Frankfurt, May 2025 – The forthcoming Construction Products Regulation (EU) 2024/3110 (CPR) will oblige manufacturers to declare environmental sustainability and ongoing considerations for implementation require data for every single product type in the Declaration of Performance and Conformity (DoPC). Because windows are highly customised, as much as 95 % of the windows placed on the European market would each require their own DoPC, creating an enormous administrative burden that particularly hurts small and medium-sized enterprises (SMEs).
The Commission’s current Acquis proposal would force companies either to test every single variant or to declare life-cycle-assessment (LCA) data based on the worst-performing window they make. This approach would overestimate the real environmental impact of most windows, distorting competition between factories and between materials, as well as diverts scarce SME resources away from innovation and towards paperwork.
EuroWindoor urges the Commission to allow reference values based on standard window sizes (EN 17213) and production-volume-weighted averages, as already used in verified Environmental Product Declarations today. This method is proportionate – fully in line with Recital 7’s demand not to over-burden SMEs. It is also practical – keeps documentation needs and notified-body checks manageable while being reliable in delivering representative data for building-level LCA calculations and the upcoming EPBD carbon limits.
To see the full EuroWindoor position on Worst-case LCA values reported in the future DoPC under the new CPR 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