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.
EU consultation
Declaration without testing of reaction to fire
7 submissions from 7 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 11 submissions on this file. Shown here: the 7 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
6 submissions from industry and none from civil society organizations; 1 from public authorities, academia and others.
Industry 6Civil society 0Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 17 Aug 2026 — it ran from 20 Jul 2026.
- Policy area
- Industry (DG GROW)
- Where it stands
- Awaiting adoption
- Adoption expected
- 30 Sept 2026 · in 31 days
How it got here
- Reg del draft17 Aug 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg del.
7 positions
GF
Glass for Europe
· · filed 17 Aug 2026 · source
Glass for Europe welcomes the opportunity to comment on this draft delegated act on declaration without testing of reaction to fire. Considering that Article 1 offers a clear set of provisions to address building glass products, Glass for Europe recommends deleting the Notes for the material "Glass" in Table 1 of the Annex ("Including heat strengthened, chemically toughened, laminated and wired glass").
IE
IDEE ECONOMICHE www.idee-economiche.it
· · filed 17 Aug 2026 · source
The draft delegated act ensures that EU manufacturers benefit from a less burdensome approach to declaring the reaction to fire of certain products. This also means that they will not be required to carry out unnecessary tests especially for H2 dispensers that do not need flame deflection facilities in the same way as LPG dispensers do.
Filed in Italian · English published by the European Commission
EUMEPS supports the objective of ensuring continuity between the previous and the new Construction Products Regulation by maintaining existing CWFT provisions for products with well-established and predictable reaction-to-fire performance. This approach contributes to regulatory certainty, proportionality and the reduction of unnecessary administrative burdens for manufacturers.
DI Construction thanks the Commission for the opportunity to comment on the draft delegated act supplementing Regulation (EU) 2024/3110 by laying down conditions for classification without testing of certain products as regards reaction to fire performance.
TU
Technical University of Applied Sciences Rosenheim
· · filed 6 Aug 2026 · source
Dear EU-COM Services Team, thank you for the draft document and the opportunity to give comments. As also comment F33530275 shows, the formulation regarding homogeneous distributed organic material in the listed materials has been changed in comparison to the existing commission decision 96/603/EC on the same topic.
EAACA supports the proposed delegated Regulation and welcomes the continuation of the classification-without-testing principle for materials with a stable and predictable reaction-to-fire performance. We nevertheless propose clarifying Row 3 of Table 1.
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.