Three documents, three philosophies
| Reference | EU guidelines (2018) | DIN SPEC 91484 (DE, 2023) | XP X46-039 (FR, 2025) |
|---|---|---|---|
| Status | Voluntary guidance | Voluntary specification | Voluntary standard, backing a MANDATORY scheme |
| Core object | Waste audit content and process | Recording building products to assess reuse potential | Full mission: contract, survey method, report structure |
| Quantification | Expected, lightly specified | Product-centred recording | Explicit: appropriate unit per category, unit mass or density, total tonnage per stream |
| Report | Recommended content | Documentation templates | Normative structure (annex), down to page marking, visited and non-visited areas, deviations with justification |
| Data continuity | None specified | Feeds reuse assessments | Feeds a national platform with before and after works declarations |
Where they converge
All three agree on the spine of the exercise: survey before works, inventory of products and materials, assessment of reuse potential before waste routing, and documentation that someone else can act on. They also share a quiet assumption: an audit is only as good as the documents the client provides, starting with up-to-date drawings of the building.
Where they diverge, and why it matters
- Quantification rigor. The French standard is the only one that spells out the quantification contract: each item carries a quantity in an appropriate unit (linear metre, square metre, cubic metre or unit), and a unit mass or density turns it into tonnes per stream. This is the part that makes audit data usable downstream, and the part most audits fail.
- Mission framing. XP X46-039 also standardizes what happens before and after the survey: the documents owed by the client, independence rules, the handling of areas that could not be visited, and how deviations from the standard must be declared and justified in the report.
- Reuse lens. DIN SPEC 91484 goes deepest on the product side (what information a reuse decision needs), reflecting the German market's platform-driven approach.
What an EU harmonization is likely to retain
If the Circular Economy Act introduces a harmonized audit, the most probable shape is a synthesis: the EU guidelines' process backbone, the German attention to product-level reuse data, and the French quantification and reporting discipline, plugged into digital product passports for data continuity. Whoever already produces audits at that intersection will not need to change anything when the obligation lands. That intersection is precisely where we built our software, and why the French system is worth studying in detail: the French blueprint.