Frankfurt, July 2023 – EuroWindoor, the European association of windows, doors and facade manufacturers, welcomes the draft delegated directive enabling the use of recovered post-consumer rigid PVC in plastic profiles of electrical and electronic windows and doors. EuroWindoor commends the efforts to harmonize European legislations but emphasizes the need for alignment and clarification to facilitate a smoother regulatory process.
The proposed Delegated Directive aims to align RoHS requirements with the REACH regulation, the latter covering chemical substances in the EU. EuroWindoor supports this alignment to minimize conflicts between overlapping European legislations, ensuring a more streamlined regulatory landscape. But a critical issue arises from the differing validity periods outlined in the draft Delegated Directive compared to the REACH derogation. While the REACH derogation is set to expire in May 2033, RoHS expiry date is set to May 2028. EuroWindoor strongly recommends to take care about possible conflicts in future and to ensure that there will be a renewal of the exemption in 2028 to keep RoHS aligned with REACH as long as a new decision will follow the Commission review in 5 years.
Moreover, EuroWindoor highlights the issue of double regulations for construction products, such as windows and doors, which have to comply with the Construction Products Regulation (CPR) and REACH with similar targets like RoHS. EuroWindoor proposes a focused approach by limiting the scope of RoHS to the electrical device of the window/door. To achieve this, EuroWindoor suggests different options for the Commission to proceed. Such a limited scope would resolve conflicting regulations and make the Delegated Directive with the exemption redundant.
EuroWindoor General Secretariat
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11