EuroWindoor supports the overall aims that the proposal to replace the CPR tries to achieve, especially by setting a level playing field when putting the focus on the functioning of the market surveillance and of the Notified Bodies. However, the draft proposal itself has many issues. Structurally the draft is written too complicated with too many articles referencing to other articles, making reading the draft for experts already difficult let alone for manufacturers who have to implement those changes. As a result of this confusing structure the draft is difficult to understand and making many areas open for interpretation.
Besides the many unclear specifications in the articles etc. EuroWindoor strongly emphasises to be cautious of over-regulation, partly because of broadening the scope in certain parts of the draft. New areas in the draft are for example the inclusion of “workers, consumers and occupants” in the Annex, something that is already been regulated in other European legislation e.g. Framework Directive on Safety and Health at Work. For product information requirements lengthy lists of information are demanded, some of whom are confidential or critical and could lead to legal disputes in the long run.
EuroWindoor also like to remind that there are currently a number of other development and revisions going on concerning the construction sector like EED, EPBD and the new Ecodesign for Sustainable Products Regulation (ESPR), which was proposed at the same time as the new CPR. There needs to be a tight coordination and alignment between all those legislative initiatives to prevent from overlapping and overregulation.
EuroWindoor, as representatives of the window, door and façade sector, identified numerous other difficult parts in the Commission´s proposal like the new definitions for construction products – which now includes packaging -or product types multiplying the number of declarations and required product information from a manufacturer.
For further information please see:
EuroWindoor feedback on the proposal for a new regulation replacing the CPR (June 2022)
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
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