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SYNTHESIS IDENTIFICATION OF THE CONSTRAINTS AND LEVERS FOR THE REUSE OF CONSTRUCTION PRODUCTS AND MATERIALS April 2016 Study on behalf of the ADEME by RDC Environment, éco BTP and I Care & Consult (Mélanie Coppens, Emmanuel Jayr, Marion Burre-Espagnou et Guillaume Neveux) N° de contrat : 1506C0024 Technical Coordination : Laurent CHATEAU ADEME Angers - Circular Economy and Waste Division - Waste Identification and Management Service

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Page 1: IDENTIFICATION OF THE CONSTRAINTS AND LEVERS FOR THE REUSE …

SYNTHESIS

IDENTIFICATION OF THE CONSTRAINTS AND LEVERS FOR THE REUSE OF CONSTRUCTION PRODUCTS AND

MATERIALS

April 2016

Study on behalf of the ADEME by RDC Environment, éco BTP and I Care & Consult (Mélanie Coppens, Emmanuel Jayr, Marion Burre-Espagnou et Guillaume Neveux)

N° de contrat : 1506C0024

Technical Coordination : Laurent CHATEAU – ADEME Angers - Circular Economy and Waste Division - Waste Identification and Management Service

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QUOTATION OF THIS SYNTHESIS RDC Environment, éco BTP et I Care & Consult (Mélanie Coppens, Emmanuel Jayr, Marion Burre-Espagnou et

Guillaume Neveux) - 2016 – Identification of the contraints and levers for the reuse of construction products and

materials – Synthesis – 13 pages.

This book is available online www.ademe.fr,/mediatheque Any representation or reproduction of the contents herein, in whole or in part, without the consent of the author(s) or their assignees or successors, is illicit under the French Intellectual Property Code (article L 122-4) and constitutes an infringement of copyright subject to penal sanctions. Authorised copying (article 122-5) is restricted to copies or reproductions for private use by the copier alone, excluding collective or group use, and to short citations and analyses integrated into works of a critical, pedagogical or informational nature, subject to compliance with the stipulations of articles L 122-10 – L 122-12 incl. of the Intellectual Property Code as regards reproduction by reprographic means.

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1. Introduction

1.1. Study context The National Programme of Waste Prevention of 2014-2020 fixed wastes from building and public works as priority No. 1, with a set of 4 measures.

- Action 1 : establishment of specific awareness actions, destined for the project owners. - Action 2 : a voluntary commitment charter for the business sectors to encourage the prevention of waste. - Action 3 : identification and use of action levers to develop the reuse of materials in the building and public works sector.

- Action 4 : a review of the regulations on demolition diagnostics, and proposal of changes where appropriate. It is within the framework of Action 3 that this study takes place, on the basis of the finding of the existence of constraints in terms of the responsibility of the producers and users of reused products and materials, and of guarantees as to the quality and insurance conditions inherent in the reuse of materials and building products. These objectives are :

- to identify the constraints and levers for reuse of construction materials and products ; - to create feedback sheets on reuse cases ; - to define an action plan to lift the constraints and to activate the identified levers.

1.2. Study scope

The study focuses on the reclamation and reuse 1 of materials and construction products in the building and public

works sectors, on the basis of the following scope : - The use of a product or material for the same purpose without preparation (e.g., tile re-used in roofing material,

rubble used as fill), either on the same site or not ; - The use of a product or material for the same purpose requiring preparation or treatment (e.g., treatment in

place of asphalt aggregates, soil treatment, cutting or surfacing of cobbles or borders) ; - Divert use of a product (e.g., window used as elements of interior partitioning), either on the same site or not.

The different types of products/materials were considered :

- unsold, trading surplus (i.e., new products which have not been used), - work site surplus (i.e., unused products in their original sale format or not, e.g., remainder of 5 litre paint tins

repackaged into 20 litres), - off-cuts (e.g., plasterboard cut into 150 x 120 pieces), - removed products (e.g., metal beam, curbs).

1.3. Document content

This document comprises the summary of the Study’s final report "Freins et leviers au réemploi de produits de construction" (Constraints and levers to reuse of construction products), available at www.ademe.fr. Feedback on the building sector is available at http://optigede.ademe.fr/dechets-batiment-prevention-exemples. Feedback on the public works sector is available at http://optigede.ademe.fr/dechets-travaux-publics-prevention-exemples.

2. Study methodology The methodology consisted of three overlapping stages.

1. Reuse of existing works 2. Investigation phase :

o critical review of framework documents o collection of the opinions of key stakeholders o identification of practical reuse cases

1 Important: in the rest of this document, the use of the term "reuse" will also cover cases of divert use or use for the same purpose of

a product became waste. Similarly, the use of the term "products" will also cover the term "materials".

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3. Analysis phase : o feedback sheets o action plan

The approach was based on a literature review, workshops and telephone exchanges with key stakeholders (project owners, contractors, insurance companies, building and public works companies and organisations representing them, public authorities, etc.) and on a critical review of the framework documents (e.g., building products regulation, harmonised "product" standards, Unified Technical Documents "UTD", etc.). This methodology allowed on one hand the identification of the generic constraints and specific levers, which are analysed for the construction of the action plan and on the other hand illustration of the problem using practical cases via accessible files on the OPTIGEDE site.

3. Lessons

3.1. Lessons from practical reuse cases The investigative work helped identify 141 practical cases of reuse. In the end, 16 interesting study cases were selected and were the subject of OPTIGEDE sheets (also contained in the appendix to the final report; refer to them for the content of the projects listed below). The main findings on the basis of these 16 cases are detailed below.

Main findings of the reuse feedbacks in the building sector Finding #1 : At present, the reuse practices in the building sector are not very developed. Currently, reuse generally pertains to:

o experimental projects aimed at demonstrating the feasibility of reuse, e.g., the “Doner Skelet” project in the Netherlands, the Engineer’s House project in Loos-en-Gohelle and the Circular Pavilion.

o Projects with minor technical constraints, e.g., the kiosk at Saint-Jean en Royans, the windows for the outer façade, the gypsum partitions.

Finding #2 : reuse practices facilitated by project leaders, partners, or clients who are sensitive in this regard The reuse cases identified have been facilitated in various ways:

o product removal operations for later re-installation have been included in the specification of the design/build deal, e.g., the Engineer’s House project in Loos-en-Gohelle,

o The project owner was a self-builder (designer, client and self-builder), which allowed them to be aware of opportunities for reuse and to apply them easily, e.g., G. Studio,

o The environmentally concerned client wanting to promote reuse, e.g., reuse of plasterboard o Provision of human resources by the city, e.g., the Circular Pavilion, o This was an experimental project to demonstrate the feasibility of reuse.

Finding #3 : The qualification of reuse materials/products was not a constraint for the cases identified. The qualification was not a problem for the cases identified because :

o either the features of the materials/products did not require re-qualification, e.g., outer façade in Belgium,

o or the materials/products were re-qualified by professionals who assumed responsibility, e.g., kiosk at Saint-Jean en Royans and “Doner Skelet” project in the Netherlands

o The materials and implementation techniques used were traditional techniques, and the control office saw no valid technical reason to refuse reuse as source materials for the construction, e.g., the Circular Pavilion

Finding #4 : Acceptance of reuse solutions had little or no competitive ability compared with new materials as they allowed an "environmental" differentiation of the work. The financial aspect was not a constraint for several identified cases (Example: kiosk at St-Jean en Royans and plasterboard partitions) knowing the priority given to environmental concerns of project owners or clients. Indeed, the desire was to reuse materials instead of using new materials, even if the cost was greater.

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Finding #5 : Foreign cases can be transposed to France Cases identified outside France are transposable to France because they involve :

o either cases with minor technical constraints that are easily reproducible without special conditions: windows for the outer façade in Belgium and gypsum partitions in the United States,

o or an experimental project, e.g., the “Doner Skelet” project in the Netherlands.

Finding #6 : The distribution platforms or dedicated resource centres are having difficulties. Discussions with key stakeholders in France have shown that:

o resource centres dedicated to construction materials and products are struggling to place their products with professionals. For the managers of these structures, this mistrust is related to the ten-year warranty issue, the companies fearing that they will not be covered if they use reclaimed products. Clients are therefore private individuals (DIY, self-build).

o The platforms and resource centres struggle to offer a sufficient variety of products and quantities in line with demand because often they lack sufficient space due to the costs related to the acquisition or rental of premises.

Main findings of the reuse feedbacks in the public works sector Finding #1 : At present, the reuse practices in the public works sector are very different. Some reuse techniques have been in practice for years, mastered by the stakeholders and commonly used in construction sites as soon as the market gave the opportunity (treatment with lime or hydraulic binder for rubble). With regard to materials with high value added, such as heritage materials or mixed aggregates, reuse channels are implemented when deposits are significant (case of pavers and granite curbs for the City of Paris. However enlargement of the reuse practices with other materials faces complications, including ignorance of these practices by the stakeholders and the habits of project owners and contractors as well as a misunderstanding about the limits of reuse and the status of the material (waste or product), and the regulatory consequences and responsibilities arising from this. Finding #2 : Solutions exist to allow better penetration of on-site reuse initiatives. Facilitating reuse practices, implementing robust traceability and material compatibility tests between the transmitter site and the receiver site appear to be effective tools to combat the mistrust and create a climate of confidence enabling collaboration between stakeholders (case of the exchanging soil between work sites via the Soldating platform). Standardising reuse practices: some project owners require the project owner to use reclaimed/reused materials by writing it directly in the requirements of the specifications (case of systematic reuse of construction site rubble of the Paris Saclay site). Finding #3 : The competitiveness of the materials designated for reuse varies between sites. The availability and the price of "new" materials vary greatly from one region to the other, which may impact the competitiveness of the reuse of materials. The economic model to be put in place to allow reuse must be treated on a case by case basis and adapted to the specific conditions of the construction sites, particularly as regards transfer distances (between construction sites or between sites and storage platforms; case of exchanges between the Soldating sites at least 30 km). Finding #4 : The organisation of the order must be rethought so as to leave room for reuse initiatives. The current lock on the "resources" in the orders only allows the integration with difficulty of reuse practices in the markets. The project owner must define its programme and environmental objectives, including reclamation and reuse, which must then be translated by the project owner in the Business Consultation Documents (BCD) to enable them to propose solutions (possibly using variants) integrating reuse. The tools, recommendations and feedbacks already exist (see OPTIGEDE) but it is time to take action. All stakeholders should consider increasing their competency in the reuse subjects (awareness, training, guidance, etc.).

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3.2. Summary of the literature review Few texts take into account explicitly the reuse of construction materials and products.

Using a hierarchy that puts re-use at the forefront of the priorities of waste management, the regulation on waste prevention and management aims to encourage reuse initiatives. However, the understanding of the status of the materials (waste or product) by different stakeholders makes this encouragement theoretical. This could be improved by clarifying cases of reuse or reuse (e.g., by criteria and illustrations that would complement the note prepared by the Ecology Ministry in 2013, see Appendix 1 of the final report of this study). It could also be reinforced by an incentive or obligation by the various stakeholders concerning the building action (product manufacturer, project owner, project leader, construction company) to eco-design the products and works, and the prescription of reuse products (as for example article 79 of law No. 2015-992 on the energy transition for green growth for road works

2).

The code of public contracts and private markets standards leave the possibility to prescribe and define the specifications of materials and products of reuse as well as the modalities of their implementation.

For public works, technical documents such as product standards (or parts of standards) covering explicitly recycled materials, performance standards, technical guides, may cover aspects of fitness for the use and implementation of certain reuse materials (asphalt aggregates, aggregates, soil, etc.).

For the building, the majority of technical texts are dedicated to manufactured products and are almost non-applicable to reuse products (with the exception of the steel structure execution standard for example). Opening these documents to the definition of performance objectives and the circular economy (eco-design of parts of works, reuse, etc.) is possible on the occasion of the revision of these texts, but remains a long process based on a consensus of many stakeholders usually having divergent interests. If it were possible, a reuse specification indication in a national supplement to the referred standards would be a faster solution.

Some aspects may prove to be critical to the image for the drafting of the Construction Product Regulation (CPR) which is subject to interpretation. The affixing of the EC mark and the declaration of performance could prove a scarcely surmountable barrier. Overall, the constraints (identified) for reuse of materials and products are related to the vigilance that must accompany reuse opportunities: usability of the products, control risks of loss, health quality, etc. However, these aspects are prerequisites to the development of reuse.

2 Act No. 2015-992 of 17 August 2015 on energy transition for green growth stipulates in article 79 that "Any tender that the State or local authorities issue for the

construction or maintenance of roads shall integrate a requirement that prioritises the use of materials resulting from reclamation, reuse or waste recycling. The State and local authorities must demonstrate each year, and the State on a regional scale: 1. From 2017 on: (a) that at least 50% by volume of all materials used during the year in their road construction work sites are from reclamation, reuse or waste recycling; (b) and that, in the case of the materials used during the year in construction sites and road maintenance, at least 10% by volume of the materials used in the surface layers and at least 20% by volume of materials used in the base layers are from reclamation, reuse or waste recycling. 2. From 2020 on: (a) that at least 60 % by volume of all materials used during the year in their road construction work sites are from reclamation, reuse or waste recycling; (b) and that, for the materials used during the year in construction sites and road maintenance, at least 20% by volume of the materials used in the surface layers and at least 30% by volume of materials used in the base layers are from reclamation, reuse or waste recycling.

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3.3. Constraints All of the 23 constraints for the building and public works sector were identified during the analysis stages of the framework documents by the collection of opinions from key stakeholders and by studying reuse cases. For buildings, 14 types of constraints were identified and classified according to five categories of constraints:

Category Constraint

Technical Qualification, evaluation of the technical performance of materials and reuse products

Legal, procedures

Status of waste

Legal status of the gift, of its provision

Ten-year liability, damage to works

EC marking of reuse materials and products

"Product" warranty

Economy

Underdeveloped market, demand low

Matching supply and demand

Eligibility for financial aid

Environment, Health

Declaration of the environmental and health performance of construction products and works

Regulated dangerous substances

Indoor air quality

Stakeholders Taking account of reuse in the current operation control process

Practices on work sites

For public works, 9 types of constraints were identified and classified according to 4 categories of constraints:

Category Constraint

Legal, procedures Regulatory developments and waste status

Ten-year professional civil liability

Economics Competitiveness of reuse materials

Environment Health Definition of environmental acceptability conditions of dirt

Risk of presence of asbestos in aggregates

Stakeholders

Organisation of public and private control

Storage on site/off site

Mistrust of stakeholders with regard to reuse products

Additional nuisance to people living near a construction site

Descriptive constraint sheets have been written to identify the main information (including levers and related actions tracks). They are included in the Appendix to the final report (see §1.3). Each sheet consists of several fields :

an identification field containing the title of the constraint identified as well as the subject ;

an identification field of reuse materials and products impacted by the constraint : o type of materials/products (wood beam, steel pole, aggregate, ballast, slide, tile, window, interior door,

etc.) ; o origin of materials/products (unsold and trade surplus, offcuts and work site surplus, removal from

rehabilitation and demolition sites) ; o function in the new work (foundation and infrastructure, structure, roof, partitioning, interior joinery,

exterior joinery, insulation, floor to wall covering, sanitary equipment, electrical installation and home automation, production of heat, refrigeration and ventilation equipment, electricity generation equipment, urban furniture, networks, etc.).

a constraint characterisation field o level of recurrence of the constraint (variable, regular, systematic) ; o criticality of the constraint (low, medium, high) ; o reference texts in relation to the constraint identified.

an explanation field for the issue containing the description of the constraint identified, cases and context where the constraint was encountered.

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a field listing and defining actions to be taken : o nature of action performed: actions are grouped into 5 types of leverage actions (see § 3.3.2) ; o action description ; o ease of implementation (--/-/+/++) ; o level of impact of action to lift the constraint (+/++/+++).

It was these actions that served as a basis for the development of the action plan.

The constraint characterisation or action fields are completed in consultation with the stakeholders or, alternatively, from expert opinion.

3.4. Action plan Analysis of the identified constraints has allowed the proposition of a set of 37 actions which can be classified according to five types of leverage actions :

tools, procedures, technical texts

regulations in the technical, fiscal, legal areas

development of competencies, training, awareness-raising

support to businesses, structuring of stakeholders

exemplary (feedback, labelling, grants for actions, use of relays) They are compiled to form an action plan specifying, for each action what it consists of, the expected results, who must drive it, what are the necessary resources (financial, human, technical, etc), who can contribute to its implementation, the execution time frame (with an implementation prioritisation), the tracking indicator. This detailed action plan is appended to the final report. These actions aim to create reuse opportunities either to maintain vigilance of the technical quality of the work or of parts of the work incorporating reuse materials and products, the health performance and control of the environmental risks. These vigilance points are prerequisites for the development of reuse. These 37 actions are classified into three levels of priority: 18 actions classified as priority 1 (highest), 11 actions in priority 2 and 8 actions in priority 3 (lowest). This prioritisation is presented in the tables below.

Priority 1

Implement the necessary conditions for reuse Sector

Re-introduce reuse materials and products to the market (CPR and EC marking)

Actions 9 and 16 Building and public works

Technical vigilance (ability to use, consistent quality)

Actions 1 and 3 Building

Environmental and sanitary vigilance (content and emission of hazardous substances)

Actions 14 and 24 Building

Lifting insurance constraints (10-year warranty and damage to work)

Actions 7, 21 and 36

Building and public works

Creating opportunities

Raise concerns related to the status of waste Actions 4 and 19 Building and public works

Implement relationship with stakeholders (networks and platforms)

Actions 31 and 33 Building and public works

Provision reuse materials and products Actions 5 and 6 Building and public works

Strengthen the requirement for reuse materials and products

Form work management and project management teams

Action 22 Building and public works

Feedback, good practices Actions 37 and 32 Building

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Priority 2

Implement the necessary conditions for reuse Sector

Technical vigilance (ability to use, consistent quality)

Action 25 Building

Environmental and health vigilance (content and emission of hazardous substances), environmental performance of products

Actions 12 and 15 Building

Protection of workers Actions 27 and 34 Building

Control of the risks of loss Action 28 Public works

Lifting insurance constraints (10-year warranty and damage to work)

Action 8 Building and public works

Creating opportunities

Deposits and supply of re-usable products

Actions 17, 30 and 23

Building

Competitiveness of reuse materials and products

Action 18 Building

Priority 3

Implement the necessary conditions for reuse Sector

Technical vigilance (ability to use, consistent quality)

Action 2 Building

Control of the risks of loss Action 26 Building and public works

Lifting insurance constraints (10-year warranty and damage to work)

Action 20 Building and public works

Environmental performance of products Action 13 Building

Commercial warranty Action 29 Building

Creating opportunities

Competitiveness of reuse materials and products

Actions 10 and 11 Building and public works

Feedback, valuation of projects Action 35 Building

These actions are mainly in the building sector, no doubt because the culture of using recycled materials is more rooted in the public works sector, and a number of technical texts already exist for the use of secondary raw materials and may allow the regulation of reuse practices. Concerning the chronology of actions, it should be agreed first :

as a priority to deal with any uncertainty concerning the EC marking requirement ;

to implement, especially for the building sector, the elements necessary for framing practices (requalification of products, content and emission of hazardous substances), control of environmental risks). These aspects of vigilance are a prerequisite for the development of the reuse of construction materials and products;

and to establish a climate of trust between insurers, project owners and companies.

In a second step, it is necessary to :

create supply (list reuse opportunities and identification on sites of deposits of potentially re-usable materials and products),

rapidly develop the relationships between stakeholders (networking, WEB-based platforms) and facilitate the storage and provision of materials (territorial platforms for storage, for distribution),

and finally to strengthen the requirement by training (particularly work control and project management teams), by raising awareness (dissemination of feedback to the project owners, to project managers and to businesses) and by encouragement (e.g., the law on energy transition: obligation to prescribe reclaimed/reused materials or recycled materials for road works).

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4. General findings and prospects This study highlighted a number of findings.

The text of the Construction Product Regulation leaves uncertainty as to the obligations of EC marking for reuse products and the declaration of their performance. The majority of potentially reusable products and materials may be affected by these obligations, especially in the building and public works sectors.

Concerning the building sector, the majority of the constraints identified include reuse of materials or products resulting from a removal (demolition, maintenance, rehabilitation), in particular constraints related to fitness for use of the products, the health risks or the insurability (ten-year liability, damage to works). Problems arise mainly for construction site surpluses or unsold products (common also to removal products or construction site offcuts) in linking the stakeholders and providing the materials and products (storage or distribution platforms), as well as specifying them.

Concerning the public works sector, the reuse practices seem more developed than in the building sector. The culture of using recycled materials is probably more anchored in the public works sector, and the border between reuse and recycling is less well defined. This use of recycled materials has led the players in public works to put in place a framework for practices that can serve as a model for reuse. These are in particular technical documents such as product standards (or parts of standards) explicitly covering recycled materials, performance standards, and technical guides which include fitness for use and implementation aspects. The environmental and health aspects can also be controlled: SETRA guide on environmental acceptability of alternative materials in road techniques and its variations, detection of asbestos in asphalts, etc.

Development prospects of reuse

Public works In the short and medium term, the development of reuse in the public works sector will remain primarily on the strengthening of the requirement: a need to educate the stakeholders (including project owners) through dissemination of feedback and to train them in good practices of reuse to increase the penetration of these practices. All of the necessary conditions for reuse being more or less in place (going beyond encouragement) as was done in the case of the obligations of article 79 of Act No. 2015-992 on the energy transition for green growth

3, may encourage a

rise in the above practices in public procurement (which represents more than 50% of the public works market). For local authorithies of limited size, the issue of the necessary skills to be able to evaluate the solutions proposed by the companies, might require some guidance. Finally, some specific issues such as the geochemical compatibility of soil or the presence of asbestos in asphalt require the establishment of technical and organisational solutions in order to lift the constraints on the reuse of these materials. Nevertheless, they exceed the strict reuse framework.

3 Act No. 2015-992 of 17 August 2015 on energy transition for green growth stipulates in article 79 that "Any tender that the State or local authorities issue for the

construction or maintenance of roads shall integrate a requirement that prioritises the use of materials resulting from reclamation, reuse or waste recycling. The State and local authorities must demonstrate each year, and the State on a regional scale: 1. From 2017 on: (a) that at least 50% by volume of all materials used during the year in their road construction work sites are from reclamation, reuse or waste recycling; (b) and that, in the case of the materials used during the year in construction sites and road maintenance, at least 10% by volume of the materials used in the surface layers and at least 20% by volume of materials used in the base layers are from reclamation, reuse or waste recycling. 2. From 2020 on: (a) that at least 60 % by volume of all materials used during the year in their road construction work sites are from reclamation, reuse or waste recycling; (b) and that, for the materials used during the year in construction sites and road maintenance, at least 20% by volume of the materials used in the surface layers and at least 30% by volume of materials used in the base layers are from reclamation, reuse or waste recycling.

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Building For the building sector, the effort will be greater. Before strengthening the requirement, it is first necessary to put in place the elements needed for the reuse practices framework and to reassure stakeholders (maintaining the technical quality of works, sanitary vigilance, control of environmental hazards), and to catalogue reuse solutions and bring the stakeholders together. In the very short term, without specific guidelines on practices, reuse in the building sector will certainly remain limited to initiatives handled on a case by case basis and on uses by private individuals (experimentation, works with low constraints, uses not affecting the work’s stability and safety, self-construction, do it yourself, etc.). In the medium term, the development of repositories, guides for the re-qualification of reuse products (performance and consistency of quality) based on their uses and when necessary, specifying their implementation, will improve the control of risks of loss and will introduce a greater level of confidence: the ten-year warranty will be facilitated for businesses; reassured project owners and contractors will prescribe reused products more easily. Once the framework is in place, it will also be necessary to create the supply (list opportunities for reuse and identify deposits of reusable products), bring together the reuse stakeholders and facilitate the availability of materials and products (storage or distribution platforms). The reclaimed materials will then find their way into public or private order markets for rehabilitation operations, or even the construction of new housing or offices. These perspectives will be promoted by the emergence of eco-designed works with a view to the reasoned use of resources throughout the life cycle, based on notions of scalability and disassembly the building and promoting:

the dismantling of all or part of its components without prejudice to the maintenance of their characteristics,

its life expectancy. Such an eco-design methodology is now available at www.bazed.fr. The path is still long but the implementation of the action plan will enable the progressive and secure development of reuse.

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ABOUT ADEME

ADEME provides expertise and advisory services to

businesses, local authorities and communities,

government bodies and the public at large, to enable

them to establish and consolidate their

environmental action. As part of this work the agency

helps finance projects, from research to

implementation, in the areas of waste management,

soil conservation, energy efficiency and renewable

energy, air quality and noise abatement.

The French Environment and Energy Management

Agency (ADEME) is a public agency under the joint

authority of the Ministry of Environment, Energy and

the Sea, and the Ministry for National Education,

Higher Education and Research. The agency is

active in the implementation of public policy in the

areas of the environment, energy and sustainable

development.