The Commission proposal for new regulation replacing the Ecodesign Directive includes many positive changes which EuroWindoor supports. To reduce the negative life cycle environmental impacts of products the Environmental Sustainability addresses green transition of the manufacturing processes, overall sustainability of the built environment and efficient use of natural resources by facilitating reuse and recycling.
EuroWindoor supports the aim of the ESPR making sustainable products the norm while at the same time strengthening a level playing field with a fair and smooth functioning internal market. However, EuroWindoor stresses the importance of ensuring a close coordination and alignment between the ESPR and those other legislative initiatives under development/revision all affecting the building sector (e.g. CPR, EED, EPBD, ...) to prevent from overlapping and overregulation. To avoid unnecessary costs and burdens associated with requirements on products and their value chain EuroWindoor underlines the importance of involving all relevant actors – including industry and Member States in the development and implementation of such product specific regulations.
EuroWindoor sees it very positive that requirements will continue to be set on a product-by-product basis taking into account individual specificities and characteristics of the different products. Especially windows are very complex and individual products therefore a differentiation on a product by product based on scientific assessment methods through recognised European and International standards is vital for a functioning market.
In contrast to this EuroWindoor does not support classes of performance labels (traffic light) on construction products as such a label could easily be misleading which is the same with benchmarking on simple environmental aspects such as recycled content. Only a single CE marking should be required for products giving the information on the performance of construction products.
For further information please see:
EuroWindoor feedback on the Ecodesign for Sustainable Product Regulation - ESPR (June 2022)
EuroWindoor General Secretariat
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 - 36
Fax: +49 (69) 95 50 54 - 11