From the perspective of the industry, the revision of the EU Construction Products Regulation (EU 2024/3110) pursues important and explicitly supported objectives: further harmonisation of the European internal market, increased transparency along the value chain, and the consistent integration of sustainability, climate protection and resource efficiency in the construction sector. In particular, the extension of the basic requirements for construction works to include environmental criteria such as embodied energy, recyclability and environmental performance under AVS 3+ is expressly welcomed.
The windows and doors sector is ready to actively contribute to the achievement of these objectives. At the same time, an analysis of the current implementation mechanisms – the Digital Product Passport (DPP), the extended Declaration of Performance (DoPC) and the systems for Assessment and Verification Systems (AVS) – show that in certain areas there remains a tension between regulatory ambition and the practical reality of a sector characterised by craft-based production, SMEs and project-specific (custom-made) manufacturing. For example, only AVS 3+ allows the use of software tools to assess the performance for environmental characteristics and no other performance related essential characteristics. Against this background, this paper is intended as a constructive contribution to the dialogue with the competent regulators, with the aim of jointly developing practical, proportionate and digitally supported solutions.
For the full position, see the following link:
(c) Picture from Guillaume Périgois on Unsplash
