EuroWindoor detected some discrepancies in using the test method EN 717-1. Furthermore EuroWindoor concludes the restriction and testing is only useful for products with relevant formaldehyde indoor emissions.
In the position paper EuroWindoor explains the situation for windows, doors and facades (curtain walling) and recommends to use EN 16516 instead as test method for formaldehyde and other VOC emissions from construction products. All articles without relevant formaldehyde indoor emissions like windows, doors and curtain walling should be exempted. Alternatively a list of selected products with certain impact can be fixed.
EuroWindoor Position on REACH restriction proposal on formaldehyde (September 2019)
[Here you find all position papers and publications]