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