidence requirements – responsible sourcing of materials at post-construction - KBCN1599

Whilst the UK BREEAM manuals are less prescriptive in the evidential requirements to allow flexibility, to ensure consistency across the schemes, it is expected that robust evidence should be provided to verify the source of any certified materials and how the assessor has confirmed the products and manufacturers used. Evidence supplied at post construction stage must reflect the completed building and confirm the responsibly sourced materials that have been procured and installed on the project. Supporting documentation is required to validate letters of confirmation or schedules of materials. Evidence provided could include proof of purchase, for example, invoices, delivery tickets, purchase orders or correspondence from suppliers. This may be an example for each material sourced, rather than every delivery ticket for instance. Alternatively, evidence of the use of the responsibly sourced materials may include as-built drawings, O&M documentation or site photographs.

FSC and PEFC Mixed Sources certified timber - KBCN00091

Products labelled:

FSC Mix or
PEFC Mixed Sources

Meet the BREEAM responsible sourcing requirements. This means any such products:

In HQM, and in BREEAM NC 2016 or older schemes: meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: meet the prerequisite for legal and sustainable timber.
In all schemes: can be used to demonstrate responsible sourcing.

Products carrying the FSC Mix label contain at least 70% FSC certified and recycled material. These products may contain a small proportion of FSC Controlled Wood (KBCN00054). However for BREEAM compliance, the FSC Mix label is sufficient to meet our requirements.

14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

FSC Controlled Wood - KBCN00054

The FSC Controlled Wood label minimises the risk that wood comes from illegal or controversial sources, however it does not eliminate this risk. Therefore, products which are:

Labelled as FSC Controlled Wood or,
Where the majority of material in a product is comprised of FSC Controlled Wood,

Do not meet the BREEAM definition of responsibly sourced. Where FSC Mix labelled products contain FSC Controlled Wood, see KBCN00091. This means that any such products:

In HQM, and in BREEAM NC 2016 or older schemes: do not meet the prerequisite for legally harvested and traded timber.
In BREEAM NC 2018 or newer schemes: do not meet the prerequisite for legal and sustainable timber.
In all schemes: cannot be used to demonstrate responsible sourcing.

14-Mar-2024 - Wording clarified and expanded. Relevant prerequisites and requirements clarified. Scheme applicability updated.

Product procurement policy after RIBA stage 2 - KBCN0994

Where a product procurement policy is put together at a later stage than RIBA stage 2, ‘02 Product procurement policy and product environmental information’ credits may still be achievable. If it can be confirmed by the person responsible for the policy that the policy will not restrict procurement of responsible sourced construction products due to its late production and implementation, then the credits can still be awarded (provided all other compliance requirements are met).

Raised access floors - KBCN00018

For the purposes of Mat 03, raised access floors should be considered as part of the floor structure. HQM - Applies to HQM's Responsible Sourcing of Construction Products assessment issue.

Responsible sourcing certification – validity - KBCN1693

Where it can be demonstrated that the responsible sourcing certificates were valid either at the time of specification, or at the time of purchase, they may contribute to the awarding of the credits. BREEAM is primarily trying to encourage designers to take responsible sourcing into consideration when specifying or selecting products and as such it is not necessary for certification to be valid at the time of design or post-construction stage submissions.

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