Systems of performance based requirements for housing in Europe

Most West-European countries call their regulations `performance based¿ and the goals and major subjects are quite similar. A more detailed look at the formulation and content of the sets of requirements, however shows quite fundamental differences. The existence of the Construction Products Directive of the European Union and the development of Euro Codes did not have much impact on the harmonization of the technical building regulations at the level of buildings until now. Research into the differences in formulations is a first and important step towards better mutual understanding of national sets of building regulations which is essential to start a discussion of the possibilities of further harmonisation of the systems of the various countries. This paper presents the results and conclusions of a comparative study of the building regulations in Belgium, Denmark, England, France, Germany, the Netherlands, Norway and Sweden. The systems and formulations of the requirements and the contents of some subjects of requirements (for houses) have been compared in detail: stairways and ramps, fire safety, noise, daylight, accessibility and dimensions of habitable space and habitable room. We concluded that the broad spectrum of different systems forms a major barrier for further harmonisation of building regulations in Europe and even so a barrier for the realisation of an internal European Market.