LEGISLATION FANS EPDS & TM65:
The need for comprehensive data in the HVAC sector
Steve Molloy, sustainability and commercial solutions manager at Daikin off ers advice on comparing TM65 embodied carbon levels and explains why Environmental Product Declarations (EPDs) are a better way to obtain quality assured, quantifi able environmental data that considers all stages of a product’s life cycle.
Crucially, EPDs cover the
entire lifetime of the product, including both operational and embodied carbon
measurements, as well as
breaking down each stage in the product lifecycle to give a more accurate
picture of the most carbon intensive parts of the process.
C
IBSE’s TM65 is an essential – and welcome – roadmap for the construction industry’s journey towards measuring and reducing embodied carbon. However, the overall
fi gures presented by climate control manufacturers should always be interrogated to ensure full due diligence has been made into the fi gures. TM65 is a technical memorandum published by CIBSE
(Chartered Institution of Building Services Engineers) that provides a methodology for calculating the embodied carbon of building services equipment, including heating, ventilation, and air conditioning (HVAC) systems. Unlike operational carbon, that measures the emissions that occur when the building is in use, embodied carbon represents the greenhouse gas emissions associated with the manufacture, transportation, installation, maintenance, and disposal of building materials and products. Created to address the lack of standardised data and methods for calculating embodied, TM65 is a self-certifi ed and standardised approach to carbon assessments. However, the issues with taking TM65 at face-value include it being self- certifi ed and that TM65 doesn’t incorporate the operational carbon elements, meaning that it doesn’t off er a true refl ection of the whole life carbon impact. On the other hand, an Environmental Product Declaration (EPD) is a document that provides detailed and verifi ed data about the environmental impact of a product throughout its lifecycle. This includes raw material extraction, manufacturing, usage, and end-of-life disposal or recycling. EPDs are developed to international standards, such as ISO 14025 and EN 15804 in Europe. This ensures that the data is consistent, transparent, and comparable across diff erent products. More specifi cally for the HVAC sector, EPDs cover equipment like boilers, air conditioners, heat pumps, and ventilation systems. These declarations give a clear picture of a product’s carbon footprint, energy consumption, resource depletion, and emissions, that are critical metrics for assessing sustainability. Crucially, EPDs cover the entire lifetime of the product, including both operational and embodied carbon measurements, as well as breaking down each stage in the product lifecycle to give a more accurate picture of the most carbon intensive parts of
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the process. Perhaps most importantly, they are independently verifi ed for accuracy – off ering a more credible and impartial insight into the product’s true performance, compared to self- certifi ed declarations. The introduction of TM65 was a welcome development for the industry as it provided very necessary progress towards improving the sharing of data and information. However, EPDs take this further to include all carbon considerations, and, as such, are increasingly in demand – with many local authorities, including the Greater London Authority, mandating EPDs for Government funded projects. Daikin has begun to roll out EPDs on all its products. This will enable contractors and specifi ers that are tasked with managing carbon budgets to make informed decisions on where the impacts will, or in some cases will not, be spent. Ultimately, there is a place for both TM65 and EPDs in the
industry, but within the right scenarios. TM65 is ideal for when there is a requirement for a quick estimation, or for when there isn’t an EPD available. EPDs are, however, superior for comprehensive, product-specifi c environmental data comparisons, and as such, the sector must make them available where possible.
www.acr-news.com • February 2025 13
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