European Associations Call on the Commission to Enable Verified Software Tools under the CPR

Frankfurt, October 2026 – Five European associations have jointly urged the European Commission to establish a clear legal framework for the use of verified software tools to assess product performance under the revised Construction Products Regulation (EU) 2024/3110.

Windows, doors and flat glass are largely custom-made and project-specific. Relying on worst-case declarations and extensive physical testing would lead to a very high number of individual declarations, high costs and administrative burden, especially for SMEs. It would also strain Notified Body capacity and reduce the representativeness of declared values. Software-based calculations have been used for many years.

European Aluminium, EuroWindoor, EPPA, Glass for Europe and Small Business Standards (SBS) therefore propose that the Commission amend Annex IX(5) on AVS 3 by delegated act under Article 10(4) CPR. Verified software could then be used to assess the performance of relevant essential characteristics, where foreseen in the standardisation request. A Notified Body would validate the input parameters and the software. Manufacturers would apply the tool within their factory production control.

The associations support the CPR’s goals of harmonisation, transparency and environmental performance. They invite the Commission, Member States and the standardisation bodies to a constructive dialogue on software validation.

The joint position has been submitted to the Commission and is available here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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EuroWindoor calls for coherent and SME‑friendly rules in Housing Simplification Package

Frankfurt, October 2026 – EuroWindoor supports the objective of reducing unnecessary regulatory and administrative burdens in order to speed up housing construction and renovation, while fully maintaining safety, social, environmental and climate goals. EuroWindoor calls for coherent, SME‑friendly rules for windows, doors and facade products.

In its contribution to the European Commission’s call for evidence on “Housing supply and affordability (regulatory simplification)” a central message is that the Housing Simplification Package should ensure closer coordination between building‑level rules (such as the Energy Performance of Buildings Directive), product‑level rules (including the Construction Products Regulation and related standards), and environmental and chemicals legislation, so that they complement each other instead of creating overlaps or contradictions.

Because most of the 2050 housing stock already exists, EuroWindoor asks the Commission to pay particular attention to renovation and the building envelope. Replacing and upgrading windows, doors and facades is central to better energy performance, comfort and indoor environmental quality in homes. In line with a “renovate first” approach, the Package should prioritise the renovation and adaptation of existing buildings.

From the perspective of window and facade manufacturers and installers, multiple and partly overlapping information and documentation requirements already arise today under instruments such as CPR, ESPR, Digital Product Passport, Energy Performance Certificates, renovation passports and national support schemes. EuroWindoor therefore encourages the Commission to map all EU‑driven information obligations affecting housing projects, eliminate duplicate data requests, harmonise terminology and performance indicators across instruments, and promote interoperable digital tools, so that product data can be used consistently at building level without repeated re‑entry.

The feedback also underlines that most window and door manufacturers in Europe are small and medium‑sized enterprises. EuroWindoor calls on the Commission to keep particular attention to SME realities at the centre of the Housing Simplification Package by designing technically sound but proportionate rules, simple and transparent documentation formats and clear, stable implementation frameworks that allow SMEs to focus on delivering high‑performance housing and renovation solutions.

For more information, see the EuroWindoor feedback click here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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Joint position on the use of verified software tools to assess product performance to implement the revised EU Construction Products Regulation (EU 2024/3110) (October 2026)

The revision of the EU Construction Products Regulation (EU 2024/3110) pursues important and explicitly supported objectives of furthering harmonisation of the European internal market, increasing transparency along the value chain, and integrating sustainability, climate protection and resource efficiency consistently in the construction sector. In particular, the extension of the basic requirements for construction works includes environmental criteria such as embodied energy, recyclability and environmental performance under AVS 3+ is expressly welcomed.

The windows and doors sector, and the flat glass sector, are 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 sectors 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 performance for environmental characteristics and no other performance-related essential characteristics. Against this background, this paper contributes to the dialogue with regulators and aims to jointly develop practical, proportionate and digitally supported solutions.

For the full joint position on the use of verified software tools to assess product performance to implement the revised EU Construction Products Regulation (EU 2024/3110) see the following link:
Joint position on the use of verified software tools to assess product performance to implement the revised EU Construction Products Regulation (EU 2024/3110) (October 2026)

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Joint position on the use of verified software tools to assess product performance to implement the revised EU Construction Products Regulation (EU 2024/3110) (October 2026) Read More »

Joint Call on the Commission to Reconsider Surface Temperature Factor Requirement (September 2026)

The signatory organisations call on the European Commission not to introduce Surface Temperature Factor (fRsi) – frame and glazing bars – as essential characteristics for windows and hatches, pedestrian doorsets, individual rooflights and individual roof hatches as well as continuous rooflights. Condensation and mould risks depend on the building, the installation, the climate and occupant behaviour and should therefore be addressed through installation rules, not through product characteristics that cannot be meaningfully declared in an isolated DoPC.

For the full joint Call for Action on surface temperature factor see the following link:
Call for action on surface temperature factor

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European Associations Call on the Commission to Reconsider Surface Temperature Factor Requirement

Brussels, September 2026 – Six European associations have jointly addressed the European Commission with a clear message: the proposed inclusion of the Surface Temperature Factor (fRsi) as an essential product characteristic in the Standardisation Request for doors, windows and related products is technically flawed and risks undermining both regulatory coherence and the interests of manufacturers across Europe.

The signatory organisations — CEI-Bois, European Aluminium, EuroLux, EuroWindoor, EPPA and Small Business Standards (SBS) — share the view that condensation and mould risks in buildings depend on a wide range of building-, installation- and climate-related factors that are beyond the control of product manufacturers. Addressing these risks through a product declaration cannot deliver the regulatory objective and may produce unintended consequences for energy performance and product design.

The associations call on the Commission to address this matter through installation and application rules rather than product characteristics, and to maintain a clear distinction between what a product can meaningfully demonstrate and what must be resolved at building level.

A technical analysis supporting this position has been submitted to the Commission and is available here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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EuroWindoor feedback on Housing supply and affordability (regulatory simplification) (September 2026)

EuroWindoor appreciates the opportunity to provide feedback on the European Commission’s planned Housing Simplification Package. We welcome the objective to reduce unnecessary regulatory burdens and administrative complexity in order to support housing supply and affordability, while fully respecting safety, social, environmental and climate goals. Simplification should focus primarily on improving and accelerating implementation, permitting and administrative procedures, rather than reopening the debate on recently agreed legislation.

As the European association representing the window, door and façade (curtain walling) sector, we see the effects of complex and sometimes overlapping rules on residential construction and renovation. Our sector delivers core building-envelope elements that are indispensable for energy performance, comfort, health and safety in homes. A targeted simplification package can make it easier and faster to deploy high‑performance window and façade solutions in both new housing and renovation, especially for vulnerable households.

For the full EuroWindoor feedback on Housing supply and affordability (regulatory simplification) see the following link:
EuroWindoor feedback on Housing supply and affordability (regulatory simplification) (September 2026)

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EuroWindoor proposes wording improvements for draft product requirements on windows and doors

Frankfurt, August 2026 – EuroWindoor has submitted comments on the European Commission’s draft delegated regulation establishing product requirements for windows and doors under the new CPR to avoid ambiguities and prevent incorrect specifications.

Unlike the essential characteristics for which a performance can be declared, product requirements are subject to a process which is not based on performance assessment but on the fulfilment of defined steps or checks. They must be fulfilled to place the product on the European market and are related to functionality, safety, and environment.

For windows and doors, these product requirements are meant to ensure safe everyday use – for example in emergency situations or when preventing children from falling from a height – and to provide a harmonised framework for manufacturers across Europe.

EuroWindoor fully supports the objective of improving safety and user protection, while pointing out a number of places where clearer wording and more tailored solutions would help to avoid practical problems or gaps in the rules for windows and doors.

With these comments, EuroWindoor continues its constructive contribution to the Technical Acquis process. The association remains committed to working with the European Commission, Member States, and standardisation bodies to ensure that future product requirements for windows and doors are both clear and proportionate, strengthening safety while remaining feasible for the many small and medium-sized manufacturers in the sector.

For more see the EuroWindoor position see the full EuroWindoor comments on DWS prduct requirements

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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EuroWindoor comments on DWS product requirements (August 2026)

EuroWindoor has submitted comprehensive comments on the European Commission’s draft delegated regulation establishing product requirements for windows and doors under the new CPR to avoid ambiguities and prevent incorrect specifications.

For the full EuroWindoor comments on DWS product requirements see the following link:
EuroWindoor comments on DWS product requirements

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EuroWindoor proposes targeted changes to CWT regulation for reaction to fire class A1 of glass products

Frankfurt, August 2026 – EuroWindoor has submitted feedback on the European Commission’s draft delegated regulation on the conditions of “Classification Without Testing” (CWT) for reaction to fire class A1 (non-combustible) for certain glass products. While EuroWindoor supports the objective of providing a clear and harmonised framework, the organisation highlights a technical inconsistency affecting glass products and suggests an adjustment to the organic content criteria, making it more robust for such products.

The feedback points out that laminated glass with polymer interlayers such as PVB or EVA contains an organic layer other than glue and therefore falls outside the intended scope of the CWT decision. At the same time, some Member States (for example Germany) require A1 or A2 materials in external walls, while also mandating laminated safety glass – a situation currently managed pragmatically by national regulators. To ensure legal certainty and consistent interpretation across Member States, EuroWindoor recommends refining the threshold for allowed organic content by basing it on the physically more relevant organic mass per unit area instead of a simple thickness ratio, and by aligning the treatment of thin organic constituents in glass with the EN 13501-1 concept of “non‑substantial components, without opening the CWT route to laminated glass with functional polymer interlayers.

EuroWindoor believes that these targeted clarifications would keep the delegated act firmly grounded in available technical evidence on glass products, while providing regulators and market operators with a robust and practicable basis for fire-safety decisions.

For more see the EuroWindoor position see the EuroWindoor feedback to the draft delegated regulation on CWT for reaction to fire class A1.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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EuroWindoor feedback to the draft delegated regulation on CWT for reaction to fire class A1 (August 2026)

EuroWindoor is pleased to contribute to the feedback period on the draft supplementing Regulation (EU) 2024/3110 by laying down the conditions for Classification Without Testing (CWT) for reaction to fire class A1. We support the objective of ensuring continuity with the former system under Regulation (EU) No 305/2011 while avoiding unnecessary testing.
At the same time, we wish to highlight a technical inconsistency affecting glass products, in particular laminated glass with organic interlayers and to suggest an adjustment to the organic content criteria, making it more robust for such products.

For the full EuroWindoor feedback to the draft delegated regulation on CWT for reaction to fire class A1e see the following link:
EuroWindoor feedback to the draft delegated regulation on CWT for reaction to fire class A1 (August 2026)

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EuroWindoor welcomes the Association of Ukrainian Manufacturers of Transparent Structures (UVSK) as a new member

Frankfurt, August 2026 – EuroWindoor is pleased to welcome the Association of Ukrainian Manufacturers of Transparent Structures (UVSK) as its newest member. Founded in 2003 and headquartered in Kyiv, UVSK unites the leading manufacturers of windows, doors and transparent façade structures in Ukraine. For more than 20 years, the association has driven industry development through regulatory initiatives, education, international cooperation and market representation.

UVSK’s membership marks a significant step in expanding the European network of the window and façade industry beyond EU borders. Ukraine is one of the largest markets for transparent structures in the region, with more than three million households impacted by war damage since 2022, and 14 percent of the country’s housing stock damaged or destroyed. Against this backdrop, reconstruction and the demand for high-quality, resilient building products have become pressing priorities for the sector.

To address these challenges, UVSK focuses heavily on education and standardisation. The association operates the WindowED Academy, Ukraine’s first dedicated training centre for the transparent structures sector. This initiative directly addresses skills shortages, which are a shared concern across the European industry.

In addition to education, UVSK and its members develop and test blast-resistant window systems. This specialized field has direct relevance to reconstruction efforts and broader European discussions on building safety.

EuroWindoor members look forward to working with UVSK to strengthen the exchange of expertise, promote high product standards and jointly engage on European regulatory developments.

For further information on UVSK, please visit www.auvsk.org.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

 

EuroWindoor welcomes the Association of Ukrainian Manufacturers of Transparent Structures (UVSK) as a new member Read More »

Newsletter 07/2026

Twice a year, EuroWindoor compiles its latest news into a single newsletter. This document summarizes our recent activities, regulatory updates, and industry positions. It serves as a valuable resource for our European network. National associations can easily share this compilation with their local members.

Browse the table of contents below to see the featured topics. To read the full newsletter, scroll to the download link at the bottom.

Overview on EuroWindoor’s activities
1. Joint proposal of the windows industry for a new Assessment and Verification System (AVS) under the CPR
2. EuroWindoor continues to have significant concerns about the draft Standardisation Request for windows and doors
3. EuroWindoor Submits Position on Tebuconazole Renewal to ECHA
4. European Window Stakeholders and EU Commission advance dialogue on CPR Implementation for Windows and Doors
5. EuroWindoor calls for Climate-differentiated Criteria of transparent products in EU Taxonomy
6. EuroWindoor Advocates for Efficient and Quality-Focused Standardisation Process
7. EuroWindoor Urges Balance Between Legal Requirements and Practical Implementation Under the CPR
8. EuroWindoor Calls for Comprehensive Revision of DPP Implementing Act
9. Proposed PFAS Restriction: Equivalent Alternatives Still Missing for Specific Exposed Applications
10. Madrid Directing Council meeting gives fresh momentum to window industry cooperation
11. Appointments 2026/2027

More information

(c) Picture from Guillaume Périgois on Unsplash

Newsletter 07/2026 Read More »

Newsletter 12/2025

Twice a year, EuroWindoor compiles its latest news into a single newsletter. This document summarizes our recent activities, regulatory updates, and industry positions. It serves as a valuable resource for our European network. National associations can easily share this compilation with their local members.

Browse the table of contents below to see the featured topics. To read the full newsletter, scroll to the download link at the bottom.

Overview on EuroWindoor’s activities
1. EuroWindoor advocates for a balanced and cost-efficient role of Notified Bodies in the new CPR
2. EuroWindoor continues its active contribution to the Technical Acquis for windows and doors
3. EuroWindoor met DG GROW representative in Brussels to discuss key challenges of the new CPR
4. EuroWindoor position on the evaluation of the Circular Economy Act
5. EuroWindoor contributes to the implementation framework of the new CPR
6. EuroWindoor comments on draft delegated regulation on fire resistance classes
7. EuroWindoor calls for clear and proportionate AVS allocation under revised CPR
8. EuroWindoor reflects on an intense year 2025 and sends warm Holiday Wishes
9. Appointments 2026

More information

(c) Sorpetaler Fensterbau GmbH

Newsletter 12/2025 Read More »

Madrid Directing Council meeting gives fresh momentum to window industry cooperation

Madrid, July 2026 – EuroWindoor members met in Madrid, Spain, on 3 July for the summer Directing Council meeting at the Spanish standardisation body UNE, with a focus on European legislation, standardisation and the future workforce of the window and façade sector.

The discussions centred on the implementation of the revised Energy Performance of Buildings Directive (EPBD) in the member states, as well as current developments under the Construction Products Regulation (CPR). Members and guests shared national experiences on market trends, regulatory changes and standardisation work, highlighting both opportunities and practical challenges for manufacturers and installers across Europe.

A key topic was the growing shortage of skilled workers. Many national associations reported that a large share of today’s experienced installers and technical staff is expected to retire over the next decade, while too few young people are entering the trades to replace them. The Directing Council exchanged examples of national initiatives, from installer-qualification schemes to social-media campaigns and cooperation with schools, and agreed that the issue is common to many countries and should remain on the EuroWindoor agenda. EuroWindoor will collect further input from its members over the coming months and return to the topic as a dedicated item at the next Directing Council meeting in November 2026.

The meeting once again brought together EuroWindoor’s member associations with guests from additional national organisations from Spain, Romania and Ukraine, underlining the value of peer-to-peer exchange on shared challenges and mutual support across borders.

A part of the program and to get to know each other and have an exchange  in an informal setting the participants took part in a joint social programme including a guided walk through central Madrid and a dinner. EuroWindoor warmly thanks ASOVEN for hosting the Madrid meeting and for its support in organising the local programme.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

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Proposed PFAS Restriction: Equivalent Alternatives Still Missing for Specific Exposed Applications

Frankfurt, May 2026 – In its feedback to ECHA’s SEAC consultation on the proposed PFAS restriction under REACH, EuroWindoor points out that PFAS-containing materials are used in the window, door and façade sector only for a limited number of specific applications subject to particular stress — predominantly in surface coatings and functional components exposed to demanding environmental conditions.

These include fluoropolymer-based coatings on aluminium profiles and façade panels, friction-reducing hardware elements, specialty gaskets, selected façade films and fire-resistant coatings. In all of these uses, PFAS are bound in solid polymer matrices and are not released into the environment during intended use.

For standard exposure conditions, fluorine-free alternatives such as polyester-based coating systems are already available and technically feasible. However, under extreme conditions — such as aggressive coastal or tropical climates, high chemical exposure or very long warranty requirements — current alternatives do not yet fully match the durability and performance of fluoropolymer technologies. When high UV and weather resistance, colour retention, chemical and corrosion resistance, and a long service life are required, PFAS coatings remain the first choice. For other PFAS-containing components, alternatives remain less standardised. A restriction without adequate transition periods could therefore lead to reduced product durability and limitations for buildings with high exposure requirements.

EuroWindoor calls for a transition timeline that reflects the complexity of the construction sector and the need for adequate product validation.

For more see EuroWindoor Feedback to PFAS Survey for 13.07 window frames (May 2026).

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

Proposed PFAS Restriction: Equivalent Alternatives Still Missing for Specific Exposed Applications Read More »

EuroWindoor Feedback to PFAS Survey for 13.07 window frames (May 2026)

In the window, door and façade industry, PFAS are mainly used in fluoropolymer-based surface coatings and certain low-friction or high-performance components.
The most relevant application is PVDF (polyvinylidene fluoride) coating systems for aluminum profiles, façade panels, curtain walls and architectural doors. PVDF belongs to the fluoropolymer group and is therefore considered part of the broader PFAS family. These coatings are typically applied as liquid or coil coatings for high-performance architectural applications.

PVDF is used because it provides:
– excellent UV and weather resistance,
– outstanding color retention and gloss stability,
– high chemical and corrosion resistance,
– low chalking and dirt pickup,
– long service life, especially in harsh climates and highly exposed façades.

PFAS-related materials may also be present in:
– PTFE-based sliding or friction-reducing elements in hardware systems, specialty gaskets using fluorinated elastomers,
– ETFE films used in selected façade applications.
– Fire resistant coatings

The main alternatives to fluoropolymer-based coatings are:
– super durable polyester (SDP) powder coatings,
– hyper-durable polyester systems,
– fluorine-free architectural coating technologies,
– anodizing in selected applications.

These alternatives are used to reduce or eliminate PFAS content while still providing high durability and weather resistance. Polyester-based systems are currently the most common alternative for architectural aluminum because they offer good outdoor performance, are widely available and support easier recycling and regulatory compliance

For the full EuroWindoor EuroWindoor Feedback to the PFAS Survey for 13.07 window frame see the following link:
EuroWindoor Feedback to PFAS Survey for 13.07 window frames 2026-05

EuroWindoor Feedback to PFAS Survey for 13.07 window frames (May 2026) Read More »

EuroWindoor Calls for Comprehensive Revision of DPP Implementing Act

Frankfurt, May 2026 – EuroWindoor has submitted a detailed feedback statement highlighting fundamental shortcomings of the European Commission’s draft Implementing Regulation on the Digital Product Passport (DPP) Registry pursuant to Article 13(5) of the Ecodesign for Sustainable Products Regulation (ESPR).

“We support the Digital Product Passport as an instrument for transparency and circular construction,” said Frank Koos, Secretary General of EuroWindoor. “However, the current draft has been designed without sufficient regard for the realities of an industry that consists almost exclusively of small and medium-sized enterprises. A comprehensive revision is essential before adoption.”

The draft Regulation applies directly to construction products via Article 76 of the Construction Products Regulation (EU) 2024/3110. Window and door manufacturers, the vast majority of them SMEs with fewer than 10 employees, will be required to register DPPs in the ESPR-based registry despite having no prior experience with the digital infrastructure it demands.

In its seven-point feedback, EuroWindoor identifies key areas requiring revision and proposes concrete amendments:

  • Simplified verification: The eIDAS-based verification process imposes disproportionate costs (~€300–800/year) and complexity. EuroWindoor proposes access via national business registers.
  • Proportionate IT security: Undefined security obligations create legal uncertainty. The Commission should offer a centrally managed secure access solution.
  • User-friendly data entry: Free, guided tools must be provided. Data already submitted via the Declaration of Performance and Conformity (DoPC) must be referenceable without re-entry.
  • Practicable registration levels: Item-level registration is unworkable for made-to-order products with millions of parametric variants. Registration at model-family or product-type level must be permitted.
  • Account continuity: Rules for personnel changes, mergers and insolvency are missing. The 90-day proof-of-registration limit is inadequate for products with 30+ year service lives.
  • Multilingual helpdesk: EU-wide implementation requires support in all official languages and national first-line support through industry associations.
  • Circular economy enablement: Data retention must support at least 25 years as required by the CPR. Liability boundaries in reuse scenarios and duplication between DPP and DoPC data must be addressed.

EuroWindoor urges the Commission to integrate the principle of proportionality into the operative provisions and to ensure that no registration obligations arise before harmonised standards define the data scope. The association remains available for constructive dialogue.

For more see EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry (May 2026).

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor Calls for Comprehensive Revision of DPP Implementing Act Read More »

EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry (May 2026)

EuroWindoor, the European association representing manufacturers of windows, doors and curtain walling, welcomes the opportunity to contribute to the public consultation on the draft Implementing Regulation on the Digital Product Passport (DPP) Registry pursuant to Article 13(5) of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781.
The draft Implementing Regulation explicitly includes construction products covered by Article 76 of the Construction Products Regulation (EU) 2024/3110 within its scope (Article 1(1)(c)). This establishes a direct regulatory link between the ESPR-based DPP registry and the construction products sector: manufacturers of windows, doors and curtain walling will be required to register digital product passports in the registry established under the ESPR framework, even though the underlying obligation originates from the CPR.
EuroWindoor would like to draw attention to the need for coherent timing between this implementing act and the development of harmonised technical specifications under the CPR. The DPP data requirements for construction products will be defined in the harmonised standards currently under development. This Implementing Regulation should ensure that the DPP registry and its data models are operationally ready and tested before sector-specific DPP obligations take effect, and that no registration obligations arise before the relevant data scope has been defined through harmonised standards.
It is essential to highlight that the European window, door and curtain walling manufacturing is almost exclusively composed of small and medium-sized enterprises (SMEs). The vast majority of manufacturers are small craft businesses, often with fewer than 10 employees, limited IT infrastructure and no dedicated digitalisation departments. Any obligation arising from this Implementing Regulation will directly and significantly affect these SMEs. While SMEs are disproportionately affected, it should be noted that many of the challenges identified in this feedback apply to all economic operators regardless of size, including the larger manufacturers in the sector as well as component suppliers. The proposed solutions should therefore be designed to benefit all economic operators.

For the full EuroWindoor EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry see the following link:
EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry (May 2026)

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EuroWindoor Urges Balance Between Legal Requirements and Practical Implementation Under the CPR

Frankfurt, May 2026 – Following the CEN/TC 33 plenary meeting on 16 April 2026, at which the Commission positions on key issues relating to the draft Standardisation Request for windows, doors and related products under the Construction Products Regulation (EU) 2024/3110 were presented, EuroWindoor has submitted a detailed response.

EuroWindoor identified several unresolved issues of significant concern to the European window and door sector. Given the tight timeline, the intention is to finalise the draft Standardisation Request before the summer break, EuroWindoor prepared a response covering several topics.

For each Commission position, EuroWindoor outlines the specific challenges facing the industry and puts forward concrete proposals for practical implementation. The topics addressed include normative references, scope and structure of door standards, the treatment of NSHEV products, essential characteristics and assessment methods, the declaration of component values for thermal performance, substances declaration requirements and the Representative Product Type approach under AVS 3.

A key concern throughout is the disproportionate administrative burden on manufacturers, particularly SMEs, if certain proposals are implemented without adjustment.

EuroWindoor remains committed to constructive collaboration with the Commission and all stakeholders and stands ready for further discussion.

For more see EuroWindoor Response to Commission Positions – Balancing Legal Compliance and Practical Implementation 2026-05.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor Urges Balance Between Legal Requirements and Practical Implementation Under the CPR Read More »

EuroWindoor Response to Commission Positions: Balancing Legal Compliance and Practical Implementation (May 2026)

On 16 April 2026, the European Commission (DG GROW H.1) participated in the CEN/TC 33 plenary meeting to discuss the draft standardization request for windows, doors and related products under the Construction Products Regulation (EU) 2024/3110 (CPR). The Commission presented its positions on key issues raised in CEN/TC 33’s comments and provided clarifications on the planned timeline, regulatory requirements and implementation approach.
The Commission emphasized that the positions presented were provisional and subject to further discussion and expressly invited stakeholders to provide feedback on points where fundamental concerns remain. The importance of dialogue was underlined to ensure the standardization request would be both legally compliant and practically workable.
EuroWindoor welcomes this constructive approach and the opportunity for continued engagement. This document addresses several critical points discussed during the meeting, highlighting specific risks and practical challenges foreseen in the implementation of certain proposals. Alternative approaches are suggested that would maintain legal compliance under the CPR whilst ensuring workability for manufacturers across the European market.

For the full EuroWindoor Response to Commission Positions: Balancing Legal Compliance and Practical Implementation see the following link:
EuroWindoor Response to Commission Positions – Balancing Legal Compliance and Practical Implementation 2026-05

Reference documents:
EuroWindoor proposal for simplified declaration under AVS 3 (May 2026)
Joint position on the use of verified software to implement the CPR in the Windows and Doors Sector (January 2026)

EuroWindoor Response to Commission Positions: Balancing Legal Compliance and Practical Implementation (May 2026) Read More »

EuroWindoor Advocates for Efficient and Quality-Focused Standardisation Process

Frankfurt, April 2026 –EuroWindoor AISBL has submitted its response to the European Commission’s consultation on revising Regulation (EU) 1025/2012. This marks a continued engagement following EuroWindoor’s 2023 feedback on the same topic.

In contrast to the previous consultation in 2023, this Impact Assessment study specifically evaluates concrete reform options: digitalisation through Online Standard Development (OSD), legal deadlines for ESOs, alternative delivery mechanisms when harmonised standards cannot be delivered in time, and measures to strengthen the EU’s global role in standardisation. The consultation also assessed cost implications for industry of the proposed reform measures.

EuroWindoor emphasised that frequent changes to guidance and templates delay the process. Sufficient time must be provided for committees to develop standards by consensus at a high technical level. Time savings should come from formal steps such as translation and voting – not from technical work.

While supporting digitalisation, EuroWindoor raised concerns about OSD implementation in large committees, where late changes create coordination difficulties and affect collaboration quality.

Delays in delivering harmonised standards often stem from factors beyond ESO control: unrealistic timelines, missing guidance and insufficient Member State involvement during development. Early engagement by all stakeholders prevents misdevelopment and saves time.

EuroWindoor encourages the Commission to prioritise stable frameworks and structured early involvement of all stakeholders.

For more see the EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor Advocates for Efficient and Quality-Focused Standardisation Process Read More »

EuroWindoor feedback to survey on review of Regulation on European standardisation (April 2026)

Introduction
This survey will be open until Tuesday, 21st April 2026, 23:59 CEST. This targeted survey is part of a consultation exercise envisaged in the Impact Assessment supporting Study accompanying the revision of the EU standardisation Regulation n. 1025/2012, which is currently being conducted by a consortium (Intellera Consulting and Fraunhofer ISI). The Study aims at analysing the difference options to review the Regulation and address the current issues of the European Standardisation System (ESS). The impact assessment assesses the performance of the ESS in the evolving landscape of technical standardisation. It determines whether the existing framework is adequate and capable of delivering standards and technical specifications to support EU policy and legislative needs, while also maintaining global relevance.

Purpose and Scope
The primary objective of targeted surveys is to gather feedback from specific categories of stakeholders. Questions are therefore focused on the possible review of the Regulation (EU) 1025/2012 which might generate benefits or costs. This will allow the European Commission to assess the impact of the revisions on all stakeholders affected.

For the full EuroWindoor feedback to survey on review of Regulation on European standardisation see the following link:
EuroWindoor feedback to survey on review of Regulation on European standardisation

EuroWindoor feedback to survey on review of Regulation on European standardisation (April 2026) Read More »

EuroWindoor calls for Climate-differentiated Criteria of transparent products in EU Taxonomy

Frankfurt, April 2026 – EuroWindoor submitted feedback to the draft delegated Regulation on the EU Taxonomy Climate Delegated Act calling for revised assessment criteria for windows and curtain walls.

The submission addresses the new pan-European maximum U-value of 1.2 W/m²K, which does not factor in geographical and climatic differences. EuroWindoor argues that this approach promotes material-intensive windows throughout the EU without securing environmental payback, while leaving solar energy gains unaccounted for.

EuroWindoor proposes that the EU Taxonomy criteria should incorporate the ‘Energy Balance’ approach, replacing the uniform U-value with values for heating and cooling energy demand according to different climatic conditions. The scientific basis for this approach is provided by the DG ENER LOT 32 study, commissioned by the European Commission.

For more see the EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor calls for Climate-differentiated Criteria of transparent products in EU Taxonomy Read More »

EuroWindoor feedback on revised Criteria for Windows and Curtain Walling in the EU Taxonomy Climate Delegated Act (April 2026)

Issue:
We very much welcome the progress made by considering curtain walls as windows. However, the technical screening criteria for the energy efficiency of transparent building components remain incorrectly defined, as neither climate differentiation nor solar energy gains are considered. The energy efficiency of transparent building components requires an energy balance assessment that accounts for both heat transfer and solar gains related to the respective climatic conditions.
The current pan-European maximum U-value of 1.2 W/(m²·K) for windows and transparent curtain walls addresses only thermal insulation and does not allow for geographical and climatic differences to be factored in to optimize resource and energy use. It rather promotes highly insulated and material-intensive windows and curtain walling everywhere in the EU without securing environmental payback.

For the full EuroWindoor feedback to the Public Consultation see the following link:
EuroWindoor feedback on revised Criteria for Windows and Curtain Walling in the EU Taxonomy Climate Delegated Act Mitigation, amendment to Section 3.5

EuroWindoor feedback on revised Criteria for Windows and Curtain Walling in the EU Taxonomy Climate Delegated Act (April 2026) Read More »

EuroWindoor at Fensterbau Frontale 2026 – Visit us at Booth 7A-524

Frankfurt, March 2026 – EuroWindoor, the European umbrella association for windows, doors and facades, will be present at Fensterbau Frontale 24. – 27. March 2026 in Nuremberg. Visitors can find us at Booth 7A-524 in Hall 7A.

Fensterbau Frontale offers an excellent opportunity for direct dialogue. Whether you are interested in the latest regulatory developments at European level, the new CPR and Technical Acquis process or the general situation affecting our industry – we welcome you to stop by our booth for a conversation.

We look forward to meeting you at Booth 7A-524.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor at Fensterbau Frontale 2026 – Visit us at Booth 7A-524 Read More »

European Window Stakeholders and EU Commission advance dialogue on CPR Implementation for Windows and Doors

Frankfurt, March 2026 – EuroWindoor, Glass for Europe, EPPA, European Aluminium and Small Business Standards engaged in a constructive dialogue with DG GROW to advance the implementation of the revised Construction Products Regulation (CPR) for windows and doors.

Industry representatives shared insights on the practical challenges manufacturers encounter with Notified Body involvement under the new Assessment and Verification System (AVS) 3. The associations presented a collaborative proposal for an additional AVS 4+ framework, which would enable manufacturers to utilise verified software tools to determine performance for variable technical essential characteristics – a practice successfully established in the market for over 20 years.

The Commission acknowledged that software tools can support manufacturers in performance calculations and clarified that Member States require Notified Body verification of calculation results for declarations. The associations outlined the operational implications and resource requirements for validating numerous calculations, despite welcomed simplifications regarding reference size, cascading procedures and component value transfer.

Both parties committed to continued cooperation on refining the AVS system in parallel with the ongoing standardisation process. The Commission underscored the importance of involving Member States and Notified Bodies in the further development to ensure a balanced and workable solution.

The full joint position on the use of verified software tools to assess product performance under the revised EU Construction Products Regulation (EU 2024/3110) in the window and door sector is available here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

European Window Stakeholders and EU Commission advance dialogue on CPR Implementation for Windows and Doors Read More »

EuroWindoor Submits Position on Tebuconazole Renewal to ECHA

Frankfurt, February 2026 – EuroWindoor has submitted its official contribution to the European Chemicals Agency (ECHA) public consultation on the renewal of Tebuconazole as a Product Type 8 (wood preservative) under the Biocidal Products Regulation (EU) No 528/2012.

In its submission, EuroWindoor emphasised the indispensable role of Tebuconazole for the European window and door industry. The substance plays an integral part in safeguarding timber joinery and profiles against decay, particularly from basidiomycete (rot) fungi. Through years of industrial experience, Tebuconazole has proven uniquely suited for this purpose, contributing to both the durability and performance of timber products.

Central Concerns Raised

EuroWindoor’s contribution highlights several concerns regarding the potential non-renewal of Tebuconazole.

Lack of viable alternatives: A thorough review reveals that options such as copper-azole, copper-quat, and copper-HDO do not deliver a comparable combination of efficacy, preservation duration, or suitability for industrial manufacturing. No currently available alternative offers the same balance of performance, process compatibility, and confidence in long-term service life for end users.

Minimised risk through professional application: Potential concerns regarding handling are effectively mitigated by the conditions under which Tebuconazole is used. In window and door production, application occurs in specialised, enclosed industrial environments operated by trained professionals with stringent safety measures in place. This ensures that both operator and environmental exposure remain negligible.

Wider implications: A non-renewal would compromise the competitiveness of wooden windows and doors, increase complexity in manufacturing, and challenge resource efficiency goals due to shorter product lifespans and potentially higher energy and carbon footprints from replacement materials.

EuroWindoor strongly recommends granting continued approval for PT8 uses, until proven, equally effective alternatives become available that support quality, innovation and sustainability objectives for European producers.

More information:

EuroWindoor Cover Letter to ECHA on Tebuconazole

EuroWindoor submission on public Consultation of Tebuconazole

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor Submits Position on Tebuconazole Renewal to ECHA Read More »

EuroWindoor Cover Letter to ECHA and submission on public Consultation of Tebuconazole (February 2026)

To whom it may concern,
EuroWindoor, representing European manufacturers of windows and doors, wishes to underline the significant importance of Tebuconazole for the sector and to advocate for its continued authorisation under the Biocidal Products Regulation for Product Type 8 (wood preservatives).
Wooden windows and doors, especially those exposed to outdoor environments, depend on effective and reliable fungicidal protection. Through years of industrial experience, Tebuconazole has proven to be uniquely suited for this purpose, contributing to both the durability and performance of timber products supplied by our members. No currently available alternative offers the same balance of efficacy, process compatibility, and confidence in long-term service life for end users.

For the full Cover Letter, see the following link:
EuroWindoor Cover Letter to ECHA on Tebuconazole 

For the full EuroWindoor submission to the Public Consultation see the following link:
EuroWindoor submission on public Consultation of Tebuconazole

EuroWindoor Cover Letter to ECHA and submission on public Consultation of Tebuconazole (February 2026) Read More »

EuroWindoor continues to have significant concerns about the draft Standardisation Request for windows and doors

Frankfurt, February 2026 – EuroWindoor has submitted comprehensive comments during the public consultation on the draft Standardisation Request for windows and doors (SReq) under the revised Construction Products Regulation.

Despite more than three years of development and four previous draft versions, critical concerns remain unresolved. EuroWindoor warns that the standardisation work risks failing to deliver the required quality within the set timeframe. Key templates, guidance documents and delegated acts essential for consistent implementation are still missing.

EuroWindoor key concerns

Unrealistic timeline: The June 2029 deadline for the harmonised product standard is highly ambitious as many fundamentals are lacking and numerous supporting standards also need to be revised. EuroWindoor calls for an extension of at least one year.

Overloaded Declaration of Performance and Conformity (DoPC): The draft SReq would require the DoPC to cover around 50 technical characteristics, 19 environmental criteria and 257 individual substances — resulting in approximately 12-page document per window. This is impractical for manufacturers, end-users, legislators and market surveillance authorities.

Disproportionate emission requirements at individual substance level: Treating hazardous substances individually would create an excessive number of characteristics. EuroWindoor advocates for a practical classification system or declaration of aggregated values such as TVOC.

Interference with established classification systems: Proposed changes to well-established classifications like for wind resistance, air permeability, watertightness and manual operating forces would require costly re-evaluation of existing products and risk increasing construction costs.

Missing horizontal solutions: Requirements for interoperability between human-readable and machine-readable formats exceed the capabilities of technical product committees. EuroWindoor urges the Commission to provide cross-sectoral solutions at CEN level.

EuroWindoor remains committed to constructive engagement and calls on the European Commission and Member States to address these outstanding issues to ensure workable, proportionate and timely standards for the European window and door sector.

More information:

Notification on draft standardisations requests for windows and doors

List of EuroWindoor comments on draft Standardization requests DWS (2026-02)

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) Picture from Guillaume Périgois on Unsplash

EuroWindoor continues to have significant concerns about the draft Standardisation Request for windows and doors Read More »

Joint proposal of the windows industry for a new Assessment and Verification System (AVS) under the CPR

Brussels, February 2026 – EuroWindoor, European Aluminium, EPPA, Glass for Europe and Small Business Standards (SBS) have jointly submitted a proposal for the introduction of a new Assessment and Verification System (AVS 4+) under the revised Construction Products Regulation (EU) 2024/3110.

The joint proposal aims to enable manufacturers to use verified software tools to determine the performance for variable technical essential characteristics of products. Under the proposed AVS 4+, a Notified Body would verify the relevant input data and validate the software tool, while the manufacturer would assess product performance using this verified digital process within factory production control.

The proposed system could be introduced by the European Commission through a delegated act according to Article 10 (4). Compared to AVS 3, the new AVS 4+ is intended to better reflect the reality of custom-made and project-specific products, where certain essential characteristics frequently vary and can be reliably determined through calculation methods.

The co-signers underline that the use of software tools is already common practice in the window and door sector, supported by established calculation methods and standards. A software-based assessment, verified by a Notified Body, ensures robust and traceable performance declarations while avoiding unnecessary administrative burden.

AVS 4+ would provide clear advantages in terms of efficiency, consistency and scalability, reduce pressure on Notified Body capacities, and significantly support SMEs and craft-based manufacturers. At the same time, it aligns with the EU’s broader objectives on digitalisation, automation and the effective use of the Digital Product Passport.

Through this joint proposal, the organisations call for a proportionate and future-oriented implementation of the CPR, ensuring high regulatory confidence while enabling digital, practical and economically viable solutions for the windows and doors sector.

You can find the full joint position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) Picture from Guillaume Périgois on Unsplash

Joint proposal of the windows industry for a new Assessment and Verification System (AVS) under the CPR Read More »

Joint position on the use of verified software to implement the CPR in the Windows and Doors Sector (January 2026)

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:

Joint position on the use of verified software to implement the CPR in the Windows and Doors Sector (January 2026)

(c) Picture from Guillaume Périgois on Unsplash

Joint position on the use of verified software to implement the CPR in the Windows and Doors Sector (January 2026) Read More »

EuroWindoor reflects on an intense year 2025 and sends warm Holiday Wishes

Frankfurt, December 2025 – As the year draws to a close, EuroWindoor looks back on an intense and productive 2025 marked by regulatory milestones, strong member engagement and important contributions to shaping Europe’s legal framework for windows, doors and façades.

A central focus throughout the year was the implementation of the revised Construction Products Regulation (CPR 2024/3110/EU). EuroWindoor actively accompanied the development of the Standardisation Request and continued its expert contribution to the Technical Acquis for windows and doors. Across more than 30 meetings, EuroWindoor consistently highlighted in positions and replies to consultations the need for practical solutions, reduced administrative burden — especially for SMEs — and balanced roles of Notified Bodies under the new CPR. Members also exchanged views directly with the European Commission at several occasions, especially in a dedicated meeting with DG GROW in November, addressing open questions and challenges in the transition to the new framework.

Energy efficiency and sustainability were likewise key priorities in 2025. EuroWindoor supported the European Commission’s work on generic datasets to ensure cost-effective and harmonised environmental assessments, and repeatedly underlined shortcomings in the current technical screening criteria of the EU Taxonomy for windows and curtain walling. The continuation of the joint social media campaign on window replacement helped raise awareness of the significant contribution of modern, energy-efficient windows to the EU’s climate and renovation objectives.

In addition, EuroWindoor provided input on the Digital Product Passport rules for service providers and participated actively in consultations on the Standardisation Regulation and the Circular Economy Act. The association also celebrated an important internal milestone: 10 years of EuroWindoor AISBL marking a decade of unified representation for the European window, door and façade sector.

As we look back on this year of strong collaboration and steady progress, EuroWindoor extends its heartfelt thanks to all members, partners and stakeholders for their constructive engagement and ongoing support.

We wish everyone a joyful festive season and a prosperous New Year filled with new opportunities, continued cooperation and shared achievements.

Happy Holidays from EuroWindoor!

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) canva

EuroWindoor reflects on an intense year 2025 and sends warm Holiday Wishes Read More »

EuroWindoor calls for clear and proportionate AVS allocation under revised CPR

Frankfurt, December 2025 – EuroWindoor welcomes the revised Commission’s approach to link assessment and verification systems (AVS) to essential characteristics rather than to intended use of products, as this improves clarity and consistency for windows, roof windows and pedestrian doors.

EuroWindoor stresses that this principle must be applied consistently to avoid overlaps between product categories. If characteristics specific to Natural Smoke and Heat Exhaust Ventilation (NSHEV) will be allocated to costly AVS 1 in the category “components of fire and smoke control products”, the common characteristics should remain within the relevant window, roof window or rooflight related AVS levels.

In addition, EuroWindoor calls for a review of selected AVS allocations. Several characteristics are determined at product delivery, assessed through simplified methods, based on component data or are newly introduced falling traditionally under manufacturer responsibility. For these characteristics, AVS 4 remains a proportionate and risk-based solution.

A targeted review would help ensure a balanced AVS framework aligned with technical realities and avoid unnecessary burdens for manufacturers.

EuroWindoor’s full position and detailed comments are available here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) canva

EuroWindoor calls for clear and proportionate AVS allocation under revised CPR Read More »

EuroWindoor comments on draft delegated regulation on fire resistance classes

Frankfurt, December 2025 – EuroWindoor took part in the public consultation on the draft delegated regulation on resistance to fire performance classes under Construction Products Regulation (EU) 2024/3110. The organisation supports the Commission’s aim of a harmonised EU approach aligned with previous Regulation (EU) No 305/2011.

EuroWindoor raises concerns about the application of fire resistance class EI-M to windows, particularly fixed windows. Although their inclusion alongside partitions helps close a regulatory gap, EI-M includes an impact test that exceeds the technical design and existing test standards for windows.

EuroWindoor therefore considers EI-M not technically justified for windows and proposes adding a note stating: “Class EI-M is not applicable for fixed windows.”

You can find the full EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c)pixabay.com

EuroWindoor comments on draft delegated regulation on fire resistance classes Read More »

EuroWindoor comments and position on the draft delegated act on AVS (December 2025)

EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR (December 2025)
On 10 December 2025, the European Commission opened a feedback period about the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under the revised EU Construction Products Regulation (EU) 2024/3110. The draft act is open for feedback over the Christmas season and New Year until 7 January 2026.
EuroWindoor welcomes the modification since draft version from July that the AVS for windows (including roof windows) and pedestrian doors are linked to essential characteristics instead of intended use of a product. Nevertheless, we do still have some concerns remaining.

For the full position, see the following link:

EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR (December 2025)

In addition to the position, EuroWindoor provided numerous comments to the Delegated Act Assessment and Verification Systems.

For a complete list of the comments, see the following link:
EuroWindoor comments to the draft delegated regulation on resistance to fire performance classes (December 2025)

EuroWindoor comments and position on the draft delegated act on AVS (December 2025) Read More »

EuroWindoor comments to the draft delegated regulation on resistance to fire performance classes (December 2025)

EuroWindoor is pleased to contribute to the public consultation on the draft delegated regulation on resistance to fire performance classes. While EuroWindoor supports the initiative to set out resistance to fire performance classes under Regulation (EU) 2024/3110, to ensure harmonised declaration of this essential characteristic and maintain regulatory continuity with Regulation (EU) No 305/2011, it has noted an issue with class EI-M and its applicability to fixed windows.

In the last revision of the delegated regulation for defining classes related to resistance to fire performance of construction products a yearlong gap related to fixed windows was closed by adding these to Table 4.1 which originally was for partitions. However, not all of the classes existing for partitions are relevant to windows. Windows, neither openable nor fixed will be intended to withstand impacts arising from the failure of other components or objects exposed to fire and therefore class EI-M will not be relevant for windows.

For the full position, see the following link:
EuroWindoor comments to the draft delegated regulation on resistance to fire performance classes (December 2025)

(c)pixabay.com

EuroWindoor comments to the draft delegated regulation on resistance to fire performance classes (December 2025) Read More »

EuroWindoor contributes to the implementation framework of the new CPR

Frankfurt, December 2025 – EuroWindoor welcomes the European Commission’s efforts to bring more clarity to the new Construction Products Regulation (CPR) through the draft Standardisation Request, the Delegated Act on Assessment and Verification Systems (AVS) and the upcoming work on the Digital Product Passport (DPP).

However, key challenges remain. The large number of technical and environmental characteristics risks generating excessive Declarations of Performance and Conformity (DoPCs), creating disproportionate administrative burdens — particularly for SMEs. Clear expectations for Notified Bodies are also crucial to avoid bottlenecks under AVS 3 and to ensure a well-functioning single market.

EuroWindoor also highlights several unresolved technical points: essential characteristics should be limited to what is strictly necessary; similar assessment methods should not be split; representative product samples should be used more flexibly; AVS 1 should be restricted to fire characteristics and simplified methods should fall under AVS 4. For the DPP, the sector still lacks practical guidance and warns against unnecessary distribution requirements.

EuroWindoor remains committed to constructive dialogue and to supporting the Commission in shaping a workable and proportionate CPR framework.

You can find the full EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor contributes to the implementation framework of the new CPR Read More »

EuroWindoor contribution to the implementation framework of the CPR (November 2025)

EuroWindoor would like to acknowledge the efforts made by the Commission to improve the implementation of the Construction Product Regulation (CPR) in 2025. The publication – and call for comments – of the draft Standardization Request (SReq) for Doors and Windows and draft Delegated Act for the Assessment and Verification Systems (AVS) have brought some level of clarity regarding the obligations for manufacturers as well as for standard developers. We expect the same attention to be paid to our comments concerning the Digital Product Passports (DPP) when the first draft Delegated Act is available.
Nevertheless, we believe that:
1. Some critical challenges have yet to be addressed – and solutions to be found – outside the scope of the 3 abovementioned documents (SReq, AVS and DPP)
2. Some technical challenges remain present in these documents to make the CPR enforceable in practice and several EuroWindoor concerns have not been addressed yet.

 

For the full position, see the following link:
EuroWindoor contribution to the implementation framework of the CPR

EuroWindoor contribution to the implementation framework of the CPR (November 2025) Read More »

Newsletter 07/2025

Overview on EuroWindoor’s activities
1. EuroWindoor advocates for feasible procedure of future declaration of thermal transmittance
2. More facts about Window Replacement
3. EuroWindoor supports the European Commission’s efforts in developing generic datasets for environmental sustainability assessments
4. EuroWindoor reminds again about shortcomings in technical screening criteria of the EU Taxonomy for windows and curtain walling
5. EuroWindoor submits numerous comments on the revised draft Standardisation Request for windows and doors
6. EuroWindoor: 10 years of successful commitment to the European window, door and façade industry
7. EuroWindoor Spring Meetings Focus on Sustainability, Innovation and Regulation
8. EuroWindoor calls for more time and clarity on open issues in the Technical Acquis for Windows and Doors
9. EuroWindoor advocates reducing bureaucratic burden of Environmental Declarations under new CPR
10. EuroWindoor members address challenges of the new CPR at Prague meeting
11. EuroWindoor provides input to public consultation on Digital Product Passport rules for service providers
12. EuroWindoor welcomes the Spanish PVC Window Association (ASOVEN) as new member
13. EuroWindoor calls for targeted Improvements while supporting the current Standardisation Framework
14. Appointments 2025/2026

More information

Newsletter 07/2025 Read More »

Newsletter 12/2024

Overview on EuroWindoor’s activities
1. EuroWindoor feedback on the European Standardisation Regulation
2. EuroWindoor feedback highlights the lack of alternatives for IPBC in wood preservation and emphasises the need for renewed authorisation
3. EuroWindoor and Commission continue their positive dialog on the “Energy Balance” principle for windows
4. EuroWindoor recommends manufacturers’ own databases to store future Digital Product Passports (DPP) for Construction Products
5. Window replacements for energy efficiency: social media campaign started
6. EuroWindoor welcomes the new Construction Products Regulation published in the Official Journal of the European Union today
7. EuroWindoor reflects on 2024 Achievements and sends warm Holiday Wishes
8. Appointments 2025

More information

Newsletter 12/2024 Read More »

EU Restriction Procedure Lead in PVC

EuroWindoor information on the implementation and involvement of Notified Bodies (NB) in new AVS 3 Different understanding by NB (November 2025)

Implementation and involvement of Notified Bodies (NB) in new AVS 3 Different understanding by NB
1 Background
EuroWindoor members have learned that different Notified Bodies (NB) in different Member States (MS) have different understanding of the tasks of NB according to Annex IX No. 5, “System 3” of the new CPR (Regulation (EU) 2024/3110):
(b) The notified body shall decide on the issuing, restriction, suspension or withdrawal of the certificate of performance and of conformity of the product on the basis of:
(i) an assessment of the performance on the basis of testing performed by a notified testing laboratory (based on sampling carried out by the manufacturer), calculation, tabulated values or documentation describing the product;
(ii) confirmation that the product type and the product category were correctly determined.

When it comes to practical implementation, a very strict understanding of the task of NB could pose serious challenges, particularly for small and medium-sized enterprises (SMEs) in the window and door industry.

For the full position, see the following link:
EuroWindoor information on implementation and NB involvement AVS3

EuroWindoor information on the implementation and involvement of Notified Bodies (NB) in new AVS 3 Different understanding by NB (November 2025) Read More »

EuroWindoor position on the evaluation of the Circular Economy Act

Frankfurt, November 2025 – In its response to the Consultations for the upcoming Circular Economy Act (CEA), EuroWindoor supports the overall objectives of improving resource efficiency and facilitating recycling. EuroWindoor underlines that measures must reflect the specific situation of long-lasting construction products, as windows and doors with a service life of more than 50 years are already inherently circular products contributing significantly to energy efficiency and sustainability of buildings.

The European Commission plans to propose the CEA to enhance the EU’s economic security and competitiveness while promoting sustainable production, circular business models and decarbonisation. The Act aims to strengthen the free movement of circular products, secondary raw materials and waste and increase the supply and demand for high-quality recycled materials.

EuroWindoor highlights that established recycling processes exist for materials such as PVC, aluminium, steel and glass, but regulatory and practical barriers still limit their full potential. The CEA should therefore promote realistic, material-specific recycling pathways and take into account challenges such as legacy substances and the availability of high-quality post-consumer materials.

Furthermore, EuroWindoor calls for the simplification and harmonisation of end-of-waste criteria and Extended Producer Responsibility (EPR) schemes across Member States. Measures should remain voluntary and incentive-based, avoid duplication of existing industry systems and ensure proportional administrative requirements for SMEs.

EuroWindoor will continue to support the Commission in shaping a balanced framework that strengthens circularity while preserving product safety, performance and competitiveness in the window, door and façade sector.

You can find the full EuroWindoor position here.

(c) Quelle: DIN, Normungsroadmap Circular Economy

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor position on the evaluation of the Circular Economy Act Read More »

EuroWindoor position on the evaluation of the Circular Economy Act (November 2025)

EuroWindoor position on the evaluation of the Circular Economy Act

EuroWindoor welcomes the European Commission’s intention under the Circular Economy Act (CEA) to foster a genuine single market for waste and secondary raw materials and to strengthen circularity in products. According to the Call for Evidence, the Commission plans to achieve this through a mix of measures, including the reform of end-of-waste criteria, the simplification, digitalisation and extension of extended producer responsibility (EPR) schemes and the introduction of mandatory public procurement criteria for circular products and services.

For the full position, see the following link:
EuroWindoor position on the evaluation of the Circular Economy Act (November 2025)

(c) Quelle: DIN, Normungsroadmap Circular Economy

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EuroWindoor met DG GROW representative in Brussels to discuss key challenges of the new CPR

Brussels, November 2025 – EuroWindoor had the honour to welcome Mr Manfred Fuchs from DG GROW H.1 in its Directing Council meeting for an exchange on the implementation of the Construction Products Regulation (CPR) and the Technical Acquis process.

The in-depth discussions with Mr Fuchs focused on Assessment and Verification Systems, the tasks of Notified Bodies and the introduction of the Digital Product Passport, as well as on key topics of the draft Standardisation Request for doors, windows, shutters, gates, and related building hardware, including the fast-track procedure for glass and its impact on product and safety requirements.

Following the fruitful conversation with Mr Fuchs, participants continued with an intensive agenda covering EuroWindoor’s large working program. Discussions covered upcoming delegated acts under the new CPR, progress in standardisation, EuroWindoor’s commitment to the circular economy, ongoing research on the Window Energy Balance and preparations for the EuroWindoor Daylight Conference at glasstec 2026.

With many important issues ahead, EuroWindoor is pleased to see its members actively engaged and committed to shaping the future of the European window, door and façade sector.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor met DG GROW representative in Brussels to discuss key challenges of the new CPR Read More »

EuroWindoor continues its active contribution to the Technical Acquis for windows and doors

Frankfurt, October 2025 – EuroWindoor maintains its strong commitment to shaping the Technical Acquis for windows and doors by actively contributing to the development of the Standardisation Request (SReq). This SReq will serve as the mandate for future harmonised product standards under the new Construction Products Regulation (CPR).

In response to the fourth draft of the SReq, EuroWindoor submitted a comprehensive list of 86 comments to the representatives of DG GROW H1. The association appreciates the constructive dialogue and the Commission’s efforts to streamline the process. However, the current draft still includes an excessive scope — listing for windows 51 technical characteristics, 19 environmental criteria and 257 substances — all of which would need to be addressed in the future Declaration of Performance and Conformity (DoPC). Many of EuroWindoor’s comments therefore focus on simplifying requirements and reducing the administrative burden for manufacturers.

Key EuroWindoor proposals include:

  • Declaring only a total value of volatile organic compounds (TVOC) instead of listing all individual substances;
  • Moving component-related data to general product information linked to dimensions, to reduce complexity and better support SMEs;
  • Allowing more time to discuss and agree on default Reference Service Life values;
  • Retaining existing test and classification standards to avoid unnecessary re-testing and re-evaluation costs.

For the first time, the European Commission has announced target adoption dates for the new harmonised product standards for windows and doors: 15 December 2028. EuroWindoor, however, calls for alignment with the parallel work on harmonised standards for Insulating Glass Units (IGUs) under CEN/TC 129, which is scheduled for adoption on 15 December 2030. As glass is an essential component of windows, a two-year gap would create uncertainty for both manufacturers and authorities. Aligning these timelines would ensure consistency and market stability.

EuroWindoor remains committed to engaging constructively in the standardisation process and to providing expert input that ensures practical, balanced and industry-relevant solutions for the European window and door sector.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

EuroWindoor continues its active contribution to the Technical Acquis for windows and doors Read More »

EuroWindoor advocates for a balanced and cost-efficient role of Notified Bodies in the new CPR

Frankfurt, August 2025 – EuroWindoor raises concerns about the European Commission’s proposed assessment and verification systems (AVS) for windows, doors and curtain walling under the revised CPR (EU) 2024/3110.

The current draft allocates AVS for windows, doors and curtain walling solely to the intended use. This approach is seen impractical, contradicts proven practice and risks unnecessary burdens for the industry. Instead, EuroWindoor advocates for AVS to be allocated per essential characteristic – a system that has already proven successful in existing harmonised product standards.

Key recommendations:

  • Limit AVS 1 to fire-related requirements.
  • Assign single-product characteristics (e.g. dimensions, opening height) to AVS 4.
  • Prevent bottlenecks by not assigning all new, previously voluntary characteristics to AVS 3.
  • Keep simplified methods under AVS 4 to reduce costs and complexity.

EuroWindoor urges adjustments to Annex III, Table 1 of the delegated act and stands ready to contribute concrete proposals for a workable AVS allocation.

You can find the full EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) Sorpetaler Fensterbau GmbH

EuroWindoor advocates for a balanced and cost-efficient role of Notified Bodies in the new CPR Read More »

EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR 2024 (August 2025)

EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR 2024

On 23 July 2025, the European Commission sent to the Member States (MS) the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under the revised EU Construction Products Regulation (EU) 2024/3110. Member States are invited to comment until 15 October 2025.
EuroWindoor welcomes the opportunity to comment but wishes to express serious concerns regarding the proposed AVS for windows (including roof windows), doors and curtain walling, as set out in Annex III, Table 1.
The current proposal is not practicable and risks creating significant burdens for industry. This is because the AVS is linked solely to the intended use of a product, rather than to each essential characteristic, which contradicts established good practice and, in many cases, cannot be implemented efficiently. Article 10 (1) and (2) of the new CPR also specify AVS levels differentiated in relation to its essential characteristics and product requirements.

For the full position, see the following link:
EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR 2024

(c) Sorpetaler Fensterbau GmbH

EuroWindoor position on the draft delegated act establishing the applicable assessment and verification systems (AVS) for product families and categories under CPR 2024 (August 2025) Read More »

EuroWindoor calls for targeted Improvements while supporting the current Standardisation Framework

Frankfurt, July 2025 – EuroWindoor has responded to the public consultation on the revision of the Standardisation Regulation (EU) 1025/2012, expressing strong support for maintaining the existing framework while advocating for targeted improvements to enhance the standardisation process.

Harmonised standards are vital for the functioning of the EU Single Market, particularly for windows and doors. They serve as a key tool in translating legal requirements into practical technical specifications, supporting the effective implementation of the Construction Products Regulation (CPR) and other EU legislation.

EuroWindoor emphasises the importance of maintaining these standards as the primary mechanism for aligning public and private sector efforts. This collaboration between public and private sectors enhances European competitiveness and regulatory efficiency. However, to increase the system’s agility and efficiency, EuroWindoor recommends streamlined procedures, reliable timelines, and well-defined roles for all stakeholders involved.

At the same time, the EuroWindoor warns against rushing the development process. High-quality standards require sufficient time — especially during the drafting and enquiry phases — to ensure meaningful stakeholder engagement. Accelerating these steps could jeopardize the inclusive approach essential for robust and widely accepted standards.

You can find the full EuroWindoor position here.

Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu

(c) wikimedia.com

EuroWindoor calls for targeted Improvements while supporting the current Standardisation Framework Read More »

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