2023-06-28 06:30:30
On July 1, 2023, the decree implementing the PEMD diagnosis will come into force. A direct consequence of the AGEC law, this development of the current Waste Diagnosis concerns the management of products, equipment, materials and waste resulting from the demolition or significant renovation of buildings. Unlike its predecessor, the PEMD diagnosis above all makes it possible to raise the awareness of project owners regarding all the possible methods of recovery and in particular to identify the potential for reuse of building waste.
In France, the building sector emits nearly 42 million tonnes of waste each year. According to ADEME, this volume is made up of 75% inert material, 23% non-hazardous waste and 2% hazardous waste. Buildings, the leading item in terms of resource and energy consumption, have been particularly impacted by regulatory changes in recent years: LTECV, PNPD, FREC, commitments to green growth and of course the AGEC law.[1].
The impacts of the AGEC law on the construction sector
For construction, the AGEC law has at least four major consequences.
REP PMCB[2] : The EPR sector dedicated to building waste entered into force on January 1, 2023. Sorting 7 streams: Sorting of mineral fractions and plaster, in addition to the five other already mandatory streams (paper, metal, plastic, wood, glass). PEMD Diagnosis[3] : Replaces the waste diagnosis before demolition and also extends to significant building renovation operations. Estimate and waste deposit slip: Concerns sites that are not subject to the PEMD diagnosis obligation.
The four eco-organizations approved for the collection and treatment of waste within the framework of the EPR PMCB are currently in the process of setting up the territorial network of collection points.
The parallel arrival of a PEMD diagnosis extended to renovation and which takes reuse into account will therefore allow coherent management of the PWR PMCB, in a context of transition towards a circular economy.
Why a new waste diagnosis?
Article 51 of the AGEC law provided for the obligation of a diagnosis relating to the management of products, equipment, materials and waste resulting from demolition work, but also from deep renovation. Taking renovation into account is far from trivial, because it should be noted that while half of the building’s waste is generated during demolition, 38% comes from rehabilitation work, new construction representing barely 13% of this flow according to official sources.
The contours of the PEMD diagnosis have been set by several texts and in particular by decree No. 2021-821 which details both the content of the diagnosis and its form. The real “revolution” of PEMD is the official recognition of the reuse of construction waste and the need to identify what can be reused, prior to deconstruction or major rehabilitation.
In the context of the circular economy, the deployment of the PEMD therefore makes it possible to energize the reuse sectors, by the systematic identification of the potential for reuse.
In concrete terms, what does this PEMD diagnosis consist of?
Initially, the diagnosis consists of identifying the nature and quantities of waste from the site, giving priority to reuse, in accordance with the AGEC law.
What is identified as potentially reusable is then located and the state of conservation is assessed, as well as the storage, transport and removal methods.
The possibilities of reuse and the processing channels are then considered. These are both on-site and off-site reuse solutions: digital platforms, physical platforms, supply to players in the solidarity economy, etc.
What cannot be reused is then considered as waste and reuse solutions[4] are then sought.
For what is not reusable or reusable, material recovery or energy recovery solutions are then considered, with disposal only occurring as a last resort.
In concrete terms, this diagnosis gives rise to the establishment of a report and a CERFA form which are sent by the project owner to CSTB[5]the organization in charge of collecting the results.
Who is concerned by the PEMD diagnosis?
The PEMD diagnosis will involve project owners, project managers, as well as builders, promoters and building and works companies.
In demolition or significant renovation[6], the sites concerned are those whose cumulative floor area (for all the buildings on the plot) is greater than 1,000 m². However, when the plot includes buildings that have hosted an agricultural, commercial or industrial activity that has used hazardous waste, the notion of minimum surface area disappears and the PEMD diagnosis becomes mandatory in all cases.
Does the PEMD diagnosis concern you? To find out more regarding the “building waste” regulatory framework, we invite you to consult the ADEME’s OPTIGEDE circular economy and waste resource center as well as DEMOCLES platform dedicated to waste diagnostics.
[1]
LTECV: Energy transition law for green growth of 2015
PNPD: national waste prevention program
FREC: Circular economy roadmap
AGEC: Anti-waste law for a circular economy
[2] REP PMCB: Extended Producer Responsibility, for the Building Construction Products and Materials sector
[3] PEMD Diagnosis: Product Equipment Materials Waste Diagnosis
[5] Reuse is distinguished from reuse by a change of use. Example: a door can be transformed into a table. In reuse, the product at the end of its life is not considered as waste and retains the same use. Example: A door is used once more as a door.
[6] Scientific and Technical Center for Building
[7] That is to say if the renovation works concern two elements of finishing work
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