Building regulations (CAM) and EPD: what’s important to know

EPDs and CAMs are two different concepts that are often mistaken for one another. This is why we want to provide some clarity by offering a clear overview of the process required to meet CAM requirements.

[INDEX]

1. What are CAMS?
2. The “CAM certification” doesn’t exist (and that’s a good news)
3. CAM govern the building’s entire life cycle
4. CAM will raise the bar even further
5. CAM as part of a broader strategy
6. Beyond compliance and toward a new standard

The Minimum Environmental Criteria (CAM) are a set of performance specifications, applied across various areas, that define the requirements needed to participate in public tenders in Italy.

With the news 2023 Public Procurement Code (Legislative Decree 36/2023), their application ha become a fundamental pillar of procurement, pushing designers, companies and manufacturers to adapt in order to meet these requirements-impacting every stage of the construction process.

However, despite their growing name recognition, several aspects of CAM remain little known or are often misunderstood. They are not simply a certificate to obtain in order to appear “sustainable”: the reality is more complex.

One of the most widespread misconceptions is that compliance requires obtaining a “CAM certification”. However, this term is inaccurate: there is no official certificate by that name, because the legislation did not create a new label to be placed on products. Instead, it is based on the need to demonstrate compliance with the required criteria.

So how does one prove compliance?
Through a set of already recognized and well-established “means of proof” available on the market.

In fact, CAMs are neither unique nor static; they vary depending on the product category to which they apply. There are, for example, CAMs for energy services, furniture, catering and textile products. In this article, we focus exclusively on CAMs related to construction, which regulate the construction, renovation and maintenance of public buildings.

In this crucial area for reducing global environmental impact, product-level requirements range from recycled content to material durability and sustainability. Moreover, at the building scale, among the rewarding criteria included in CAM Edilizia, a key role is played by the use of advanced design methodologies such as Life Cycle Assessment (LCA), which allows the evaluation and optimization of environmental impact throughout the entire life cycle – from the production of materials to the end-of-life of the buildings.

Among the main means of proof requires to demonstrate compliance with CAM Edilizia are:

• Product certifications, such as ReMade in Italy or Plastica Seconda Vita (PSV),  which verify recycled material content
• Recognized environmental labels, including Environmental Product Declarations (EPDs), the EU Ecolabel, or certifications for sustainably managed wood (FSC/PEFC)
• Compliance with reference practices and techincal standards, such as UNI/PdR 88 for verifying recycled content in construction materials
• Test reports, meaning analyses and tests conducted by accredited laboratories that verify specific performance aspects, such as indoor emissions or durability

At the building scale. sustainability protocols such as LEED and BREEAM become particularly relevant, together with the use of tools like LCA (Life Cycle Assessment) and LCC (Life Cycle Costing), which allow the environmental and economic performance of a project to be measured and demonstrated objectively.

The good news is that the CAM enhance standards and tools that already exist at the national and international level. In doing so, they integrate intelligently into the market, rewarding companies that have already invested in transparency and sustainability through reliable certifications and recognized methodologies.

The most common mistake is thinking that the CAM for Construction are limited to imposing minimum percentages (such as recycled content in construction products) on materials. In reality, their scope is much broader and covers the entire life cycle of a building, from cradle to grave. This holistic approach is designed to drive and achieve specific objectives at every stage (from design to construction), introducing more:

• responsibility for the people involved
• emphasis on building quality and well-being (both in terms of context and technical performance)
• sustainability in all its dimensions, from energy efficency to material selection, considering both upstream impacts and end-of-life/reuse and recycling

In practice, the CAM focus attention on three key moments of the construction process:

1. During the design phase and material selection: mandatory criteria are required from the outset in the selection of designers, in technical design specifications and in contractual clauses. For example, the project must incorporate environmental analyses, strategies for durability, recycling, health and safety and energy efficiency.
2. During construction/execution of the works: contractual clauses must include requirements for site management, selective demolition, waste recovery (with at least 70% of non-hazardous waste to be recovered), the use of material with minimun recycled content, environmental protection measures and emission control, as well as monitoring of indoor environmental quality.
3. Demolition and end-of-life: this includes selective demolition processes, giving priority to the recovery, recycling and reuse of materials.

As already mentioned, CAM are not a static regulation, but an evolving tool designed to keep pace with technological progress and increasingly ambitious environmental goals.

Attention is now turning to the 2025 Construction CAM, which will introduce significant updates aimed at raising industry standards even further. At the time this article is being published, they are still under revision, but the changes will likely involve:

• mandatory environmental certification for construction materials
• stronger incentives for projects adopting sustainability protocols
• more stringent requirements for indoor air quality
• integration through digital tools such as BMI (Building Information Modeling) and alignment with the DNSH (Do No Significant Harm) principle

These changes may signal a shift toward greater transparency, digitalization of processes and a qualitative leap in the level of sustainability required. For companies in the sector, anticipating these trends is therefore no longer an option, but a strategic necessity.

Minimum Environmental Criteria are not an isolated rule created to make life harder for companies. On the contrary, they are the “operational arm” of a much broader European and national strategy: Green Public Procurement (GPP).

GPP is the approach through which Public Administrations use their purchasing power as a lever to steer the market toward more sustainable products and services. Instead of buying solely based on the lowest price, public bodies choose solutions that deliver environmental and social benefits, turning public spending into a driver of the ecological transition.

CAM are, in fact, the technical tool that translates this strategy into specific requirements for each sector, as defines in the National Action Plan for Green Public Procurement (PAN GPP).

Therefore, CAM for construction are much more than a simple checklist of techncal requirements for public tenders. They represent a powerful driver of change that is redefining what it means to build responsibly in Italy, pushing the entire supply chain toward higher and more sophisticated standards of sustainability, transparency and quality.

It is now more necessary than ever to align with this vision and compete effectively in a market that rewards sustainability by documenting the environmental performance of one’s products.