320 submissions from 284 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 348 submissions on this file. Shown here: the 320 from organizations. Not shown: 14 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 14 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
CommitteeIMCORapporteurChristian Doleschal (EPP)
Delegated act published: Construction products – assessment and verification systems · 27 Aug 2026
Delegated act published: Construction products – assessment and verification systems · 27 Aug 2026
Public feedback open: Declaration without testing of reaction to fire · 19 Jul 2026
Commission plans delegated act under parent act · 17 Jun 2026
Delegated act adopted: Construction products – assessment and verification systems · 10 Jun 2026
Who showed up
237 submissions from industry — companies and their trade associations — against 32 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.4 industry submissions for every one from civil society.
Industry 237Civil society 32Public authorities, academia, other 51
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
96 of 284
in the EU Register
392
full-time lobbying staff
€43.7M+
declared costs a year
225
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 12 Jul 2022 — it ran from 3 Apr 2022.
Concerning: Last sentence of point 4 of Article 7 in Chapter I on page 53 of the German version of the draft Regulation. In the current wording ‘For this purpose, Member States shall, where appropriate, apply the notification procedure laid down in Directive (EU) 2015/1535’, the word ‘where appropriate’ should be completely vague and therefore deleted from the current sentence without replacement.
Filed in German · English published by the European Commission
PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. We generally welcome the Construction Products Regulation (CPR) proposal as it builds on the existing single market legislation to cover environmental sustainability and circularity aspects.
To: European Commission Brussels, 12 July 2022 ECIA’s response to the Construction Products regulation proposal A green and digital transition requires transparency, supported by a stable regulatory framework. The European Commission's proposal for a new Construction Products Regulation (CPR) was long-awaited, in particular by the construction industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EPFA welcomes the EC initiative to make the construction products more sustainable (i.e., durable, repairable, recyclable, easier to re-manufacture) in line with the objectives of the European Green Deal and especially with one of its main building blocks – the Circular Economy Action Plan.
Revision of the Construction Product Regulation – Saint-Gobain response to the public consultation July 2022 Saint-Gobain welcomes the opportunity to provide feedback on the proposal to revise the Construction Products Regulation. This paper summarizes our general comments on this proposal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECOBA, the European Coal Combustion Products Association, appreciates the possibility to comment on the proposal for a revised Construction Products Regulation. Recognizing the complexity of the proposal ECOBA members are concerned about the impact on existing uses and its potential growth by new requirements and increasing costs for assessments and proofs. The comments are attached.
With the attached position paper, the ZVEI - Electro and Digital Industry Association wants to make a contribution to the consultation procedure for the proposal for a Regulation of the European parliament and of the council laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.
HeidelbergCement Initial Feedback on the Commission Proposal for a Revised Construction Products Regulation Brussels, 12 July 2022 As one of the world's largest integrated manufacturers of building materials with leading market positions in aggregates, cement and ready-mixed concrete, HeidelbergCement welcomes the possibility to provide feedback to the proposal for a revision of the EU Construction Products…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In the new CPR, art. 22(1) touches upon methodology but leaves the door open to the use of existing harmonised technical specifications, notably under EN 15804. The latter lays out the core rules of Environmental Product Declarations (EPDs), upon which product category rules are standardised and applied to cover product-specific aspects.
BPIE welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR) and the opportunity to provide feedback. Our contribution is aimed primarily at addressing the sustainability performance of construction products and creating transparency and trust around their environmental credentials.
www.catalano.it Ref. Ares(2022)5086381 - 12/07/2022 [email removed] General argument to reverse the decision to exclude sanitary appliances from the CPR We appreciate the efforts from of the European Commission to include sustainability and environmental aspects into the proposal for the revision of the construction product regulation (CPR) with document COM(2022) 144 final from 2022-03-30.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
!Unexpected End of Formula Ref. Ares(2022)5086328 - 12/07/2022 The Association for European Manufacturers of Expanded Polystyrene (EUMEPS) comments to the Proposal for a New Regulation on Construction Products. To win the race of the green and digital transition, construction product manufacturers need clear and transparent rules supported by a stable legal framework right from the start.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Expanded Clay Association (EXCA) welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products. Detailed feedback on the proposal is provided in the attached position paper.
The Commission's proposal is good in principle, particularly the goal to promote the circular economy and the operation of the internal market in the construction sector. It important to have the opportunity to re-use construction products on a wider scale than at present.
Parecer da ZERO em relação à proposta de revisão do Regulamento dos Produtos de Construção (CPR) 12 Julho de 2022 Sumário A ZERO congratula a Comissão Europeia pela proposta de revisão do Regulamento de Produtos de Construção (CPR na sigla inglesa), em particular o esforço de alinhar o Regulamento com os princípios ambientais já apresentados no Regulamento Eco-design Para Produtos Sustentáveis (ESPR na sigla…
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
12.07.2022 Antti Koponen Rasek Consulting Oy Ltd Comments on the Commission document ‘Proposal for a Regulation of the European Parliament and of the Council laying down harmonized conditions for marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011’; published 30.3.2022 A. General comments 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We note that an extension of the tasks of manufacturer and notified bodies is envisaged, especially in system 2 +, which is that all prefabricated elements of structural concrete with mandatory CE marking are followed.
Filed in Spanish · English published by the European Commission
Thank you for the opportunity to deliver an opinion on the proposal for a Regulation of the European Parliament and of the Council laying down harmonised conditions for the marketing of construction products, published in March 2022, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.
Filed in German · English published by the European Commission
July 11th, 2022 Re: Construction Products Regulation – revision Pyrowave is a pioneer in the electrification of chemical processes based on low carbon footprint microwaves. Pyrowave is also a Canadian leader in the plastics circular economy and chemical recycling to regenerate post-consumer and post-industrial plastics into new materials, reclaiming these resources’ full value.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Central Association of German Construction (ZDB), which represents the interests of small and medium-sized construction companies in particular (in Germany 99 % of all construction companies) and is a member of FIEC, welcomes the Commission’s initiative to improve the overall functioning of the internal market for construction products and to focus more on the environmental performance of construction products.
Filed in German · English published by the European Commission
Stellungnahme Stellungnahme zum Vorschlag für eine VERORDNUNG DES EUROPÄISCHEN PARLAMENTS UND DES RATES zur Festlegung harmonisierter Bedingungen für die Vermarktung von Bauprodukten, zur Änderung der Verordnung (EU) 2019/1020 und zur Aufhebung der Verordnung (EU) Nr.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As a responsible European manufacturer of sanitary appliances, with several manufacturing locations within the EU, we are deeply concerned about the exclusion of sanitary appliances from the scope of the current version of the CPR proposal. Sanitary appliances have been covered by the CPR since decades and are by no doubt construction products.
BRE Global Ireland response to European Commission’s Construction products – review of EU rules, July 2022 BRE Global Ireland welcomes the European Commission’s proposed new Construction Product Regulations (CPR) and is very supportive of many of the key provisions in this document, including but not limited to: • Sustainability elements are very extensive within the proposed changes.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEAD welcomes the Commission’s proposal for a new Construction Products Regulation and its main objectives of achieving a well-functioning single market for construction products and contributing to the goals of the green and digital transition. The European Waste Management Industry gives a strong contribution in the transition to a circular economy of the construction products sector.
3M welcomes this initiative of the European Commission to further enhance the sustainability of construction products and to address delays in the European standard development system and OJEU citation. While reviewing the CPR, we wish the EU legislators to consider the following policy actions: - Ensure that standard development is up to speed, transparent and led by CEN and CENELEC technical committees to…
Feedback to the Commission proposal for a regulation laying down harmonised conditions for the marketing of construction products (Construction Products Regulation) FIR represents the recycling industry of Construction & Demolition Waste (C&DW) and of Incinerator Bottom Ash (IBA). Those member states where FIR has representation cover 60% of the EU population.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Treindustrien welcomes the possibility to provide feedback on the proposal for a new Construction Products Regulation. Treindustrien (The Norwegian Wood industry Federation) is an industry organisation for manufacturers of building materials made of wood, such as structural timber, panel and cladding, glulam, prefabricated elements etc.
RESPONSE TO PUBLIC CONSULTATION - EUROPEAN GENERAL GALVANIZERS ASSOCIATION REVISION OF THE CONSTRUCTION PRODUCTS REGULATION (2022/0094) 12 JULY 2022 IMPORTANCE OF THE CPR The European General Galvanizers Association (EGGA) represents approx. 600 industrial operators (mostly SMEs) that provide the service of sub-contract application of long-term protective zinc coatings for steel products (ie., hot dip galvanizing).
EUROPEAN MANUFACTURER ASSOCIATIONS COMMON POSITION PAPER TO THE COMMISSION PROPOSAL FOR A REVISION OF THE CPR Our various organizations represent in total 80 manufacturers of Small Wastewater Treatment Plants (SWWTP) in Europe and represent about 6 000 employees of the European environmental sector. SWWTP are generally prefabricated products, delivered and installed on site.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Swedish Wood’s feedback to the European Commission’s consultation on the proposed revision of the Construction Products Regulation (CPR) 2022-07-12 To the European Commission Swedish Wood’s feedback to the European Commission’s consultation on the proposed revision of the Construction Products Regulation (CPR) Swedish Wood appreciates and welcomes this opportunity to submit feedback to the European Commission’s…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECRA, as a member of EUFCA (European Floor Covering Association) fully supports the Construction Products Europe comments to the Proposal for a New Regulation on Construction Products. With respect to the digitalisation we recommend that besides the fully machine readable aproach the use of human readable digital data should not be forgotten as in future end users still will need to be inforemed about product…
The European Union Road Federation welcomes the revision of the CPR. As our members are active in the road construction and maintenance, the CPR is of crucial importance to the setting of public procurement contracts. Technology is evolving and new business models are gaining ground. Road safety and smooth mobility are the key aspects of the common objectives between road owner and the supplying industry.
A clear, lean and reliable legal framework is an essential prerequisite for an effective and economic functioning of the internal market for construction products as well as to contributing to affordably, green and digital objectives The persisting problems with the citation of CEN standard deliverables in the EU Official journal as well as with the revision of Mandates/Standardisation Mandates has put the…
NVTB is the Dutch Association for Construction Supply and represents the construction products industry in the Netherlands. NVTB welcomes the Commission proposal for a new Construction Products Regulation which aims at solving the implementation issues producers have been facing and bringing to the attention of the European Commission.
Projet de révision du Règlement Produits de Construction Les représentants de la Filière Béton ont procédé à un examen attentif du projet de révision du Règlement Produits de Construction, soumis à consultation publique depuis le 30 mars 2002.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comissão Europeia Bruxelas, Bélgica Coimbra, 12 de julho de 2022 Assunto: Comentários do Itecons à proposta de Regulamento de Produtos de Construção de 30 de março de 2022 Exmo.(s) Senhor(es), Enquanto Instituição fortemente ligada ao Setor da Construção e enquanto Organismo de Avaliação Técnica e Organismo Notificado no âmbito do atual Regulamento dos Produtos de Construção (Regulamento (UE) n.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
A clear, lean and reliable legal framework is an essential prerequisite for an effective and economic functioning of the internal market for construction products as well as to contributing to affordably, green and digital objectives The persisting problems with the citation of CEN standard deliverables in the EU Official journal as well as with the revision of Mandates/Standardisation Mandates has put the…
We fully support the Commission’s efforts and intentions underlying the proposal. We are looking forward to continuing to implement the performance approach which has proven its worth meeting the various needs of the sector. We also welcome the harmonised technical standards at the heart of harmonisation in the proposed new CPR. However, the proposal raises many issues. The most important ones are: 1.
The French Aggregates Standardisation Commission welcomes the publication of this long-awaited draft revision of the CPR. Although she shared the objectives of this project, there were several issues of concern to its members. These subjects are summarised below.
Filed in French · English published by the European Commission
RA Norbert Küster Wirtschaftsrecht Brandschutz- u. Bauproduktenrecht Marken-, Sorten- und Urheberrecht RA Wolfgang Bramer Fachanwalt für Familienrecht Fachanwalt für Steuerrecht RA Hamid Mehrpuyan Strafverteidigung Fachanwalt für Verkehrsrecht RA Norbert Küster | Oxfordstraße 10 | 53111 Bonn Europäische Kommission DG Growth Vertretung bei allen Amts-, Landund Oberlandesgerichten in Kooperation mit: RAin Heike…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Annex II(h) provides for the indication of an estimated average and minimum useful life in the declaration of performance. Here we see the following problems: — practical value of indicating an estimated useful life for the user —the resulting legal uncertainty for manufacturers and users (legal relevance of this statement, promised property) —Dependency of product life depending on the design and boundary…
Filed in German · English published by the European Commission
Uwagi Polskiego Stowarzyszenia Producentów Styropianu (PSPS) do projektu zmian CPR Lp. Jednostka redakcyjna, której uwaga dotyczy/ pkt Uzasadnienia/ pkt oceny skutków Zgłaszający Uwaga/ Propozycja zmian zapisu I. UWAGI OGÓLNE Uzasadnienie proponowanych zmian PSPS popiera ogólne cele wniosku i opisane narzędzia ich realizacji. Cele ogólne wniosku wskazane przez KE: 1.
Filed in Polish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Deutsches Säge- und Holzindustrie Bundesverband e.V. (DeSH) therefore welcomes the aim of the European Commission (European Commission) to remedy the existing difficulties in the process of developing and citing harmonised standards and to remove today’s restrictions on the development of the internal market for construction products and competitiveness.
Filed in German · English published by the European Commission
Hydrogen Europe welcomed the high ambition of the European Union’s Green Deal and the heightened importance given to sustainability and decarbonisation goals. It is essential now that the co-legislators and the Commission keep this ambition and define a regulatory framework that incentivises the shift towards more sustainable, zero- and low-carbon solutions in industrial sectors.
ZDH, the German Confederation of Skilled Crafts and Small Businesses, represents more than one million crafts enterprises. The majority of these are active in the construction sector. In short, we want to stress the following aspects. For a more detailed feedback, we kindly refer to the attached document.
Filed in German · English published by the European Commission
ANIMA Confindustria Meccanica Varia is Italian industrial Organisation that represents companies operating in the mechanical engineering sector. ANIMA Confindustria Meccanica welcomes the publication of the Proposal, which aims to contribute to the transition of the sector toward the green and digital economy, and would like to share some considerations on the implementation of this piece of legislation.
GNB-CPR GNB-AG Co-ordination of the Group of Notified Bodies for the Construction Products Regulation No. (EU) 305/2011 NB-CPR/22/902 Issued: 12 July 2022 Working Document GNB-CPR Comments regarding the proposal for a revised Construction Products Regulation 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The National Federation of Public Works (FNTP) welcomes the Commission’s intention to further integrate digital and green transition issues into its proposal for a regulation. It welcomes the Commission’s intention to incorporate aspects relating to improved market surveillance and the establishment of a mechanism for harmonising national health and safety regulations.
Filed in French · English published by the European Commission
CONSTRUCTION PRODUCTS – REVIEW OF EU RULES EDANA, the international associations serving the nonwovens and related industries, welcomes the proposals made by the European Commission in the context of the revision of the Construction Products Regulation (CPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Proposal for a revision of the European Construction Products Regulation — Contribution from the Climate Action Network and the Watt Institute The Climate Action Network and the negaWatt Institute welcome the European Commission’s proposal to revise the CPR Regulation, which represents a real effort to align with the environmental principles of espionage and to reduce environmental impacts — in particular carbon —…
Filed in French · English published by the European Commission
Confartigianato Imprese, the most representing social partner for micro and SMEs in Italy, welcomes the publication of the revision proposal of the CPR, which is expected to establish a stable regulatory framework to enable the sector to contribute to the efforts toward green and digital transition. However, it should be ensured that the twin transition aims at simplification, instead of creating additional burdens.
Hauptverband der deutschen Bauindustrie – Feedback zum Kommissionsvorschlag der neuen Bauprodukteverordnung Die Bauindustrie begrüßt, dass die EU-Kommission einen Vorschlag zur Überarbeitung der Bauprodukteverordnung vorgelegt hat, der einen besser funktionierenden EU-Binnenmarkt für Bauprodukte hervorbringen soll.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The draft of the new CPR will bring life to the issue of environmental sustainability. The use of SPDs as a key tool to describe environmental characteristics is logical; it builds on the existing capacity and experience and thus strengthens the environmental sustainability of the whole construction sector in a highly efficient way. However, the Institut Bauen und Umwelt e.V.
Filed in German · English published by the European Commission
Build Europe welcomes the efforts and work of the European Commission to harmonise rules for the marketing of construction products in the EU. However, as stated in our response to the public consultation on the potential revision of the Construction Products Regulation, Build Europe believes that CPR provisions could have a negative impact on the price of construction products as well as administrative burdens for…
BIBM is the Federation of the European Precast Concrete industry, representing the manufacturers at the European level. The role of the association is to establish a dialogue between the precast concrete sector on one side and European and international stakeholders, including policy makers and standard writers, on the other, for the achievement of a fair, market-relevant regulatory framework.
The Fédération Française du Bâtiment (FFB) fears that the proposal for a regulation on construction products will create an unbearable administrative and financial burden for building builders and craftsmen, thus hampering the sector’s efforts in terms of ecological transition, adaptation to climate change and innovation.
Filed in French · English published by the European Commission
Regolamento Prodotti da Costruzione (CPR 305/11) – proposta di revisione COMM (2022) 144 final- Osservazioni FINCO – Federazione Industrie Prodotti, Impianti, Servizi ed Opere Specialistiche per le Costruzioni e le Manutenzioni Edili e Stradali.
Filed in Italian · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Safety Federation welcomes this initiative of the European Commission to further improve the legislation of construction products, including sustainability and recognizing delays in the European standard development system and OJEU citation.
We appreciate the European Commission’s efforts to include sustainability and environmental aspects in the proposal for the revision of the Construction Products Regulation (CPR) with COM (2022) 144 final of 30-03-2022. However, we are deeply concerned about the exclusion of healthcare appliances from the scope of the CPR.
Filed in Italian · English published by the European Commission
EVIA welcomes the European Commission’s revision proposal for the Construction Products Regulation (CPR). This revision of the CPR will be the first revision of an EU sectoral products legislation in the new era that will be framed by the draft Ecodesign Regulation.
The following is only an extract. See the attached file for full response. Best regards. FIVRA fully subscribes to the necessity, as identified by the European Commission, to revise, repair and complete the EU Construction Products Regulation (CPR, EU 305/2011).
Mapei welcomes the aims of the European Commission (EC) proposal for the revision of the Construction Products Regulation (CPR) and the objectives to achieve a well-functioning single market for construction products, to improve the market surveillance, to avoid the overlapping between DoP and CE marking, to better clarify the meaning of the CE marking on construction products and to contribute to green and digital…
European Commission Construction Products Regulations Brussels, Belgium By Email 12th July 2022 Introduction: The Society of Chartered Surveyors Ireland (SCSI) is a professional body representing approximately 5000 surveyor members who are typically employed across the built environment in the construction land and property markets through private practice, in central and local government, in state agencies, in…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sir, Dear Madam, Please find our full position paper in attachment. In short, we recommend clarifying in the legislative text that when products are covered by an ecodesign and/or energy labelling regulation, they should not be covered by the CPR, under the principle of lex specialis versus lex generalis.
ASTM International welcomes the European Commission (EC) proposal for a revised Construction Products Regulation and is pleased to provide our feedback. While several ASTM International Technical Committees (TCs) actively develop and maintain standards relevant to the construction industry, we were particularly excited to see the prominent role of additive manufacturing (AM, more commonly known as 3D printing)…
Eufca , association of associations, covering textile (ECRA), resilient (ERFMI),laminate (EPLF), modular mechanical locked (MMFA) flooring , welcomes the new CPR proposal as a good step forward. We largely endorse the comments document worked out by Construction Products Europe . The Eufca member association will highlight their specific issues in their comments.
12 July 2022 Confindustria Ceramica position paper on the proposal for a revised Construction Products Regulation On 30 March 2022, the European Commission published its proposal for a revised Construction Products Regulation (CPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Contribution du CSTB à la consultation ouverte sur la révision du règlement sur les produits de construction Champs sur Marne, le 12 juillet 2022 Le 30 mars 2022, la Commission européenne (ci-après, la « Commission ») a publié une proposition de règlement abrogeant et remplaçant le règlement (UE) n° 305/2011 du Parlement européen et du Conseil du 9 mars 2011 établissant des conditions harmonisées de…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bellona Europa welcomes the ongoing efforts by the European Commission, and the invitation to provide views, feedback and recommendations on the proposal to revise the Construction Products Regulation (CPR). Buildings and the materials with which they have been constructed have a significant environmental and climate footprint.
Feedback from VdS Schadenverhütung GmbH VdS Schadenverhütung GmbH is one of the world's most renowned institutions for corporate security. Around 500 experts offer a unique range of services for fire protection, security, cyber security and natural hazard prevention.
Members of EAE, the European Association for External Thermal Insulation Composite Systems (ETICS), have recognized the publication the European Commission’s proposal for a revised Construction Products Regulation (CPR), dated 30 March 2022. We are pleased to contribute our views in the feedback period and stand ready for questions and to contribute to further improvements.
ROCKWOOL welcomes the Commission’s proposal on the CPR revision, which is positive in many respects. Implementation time is going to be crucial to keep up the ambition and to ensure that harmonized and verified info on circular, sustainable, and safe construction products will soon be available on the EU market.
Eurogypsum, the European federation of national associations of producers of gypsum products (such as plaster and plasterboard), believes that the Construction Products Regulation (CPR) is a good instrument to regulate the trade of construction products within the European Union.
The European Resilient Flooring Institute, ERFMI, welcomes the Commission’s proposal for a new Construction Products Regulation and appreciates the Commission’s commitment to solving the issues construction products’ manufacturers have been facing over the past few years. The attached document highlights the key points which we believe raise concerns or require clarification.
Small Business Standards (SBS) and European Builders Confederation (EBC) appreciate the opportunity to provide joint feedback to the proposal for the revision of the CPR, expressing the needs of construction SMEs and crafts. We support the development of a functioning and pragmatic CPR as key to ensuring level playing field and fair competition in the construction sector.
After careful reading of the proposal for a Regulation, we find that some of the proposals cannot be accepted. The following will seek to comment briefly on Articles 2 and 4 and on the main issues which we do not support: — Article 2: it would be advisable to define the scope after the end of the CPR Acquis works, which would give a clearer idea of the scope of the CPR.
Filed in Italian · English published by the European Commission
CFE represents manufacturers of anchors, wood screws and similar construction fixings. Each of our member companies holds at least one European Technical Assessment. The following positions are focussed on issues related to EADs and ETAs. 1.
IEW welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR), in particular the effort to align with the environmentally sound principles put forward by the Ecodesign Regulation for Sustainable Products (ESPR).
Hello, The attached document sets out the opinions and questions of the parent parties of the BNTRA standardisation bodies on the proposal for revision of the CPR submitted by the European Commission. BNTRA is a sectoral standardisation office by delegation from Afnor in the fields of transport, roads and their development. Kindly cordially, The Deputy Director
Filed in French · English published by the European Commission
Stellungnahme zum Vorschlag für eine VERORDNUNG DES EUROPÄISCHEN PARLAMENTS UND DES RATES zur Festlegung harmonisierter Bedingungen für die Vermarktung von Bauprodukten, zur Änderung der Verordnung (EU) 2019/1020 und zur Aufhebung der Verordnung (EU) Nr.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Thank you for the possibility to comment on the Proposal for a Regulation of the European Parliament and of the Council laying down harmonised conditions for the marketing of construction products amending Regulation (EU) 2019/1020 and repealing Regulation (EU) No 305/2011. Please refer to the attached file for our comments.
Filed in German · English published by the European Commission
The European Producers of Laminate Flooring (EPLF) endorses the Construction Products Europe (CPE) position paper on the revision of the Construction Products Regulation (CPR), which has already been submitted to the European Commission's online consultation.
1. Does a decorative product (Article 12.2) mean that none of the Basic Work Requirements/Essential requirements apply anymore? In that case, a declaration of performance for used product is an empty shell, as there are no performances that can/should be included in this declaration. In fact, this possibility already exists under the current CPR.
Filed in Dutch · English published by the European Commission
DIN, the German Institute for Standardization, is the independent platform for standardization in Germany and worldwide. As a partner for industry, research and society as a whole, DIN plays a major role in helping innovations to reach the market in areas such as the digital economy or society, often within the framework of research projects.
UNE welcomes the European Commission proposal for the revision of the CPR which aims at strengthening the well-functioning of the single market for construction products and proper contribution to the EU objectives of the twin transitions (green and digital). Relating to standardization issues, most of our concerns are included in the reply from CEN/CENELEC to the proposal.
The Federal Association for Energy-Efficient Building Envelopes (FAEBE / BuVEG) welcomes the aim of the EU Commission to use the Construction Products Regulation (CPR) to achieve the smooth functioning of the internal market, a free movement of construction products within the European Union and to strengthen the internal market for construction products through a well-implemented regulation.
EUROFER Position paper on the Commission’s proposal for the revised Construction Products Regulation - 2022/0094 (COD) The European Steel Association (EUROFER) broadly welcomes the Commission’s proposal for a revised Construction Products Regulation (CPR) and supports the following elements in particular: • • • • • • • • Alignment with the Ecodesign for Sustainable Products Regulation (ESPR) proposal is essential…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Feedback from ANAIP (Spanish Association of Plastic Converters) to EU Commission Consultation on the revision of the CPR 2022.07.12 ANAIP, representing more than 450 plastics converters and over 40.000 employees in Spain, welcomes the publication of the European Commission’s proposal for a revised CPR and fully supports its objectives to achieve a well-functioning single market for construction products as well as…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Orgalim, representing Europe’s technology industries, welcomes the opportunity to comment on the European Commission’s proposal for a Regulation on Construction Products. Within the Construction sector many of our 29 national industry associations and 19 European sector associations represent a variety of large, small and micro-industries that manufacture structural metal products, metal windows and doors, small…
1/2 Ref. Ares(2022)5074988 - 12/07/2022 Paris, le 7 juillet 2022 Marquage CE au titre du Règlement Produits de construction N. Réf. : PP/2022 07 07 Madame, Monsieur, Vous trouverez ci-après les commentaires du LNE, organisme notifié n°0071 au titre du marquage CE pour les Produits de la Construction sur la proposition du 30 mars 2022 de révision du Règlement du Parlement Européen et du Conseil établissant des…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Commission DG for Internal Market, Industry, Entrepreneurship and SMEs [name removed], Commissionar B - 1049 Brussels (Belgium) E-mail: [email removed] CC: [email removed] English Version (German Version below) Vienna, 10th July 2022 Statement on the amendment of the Construction Products Regulation, Status 30.3.2022 The Austrian Construction Materials Recycling Association is the national representative of…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurolux strongly believes in a construction products legal framework that contributes to the green transition of the sector and towards a more climate-neutral building stock, while remaining workable, cost-efficient and creating a level playing field.
The construction sector is an important market for steel products. These are fully circular. They thus promote the circular economy through options for re-use, reparability or other equivalent characteristics. In addition, the steel sector is constantly developing new solutions to the design ecosystem, with the aim of meeting the requirements of the European Green Deal and the EU Circular Economy Action Plan (CEAP).
Filed in German · English published by the European Commission
The European cement industry is committed to achieve carbon neutrality by 2050 as set out in CEMBUREAU Carbon Neutrality Roadmap outlining the CO2 reduction pathways in clinker/cement manufacturing and in production/use/end-of-life of its end-product, concrete. Concrete is a key building material for tomorrow’s sustainable built environment thanks to its durability, strength, recyclability and carbonation potential.
The EEB welcomes the European Commission's proposal to revise the Construction Products Regulation (CPR). However, the current proposal is not aligned with the Paris Agreement ambition and does not grant an effective contribution to 2050 carbon neutrality objectives. Lack of clear provisions to actually reduce embodied emissions beyond information is a worrying postponement of necessary efforts.
Feedback from AseTUB - Spanish Group of Plastic Pipes and Fittings Manufacturers of ANAIP (Spanish Association of Plastic Converters) to EU Commission Consultation on the revision of the CPR 2022.07.12 AseTUB, representing more than 70% of the Spanish plastic piping systems market and companies, welcomes the publication of the European Commission’s proposal for a revised CPR and fully supports its objectives to…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CEN – European Committee for Standardization CENELEC – European Committee for Electrotechnical Standardization CEN Identification number in the EC register: 63623305522-13 CENELEC Identification number in the EC register: 58258552517-56 Position Paper CEN and CENELEC response to the European Commission proposal for the revision of the CPR July 2022 General Overview On 30 March 2022, the European Commission (EC)…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Together with the representatives of French organisation Filière Béton, CERIB has carried out a careful examination of the draft revision of the Construction Products Regulation, submitted for public feedback since March 30.
Austrian Standards International – Standardisierung und Innovation (A.S.I.) supports the objective of the proposal for the revision of the Construction Products Regulation (CPR) to achieve a wellfunctioning single market for construction products and contribute to the EU objectives of the twin transitions (green and digital). A.S.I.
As a medium-sized Austrian producer of woodwool lightweight products, we see the principle objectives of a new regulation Positively, but warn against an excessive bureaucracy that makes it Massively difficult for small and medium-sized companies to participate in the market.
Filed in German · English published by the European Commission
In Green Transition Denmark we welcome the European Commission's proposal to revise the Construction Products Regulation (CPR), underlining the effort to align it with the environmental principles included in the Eco-design Regulation for Sustainable Products (ESPR). The proposal doesn't deliver enough.
Comentários do grupo informal constituído por elementos da CT 153 - Comissão Técnica Portuguesa para os ligantes betuminosos Proposta de regulamento: 1. Avaliação de impacto, adequação da regulamentação, simplificação, outros elementos e considerandos iniciais da proposta de regulamento a.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear colleagues, Please see attached the full BSEF Position Paper on Commission Proposal for a Revision of the Construction Products Regulation (CPR) The BSEF Key messages: • The Revision of the CPR needs to continue to consider fire safety of construction materials, given; 1) The move towards Green Energy and EVs, and required energy storage applications in homes 2) The increased use of plastics and flammable…
ECOS welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR), in particular the effort to align with the environmentally sound principles put forward by the Eco-design Regulation for Sustainable Products (ESPR).
11. July Juli 2022 2022 | page 1 from 3 German Ecolabel Blue Angel’s feedback on the European Commission’s Proposal for a Regulation laying down harmonised conditions for the marketing of construction products Suggestions for amendments regarding the interface with ecolabels (Article 18) and green public procurement (Article 84) We appreciate the possibility to send feedback on your Proposal for a Regulation laying…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ecocem, Europe’s leader in low carbon cement technologies, welcomes the Commission’s proposal for a revision of the Construction Products Regulation (CPR). We consider the overall messaging of the proposal to be positive.
We welcome the European Commission’s proposal to revise the Construction Products Regulation (CPR). The Commission’s aim to achieve a well-functioning single market for construction products across the European Union is highly supported.
We fully support the Commission’s efforts and intentions in the writing of this proposal. Since many years, we advocate as the Swiss industry to keep the performance approach which has proven its worth meeting the various needs of the sector – especially the SME. Therefore, we are looking forward to implementing it further.
Plastics Recyclers Europe welcomes the proposal for a Regulation laying down harmonised conditions for the marketing of construction products (CPR), amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.
DEAR Sir or Madam, Environmental Action Germany (DUH) is a non-governmental environmental and consumer protection organisation in Germany. WE are politically independent, recognised as a non-profit organisation and entitled to bring legal action. DUH supports all sustainable ways of life and economic systems that respect ecological boundaries.
Filed in German · English published by the European Commission
UL Solutions response to the Public Consultation on Construction Products – Review of EU rules UL Solutions respectfully submits these comments in response to the draft legislative proposal for a regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011, published in March 2022.
CEN and CENELEC welcome the objective of the proposal to achieve a well-functioning single market for construction products, avoid overlap of EU legislation and contribute to the EU objectives of the green and digital transition. A summary of the CEN and CENELEC key messages is presented below.
TEPPFA contribution to the proposal for a revised Construction Products Regulation. TEPPFA, the European Plastic Pipes & Fittings Association, welcomes the publication of the Commission’s proposal for a revised CPR and fully supports its objectives to achieve a well-functioning single market for construction products as well as to contribute to the green and digital transition for a resource-efficient and…
AFELMA fully subscribes to the necessity, as identified by the European Commission, to revise, repair and complete the EU Construction Products Regulation (CPR, EU 305/2011). We share the spirit, intentions and objectives of the overall Commission proposal as many of its specific constituents largely reflect the subjects / areas of attention put forward by our association in its contribution to the initial…
The Confédération de l’Artisanat et des Petites Entreprises du Bâtiment (CAPEB) is a employers’ union representing construction companies, the majority of which are in the craft industry. It has more than 59 000 member companies. Many companies involved in the woodworking, metalling or stone trades manufacture some of the construction products which they themselves use in construction works.
Filed in French · English published by the European Commission
Common position of the Administrative Cooperation Group for Construction Products on Commission’s proposal for a Regulation of the European Parliament and of the Council laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011 We would like to thank you for the opportunity to comment on Commission’s proposal for a…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German Institute for Quality Assurance and Certification (RAL Deutsches Institut für Gütesicherung und Kennzeichnung e. V. – RAL) acknowledges, with great interest, the Proposal put forward by the European Commission for a Regulation of the European Parliament and of the Council laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing…
Hello APMS is the only French trade union of microstation manufacturers. Since 2010 he has been representing the profession before the legislator and has been involved in standardisation work. It creates information and promotion measures for the various public and private bodies in order to highlight the environmental and economic performance of Micro-waste Water Treatment Stations.
Filed in French · English published by the European Commission
CEI-Bois We are a responsible Industry CEI-Bois feedback to the European Commission’s consultation on the proposed revision of the Construction Products Regulation As the representative of the European Woodworking Industries, CEI-Bois welcomes the European Commission’s proposal to revise the Construction Products Regulation (CPR) as a legal framework whose overarching goal is to remove any remaining obstacles to…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
POSITION FFMI SUR LE PROJET DE RÉVISION DU RPC INTRODUCTION LA FFMI La Fédération Française des Métiers de l’Incendie (FFMI) représente les intérêts moraux et professionnels des constructeurs, sociétés de services, acteurs majeurs de la sécurité incendie en France. 300 entreprises, qui emploient 25 000 salariés, au service de la protection incendie, pour un marché annuel d’environ de 3 milliards d’euros.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
22-07-08 Feedback to the EU proposal for a revised CPR (Construction Products Regulation), July 2022. I represent the Wood Packaging Committee within Swedish Wood and Swedish Forest Industries Federation. We support the following answers from our German colleagues.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products.
The ATANC Loire Bretagne et Outre-Mer and ARTANC are two associations bringing together the technicians of the Public Services for Non-Collective Sanitation (SPANC), working in local authorities, responsible for checking the installations when they are set up and in operation.
Filed in French · English published by the European Commission
Many new approaches have been taken in the draft CPR, which at the outset are logical for the future of Europe. However, many text areas seem as if this was intended exclusively for strucural engineering works. However, analogous to the developments in the digitalization of construction (BIM), the processes in civil engineering works (roads, bridges, railway etc) must be thought of differently.
European Single ply Waterproofing Association (ESWA) and its members support a steady transition towards an increasingly greener, harmonised, and more resilient European circular economy and to the extent possible we will help reaching the Green Deal goals set.
In the context of general digitalisation, harmonised conditions for information on construction products should be introduced. CEN/TC 442 standards can be used as a basis. The Construction Products Regulation should also be compared with other EU initiatives or regulations (e.g. Digital Product Pass, Sustainable Product Initiative, Energy Performance of Buildings or Energy related Products).
Filed in German · English published by the European Commission
MOSS 11 JULY 2022 BYGGEVARERE GJENNOMGANG AV EU — RULES ACTION FROM AVAIR NORWAY TO THE FURTHER ARBEID OF THE COMMUNITY. Avløp Norge is a Bransjeforening for suppliers av typegodkjente minirenseanlegg. Weaning targets are just just competitive wet members and promote minirenseanlegg as a powerful solution to protect wet fields’ drinking sources and vulnerable wanner areas.
Filed in Danish · English published by the European Commission
The Industrieverband Bau- und Bedachungsdarf represents the interests of businesses from Germany, the Netherlands, Austria and the Principality of Liechtenstein. Our member companies are predominantly medium-sized companies that develop, produce and market products and services for construction, technical building equipment, plant building and renewable energy production and distribution.
Filed in German · English published by the European Commission
EUROVENT CERTITA CERTIFICATION, certification body, acredited for HVAC fields, has scrutinized with great interest the European Commission's proposal for the revision of the construction product regulation, dated March 30, 2022 and supports AFOCERT (association des organismes certificateurs des produits et ouvrages de la construction) & AIMCC (Association Française des Industries des Produits de Construction)…
The European Panel Federation (EPF) welcomes the possibility to provide feedback on the Proposal for a Regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.
Ecodes welcomes the European Commission's proposal to revise the Construction Products Regulation (CPR), underlining the effort to align it with the environmental principles included in the Eco-design Regulation for Sustainable Products (ESPR). However, the current proposal is not aligned with the Paris Agreement, mainly in treating embodied emissions inherent in construction materials.
In the context of the ongoing revision of the Construction Products Regulation (EU 305/2011), the Fédération Nationale du Bois (professional organisation representing manufacturers, repackers and letters of pallets) wishes to withdraw the unjustified extension to packaging from the definition of “construction product” as specified in Article 3 of the proposed text.
Filed in French · English published by the European Commission
Position of the FRENCH FEDERATION FOR TILES AND BRICKS (FFTB) on the proposal for a new regulation on construction products The French Federation for Tiles and Bricks (FFTB), professional union of clay building products has taken note of the proposal for revising the Construction Products Regulation (CPR) of the European Commission (EC) released on March 30, 2022.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sirs We write with concern around the proposal for the revision of the construction product regulation (CPR) with document COM (2022) 144 final from 2022-03-30. We appreciate the efforts from of the European Commission to include sustainability and environmental aspects into the proposal for the revision of the construction product regulation (CPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Copper Institute (ECI), welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR), in particular, ECI welcomes the stronger attention given to Life Cycle Assessments and circularity aspects. Copper is a highly circular material and benefits of recyclability must be considered for metals to better reflect advantages they can bring to the construction sector.
Feedback on the proposed revision of the Construction Products Regulation from VA og VVS Produsentene - VVP (Association of Norwegian manufacturers and suppliers of plumbing, heating, and sanitary products) VVP appreciates the possibility to give feedback on the proposed revision of CPR, Construction Product Regulation, and will present our point of view in the attachment.
European Plastics Converters (EuPC) and its members support a steady transition towards an increasingly greener, harmonised, and more resilient European circular economy and to the extent possible we will help reaching the Green Deal goals set.
FederlegnoArredo (FLA), the Italian Federation of Woodworking, Cork, Furniture, Lighting and Furnishing Industries warmly welcomes the recent initiative of the European Commission to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products and to unlock the sector’s growth and jobs potential, promoting the definition of environmental goals as part of…
Key positions by the Austrian Association for Building Materials and Ceramic Industries on the proposal for the new CPR We acknowledge the release of the long-awaited Commission proposal for a new Construction Products Regulation which is aiming at solving the implementation issues construction manufacturers are facing and adapting this key piece of legislation to the policy goals set by the Commission as described…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The FNB welcomes the revision initiative of the CPR. Indeed, several draft revisions of harmonised standards for wood products have been blocked or have not been published in the OJEU. The objective of simplification is also crucial to progress. It is clear that circular economy aspects and environmental data are issues to which France and in particular wood product professionals are particularly sensitive.
Filed in French · English published by the European Commission
The Danish Construction Federation contribution to the proposal for a revised Construction Products Regulation. Our response to the consultation is divided into positive and negative remarks on the proposal. Positive elements of the proposal: • The core elements from the existing CPR are kept • Increased focus on sustainability • Improvement on market surveillance and product contact point • Introduction of…
The Swedish Betong Association is a trade association for companies that produce factory concrete, carry out concrete pumping and companies that manufacture and/or assemble concrete products. In Sweden, the concrete and cement industry translates a total of around SEK 30 million per year and employs almost 9 000 people.
Filed in Swedish · English published by the European Commission
ARGE – The European Federation of Associations of Locks and Builders Hardware Manufacturers represents around 250 companies and 50,000 employees in Europe who generate an annual turnover of close to € 10 billion with developing, manufacturing, and marketing locks and building hardware.
CPR must address and create a level playing field for embodied carbon in products in the construction sector as a matter of urgency, starting with cement, steel and metals due to their outsized materiality. For this, CPR must: 1.
Construction Products Europe contribution to the proposal for a revised Construction Products Regulation. Construction Products Europe acknowledges the release of the long-awaited EC proposal for a new Construction Products Regulation which aims at resolving the implementation issues impacting our industry and that we have regularly brought to the attention of the EC.
Portuguese Technical Committee CT 139 “Sanitary appliances” – Answer to exclusion of sanitary appliances from the CPR The Portuguese industrial sector of the production of sanitary appliances appreciates the efforts of the European Commission to include sustainability and environmental aspects into the proposal for the revision of the Construction Product Regulation (CPR) with document COM(2022) 144 final from…
We congratulate the Commission on the publication of the long-awaited proposal for a revised CPR and fully support its objectives of achieving a well-functioning single market for construction products, as well as contributing to the green and digital transition of a resource-efficient and competitive construction industry.
The European Organisation for Technical Assessment (EOTA) welcomes the initiative of the European Commission to strengthen the internal market for construction products and transform the construction sector into a sustainable, resilient and smart industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Finnish Association of Construction Product Industries RTT thanks for the opportunity to submit its opinion on the draft for a new EU Construction Products Regulation. RTT supports the objectives set for the new CPR but has doubts as to whether the proposed new system would achieve these objectives in practice.
SNIP (the French gypsum and plaster organisation) brings together the manufacturers who produce and market gypsum, plaster and related products. It represents around 95% of the national production, all products together.
EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe. The organisation was founded in 1988 and has members from 19 countries, operating more than 100 production sites and producing around 18 million cubic metres of AAC annually.
COMMENT/PROPOSAL: Chapter V, Article 45, Point 1 of the proposed revised CPR currently reads: “A TAB shall be competent and equipped to carry out the assessment in the product area for which it has been designated.
Dear Sir or Madam, Studiengemeinschaft Holzleimbau e.V. (Studiegemeinschaft Holzleimbau e.V.) is a group of producers of glued-bearing wood products and firms that export engineering wood constructions. You will find our comments on documents CDR_COM_2022_144_1_DE_ACT_part1_v1 and CDR_COM_2022_144_1_DE_annexe_proposition_part1_v1 in the attached document.
Filed in German · English published by the European Commission
2022/TC/010 European Bitumen Association aisbl Boulevard du Souverain 165 B - 1160 Brussels, Belgium Tel.: [phone removed] Fax: [phone removed] [email removed] Revision of Construction Products Regulation [Regulation (EU) No 305/2011] Eurobitume Input into Open Feedback Option Introduction On 2nd May 2022, document 2022/TC/006 on “Revision of Construction Products Regulation [Regulation (EU) No 305/2011] – Status”…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Federation of the Parquet Industry Fédération Européenne de l’Industrie du Parquet Föderation der Europäischen Parkett-Industrie Address: Rue Montoyer 24/box 20, BE-1000 Brussels TP: +32 2 287.08.77 E-mail: [email removed] - www.parquet.net - www.realwood.eu VAT BE 0655.762.263 European Commission Brussels, 11 July 2022 FEP feedback to the European Commission proposal for a revised Construction Products…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Norwegian Water is a national association representing Norway`s water industry. It acts on behalf of the members, which are mainly municipalities and companies owned by the municipalities. Norwegian Water in total represents approx. 320 municipalities, with 96 % of the population. Norwegian Water also has affiliated members like consultants, producers, suppliers and educational and research institution.
2022-07-04 Byggprodukter – översyn av EU-reglerna, COM(2022) 144 final, 2022/0094, (Byggproduktförordning) Nedan redovisas Byggvarubedömningens svar på EU-kommissionens förslag till en ny byggproduktförordning avgränsad till de delar som påverkar vårt verksamhetsområde.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Quality Assurance Association for Pipe Supports ("Gütegemeinschaft Rohrbefestigung") is an independent, multi-manufacturer organisation dedicated to, among other things, establishing technical rules and standards for quality assurance purposes. The Gütegemeinschaft Rohrbefestigung has been recognised by RAL, the “German Institute for Quality Assurance and Certification”, since December 2003.
Technology companies represent Swedish industry. Together, our 4 300 member companies account for one third of Sweden’s exports. Common to our member companies is that they develop world-class goods and services and that almost all sales take place in global competition. While the member companies solve many of the challenges of our time, they create growth and prosperity in Sweden.
Filed in Swedish · English published by the European Commission
EPF amendments proposals on the Proposal for a Regulation laying down harmonised conditions for the marketing of construction products (CPR) 2022 CPR revision proposal - COM(2022) 144 final Article 1 Subject matter This Regulation establishes harmonised rules for the making available on the market and direct installation of construction products, regardless of whether undertaken in the framework of a service or not…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
1) Considering the numberless environmental requirements imposed by the different European standards (REACH, EPBD, SPPI, CPR,… etc), we wish to underline that these must necessarily overlap. 2) It is necessary to clarify the definition of “USED construction product” and who is the real responsible of performance and conformity of it.
We welcome the ambition of the European Commission to revise the Construction products regulation. We call the European Commission policy makers to revise the CPR with the European Industry competitiveness in mind, as an integral contributor the EU Green Deal objectives for a just transition towards a circular economy, where the construction sector is contributing to the net zero GHG emissions objective in 2050.
Datum Ref. Ares(2022)5022668 - 09/07/2022 Diarienummer 2022-07-01 Dnr 2022/216 Europeiska Kommissionen Svar på remiss avseende Byggprodukter – översyn av EU-reglerna, COM(2022) 144 final, 2022/0094, (Byggproduktförordning) Sammanfattning Micasa Fastigheter välkomnar revideringen av byggproduktförordningen där information om byggprodukter utökas med fakta om miljö, hälsa och säkerhet.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
1)We support the fundamental objectives of the European Commission set out in this proposal in the areas of environmental and consumer protection, resource efficiency, circular economy and improvement of the internal market for construction products and speeding up the harmonisation of the standardisation of construction products in the Union.
Filed in German · English published by the European Commission
FIEC wishes to thank the European Commission for the opportunity to provide feedback on the proposal for a revised Construction Products Regulation. FIEC will analyse the proposal in more detail in the coming weeks. For now, it would like to draw the Commission’s attention to the points listed below. Detailed comments can be found in the attached file. 1.
A functioning movement of goods without pallets, crates, export packaging, cable/rope drums, is unthinkable. The material flows of EU internal market would not function without this packaging and means of transport. Nor would the construction, building and construction product sectors.
IRSTEA (now INRAE) coordinated, with the help of many French public actors at different scales in the territory, an insituous study of the quality of discharges and the maintenance/renewal of parts of more than 200 ANC installations.
Filed in French · English published by the European Commission
Input in EU Commission Consultation 12 July 2022 European Commission proposal COM (2022)144 regarding the Review of the Construction Products Regulation (CPR) 305/2011 laying down harmonised conditions for the marketing of Construction Products “Revise, Repair, Complete” Eurima is the European Insulation Manufacturers Association representing the interests of all major Mineral Wool (Glass and Stone Wool) insulation…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
8 July 2022 KNAUF INSULATION FEEDBACK ON THE COMMISSION PROPOSAL FOR A REVISED CONSTRUCTION PRODUCTS REGULATION The European Commission (i.e., Commission) proposal for a revised Construction Product Regulation (CPR) confirms that the harmonised rules on producing and marketing construction products across the Union shall remain in one piece of legislation with a view to preventing a fragmented1 regulatory framework…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ARTANC Adour Garonne and the ATANC Loire Bretagne et Outre-Mer are two associations bringing together technicians from the Public Services for Non-Collective Sanitation (SPANC) in the river basins concerned, which represents about half of the French territory.
Filed in French · English published by the European Commission
Europacable, the voice of Europe’s wire and cable industry, calls on EU Institutions to improve the proposal for a new Construction Products Regulation (CPR). The aim should be to ensure legal certainty for the promotion of sustainable construction products and improved safety levels all across Europe while recognising the importance of an open and transparent market-driven standardisation.
First of all, we would like to express our gratitude to you for supporting and allowing us to comment. As Efectis Era Avrasya we refer to the file F33213250 jointly submitted on behalf of the international Efectis Group. We are always ready to support the development process of CPR.
Many thanks for the opportunity to provide feedback to the proposal from the European Commission for a new regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 (market surveillance regulation) and repealing Regulation (EU) 305/2011 (CPR).
Please, find attached Stora Enso's full feedback to the 'Construction products – review of EU rules'. Stora Enso is a renewable materials company that employs more than 18 000 people in the EU. We deliver renewable and circular products that store carbon and provide low-carbon emission alternatives to non-renewable materials.
EAPA feedback on the new proposal of the European Commission laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011 4 July 2022 The European Asphalt Pavement Association (EAPA) is the voice of the asphalt paving industry in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Thank you for allowing our feedback. As Efectis Nederland we refer to the file F33213250 jointly submitted on behalf of the international Efectis Group. We also would like to express our appreciation for the efforts to harmonize the CPR with other (EU) legislations, programs and objectives, especially in regard to a sustainable construction sector.
As notified bodies in France, Nederland and Turkey, Efectis has scrutinized the proposal for revision of the Construction Product Regulation. Due to the limited commenting period and the extent of the proposal, we have focussed our analysis to the point where Notified Bodies are involved. We recognise the extent of the revision, the objective to solve some of the challenges identified during the consultation period.
ASQUAL considers that this project, based on option D, is extremely complicated and extensive and ultimately far removed from the preference for option A expressed by interested parties in all investigations. The addition of new environmental protection provisions is a step in the right direction and is in line with new constraints since 2011 (circular economy in particular).
Filed in French · English published by the European Commission
HELUZ Group is a group including, inter alia, companies manufacturing bricks and insulating glass. It currently employs more than 500 employees and is active on the market in six EU Member States. The group has always taken a conscientious approach to both the technical and environmental safety of its products.
Filed in Czech · English published by the European Commission
Position Paper Plastics Europe initial comments on the revision of the Construction Products Regulation (CPR) Key Points: • Plastics Europe supports a future-orientated Construction Products Regulation – one that recognises the value of plastics as a high-performance, durable, and sustainable construction material.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Spanish Institute of Cement and its Applications,IECA, welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products. However, we would like to take the opportunity to highlight some very relevant aspects that shall be considered in the ongoing process. Please find these aspects in the attached file.
The EAPFP welcomes the proposal for a revision of the CPR, but has some points of concern, mainly the validity and impact of the EAD/ETA system now they are outside the harmonized zone. Other concerns are in the field of the administrative burden, and the differences of opinion between CEN and EOTA.
The EFFCM highly appreciates the EU Commission to continue with CE marking. The EFFCM have a limited number of points they would like to bring to the attention of the EU Commission: - (CEN) test procedures incorporated in harmonized standards, but unilaterally being modified by EOTA, risking confusion on the actual meaning of declared performances; - The administrative burden.
The draft CPR is in many parts unclear, poorly user-friendly and sometimes impossible to implement. The objectives of strengthening the internal market for construction products and increasing competitiveness cannot be achieved.
Filed in German · English published by the European Commission
Etex is a global building material manufacturer and pioneer in lightweight construction and would like to highlight several points related to the current proposal: •Level of ambition: The proposals made by the Commission seems to enhance the EU’s regulatory power in the field of construction product manufacturing and we would like to understand if the EU Commission is looking at the opportunity to create dedicated…
Dear Sir or Madam, from our point of view of the skilled trades, regulation has become even more complex and has a considerable effort in terms of further evidence for construction products. The German carpentry association is affected accordingly, as our member companies with between 1 to 60 workers (Ø 5,4) usually also produce or use construction products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Construction Products Regulation (CPR) is key to ensure fire safety in buildings – any review must keep the current safeguards The Modern Building Alliance (MBA): - welcomes the CPR review proposal as it confirms the fundamentals of the internal market legislation. - supports market continuity with consistent harmonised implementation of testing and classification standards.
General argument to reverse the decision to exclude sanitary appliances from the CPR We appreciate the efforts from of the European Commission to include sustainability and environmental aspects into the proposal for the revision of the construction product regulation (CPR) with document COM(2022) 144 final from 2022-03-30. However, we are deeply concerned about the exclusion of sanitary appliances from the CPR.
The French Association of Expanded Polystyrene Insulation in the Building Industry (AFIPEB) represents the converters of expanded polystyrene and the producers of expandable polystyrene. AFIPEB is mainly involved in the promotion of new insulation solutions for the renovation and the construction of more economical, ecological and efficient buildings.
The Swedish Institute of Steel Construction appreciates the opportunity to provide feedback to the European Commission on the proposal of a new Construction Product Regulation. In general, we support the intention of replacing the CPR. See attached reply from SBI - Swedish Institute of Steel Construction.
Handläggare: Maria Löfholm Datum: 2022-07-07 Dnr: SB 2022/384 Till Europeiska Kommissionen Remiss av Kommissionens förslag till en ny byggproduktförordning, en översyn av EU-reglerna, COM(2022) 144 final Sammanfattning Svenska Bostäder välkomnar revideringen av byggproduktförordningen där information om byggprodukter utökas med fakta om miljö, hälsa och säkerhet.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Commission Byggmaterialindustriernas svar på kommissionens förslag till ny byggproduktförordning Byggmaterialindustrierna är en paraplyorganisation för företag och branschorganisationer som tillverkar och arbetar med byggmaterial inom alla byggmaterialområden. Byggmaterialbranschen i Sverige omsätter omkring 170 miljarder SEK och sysselsätter drygt 50 000 personer.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome the publication of the proposal for the revision of the CPR and would like to take the opportunity to provide feedback. A well-functioning internal market for construction products based - as the main route - on harmonised standards as a tool for technical language and harmonised assessment methods is urgently needed.
Norske Trevarer (The Norwegian Federation of Woodworking Industry) appreciates the opportunity to provide feedback to the European Commission on the proposal of a new Construction Product Regulation. In general, we support the intention of replacing the CPR as set out in the Context of the Proposal. However, we do not see how the proposal will solve the addressed problems for certain issues.
Representative of TC 163 WG4 - Baths and Showers Appliances, we as a group present our feedback in the attached file: In summary Concerns of the extra burden placed on manufacturers but we understand the efforts of the commission to include the sustainability into the CPR.
Fire Safe Europe (FSEU) welcomes the revision of the Construction Products Regulation (CPR) as a crucial step forward to boost the internal market for construction products and ensure that the regulatory framework in place is fit for making the built environment deliver on our sustainability and climate objectives.
Dear Madam/Sir, The revision of the CPR emphasizes the promotion of circular economy principles and sustainability by the use and manufacture of construction products which contributes to resource-saving. In art. 22, while the CPR draft stresses the use of recycled wastes, it overlooks the use of industrial by-products.
The Norwegian council of water exposed rooms (FFV) support the view of SINTEF Community below, and are deeply concerned about the consequences for health and water leakage development in the future if this is implemented.
The evaluation of the Construction Products Regulation (CPR), opinions of the REFIT platform as well as Member States and stakeholders feedback pointed clearly to the shortcomings of the framework, hindering the functioning of the single market for construction products, and therefore failing to achieve the CPR’s objectives Therefore, CAPIEL welcomes a revision of the CPR to improve the situation with a particular…
Dear Sir or Madam, please find enclosed the opinion of the European Quality Association for Recycling e.V. on the amendment to the EU BauPVO with the request that it be taken into account. Yours sincerely, [name removed] Management EQAR European Quality Association for Recycling Kronenstrasse 55-58 10117 Berlin
Filed in German · English published by the European Commission
The evaluation of the Construction Products Regulation (CPR), opinions of the REFIT platform as well as Member States and stakeholders feedback pointed clearly to the shortcomings of the framework, hindering the functioning of the single market for construction products, and therefore failing to achieve the CPR’s objectives Therefore, CECAPI welcomes a revision of the CPR to improve the situation with a particular…
SINTEF Community SINTEF Community Address: Postboks 124 Blindern NO-0314 Oslo NORWAY Switchboard: [phone removed] [email removed] Enterprise /VAT No NO 919 303 808 MVA Feedback on the proposed revision of the Construction Products Regulation PROJECT NO/FILE CODE DATE 2022-07-06 CLASSIFICATION Unrestricted Introduction SINTEF welcomes the opportunity to give feedback to the proposed revision on the Construction…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Euralarm, representing Europe’s electronic fire safety and security industry, a sector whose products are already largely subject to the existing CPR, welcomes the publication of Commission’s proposal for a new CPR.
For the industry developing their structural products, the main problem is that updates of harmonized standards are not being cited in the official journal of EU. The development of standardized products has come to a halt. It is a wish that the CPR revision will remedy this situation. However, the timeline is too long, and faster solutions are needed.
Following the launch of the European Commission’s proposal for a Regulation laying down harmonised conditions for the marketing of construction products, the International Union of Property Owners wants to reiterate the importance of involving both the building sector and the construction ecosystem in the green and digital transition of the EU economy.
The Austrian Precast Concrete Association generally welcomes the circular economy and the promotion of the use of recycled material. However, the specification of mandatory minimum recycling contents for the production of precast concrete parts and prefabricated concrete products is viewed extremely critically in the current draft of the CPR and should therefore be rejected for the following reasons: Problems with…
European Aluminium welcomes the release of the long-awaited Commission proposal for a new Construction Products Regulation which aims at solving the implementation issues that our members as construction product manufacturers and system providers have been over the last years.
Dear Sir/Mademe Please find in enclosed pdf-document the suggestions and opinions of the Swedish Paint and Adhesive Association about the proposal for the new CPR. Should you have any questions, please contact: [email removed].
As the EU trade association representing building glass manufacturers and fabricators in Europe, Glass for Europe welcomes the new CPR proposal since it reinforces the single market principles for construction products and supports the construction industry’s move towards greater sustainability.
Jernkontoret, the Swedish iron and steel producers' association, supports the overall problem description in the proposal. "Greening" of construction products have an important role in the transition to circular economy and decreasing climate impact. Harmonised legislation at EU-level is needed to create an inner market with fair competition.
Public Housing Sweden is an interest and industry organisation for the municipality and private owned public housing companies in Sweden. We represent more than 900 000 apartments and over 300 companies in Sweden. Public Housing Sweden welcomes the revision of the Construction Products Regulation, where information on construction products will be expanded with information on the environment, health and safety.
220705 Kommentarer om EU-kommissionens förslag till en ny byggproduktförordning Dnr Fi2022/01190 Vi tackar för möjligheten att inkomma med synpunkter på rubricerat förslag. SundaHus har tagit del av remissen Dnr Fi2022/01190 Kommissionens förslag till en ny byggproduktförordning och lämnar nedanstående synpunkter.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEICA - POSITION PAPER Brussels, 04 July 2022 Position Paper of the European Association of Adhesives and Sealants Industry on the Commission Proposal for the revision of the Construction Products Regulation (CPR) FEICA, the Association of the European Adhesive & Sealant Industry, is a multinational association representing the European adhesive and sealant industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comments on Document „Proposal for a Regulation of the European Parliament and of the Council laying down harmonized conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011” 2022/0094 (COD) 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
One of the overarching goals of the draft of the CPR is, among other things, the resource-saving manufacture of construction products and the promotion of circular economy and sustainability in the construction industry. This goal is considered in the new draft of the CPR by imposing environmental obligations on the manufacturer in Art. 22 of the draft of the CPR.
One of the overarching goals of the draft of the CPR is, among other things, the resource-saving manufacture of construction products and the promotion of circular economy and sustainability in the construction industry. This goal is considered in the new draft of the CPR by imposing environmental obligations on the manufacturer in Art. 22 of the draft of the CPR.
Remissvar 2022-06-30 BYGGPRODUKTER – ÖVERSYN EU REGLERNA Svar på remiss avseende Byggprodukter – översyn av EUreglerna, COM(2022) 144 final, 2022/0094, (Byggproduktförordning) Bakgrund Kommissionen har lagt fram förslag till ny byggproduktförordning att gälla inom EU.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Article 2.3 excludes some products that have been covered by the CPR so far such as systems treating wastewater. For indivual wastewater units currenly covered by the CPR and the hEN12566 standard, what is envisaged to replace existing provisions ? E.g. will the on-going revision of the Urban Waste Water Directive include provisions for these indivual wastewater systems?
CPR rev Comments IFT Rosenheim Article GE Content GE EXPLANATORY MEMORANDUM NB 0757 2022-07-01 Comment The following comments primarily focus on our concerns as a notified body. There are other major concerns as according to our experience, the foreseen requirements for reporting, data storage and assessment of environmental product aspects as well as proof of designed product life cannot be met by those of our…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Summary Sweden Green Building Council welcomes the Commission's intention to broaden the Construction Products Regulation so that sustainability requirements are included. However, we reject parts of the Commissions problem description and would like the Commission to recognize the forerunners in the EU when it comes to setting sustainability requirements for products and buildings.
Position du SNMI sur la proposition de révision du Règlement Produits de Construction (RPC) Le Syndicat national des mortiers industriels (SNMI)1 accueille favorablement la proposition de révision du règlement sur les produits de construction (RPC) présentée par la Commission européenne le 30 mars 2022.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find attached our feedback to the public consultation on the construction products regulation (CPR). In general, we support the intention of revising the CPR as set out in the Context of the Proposal. However, we do not see how the proposal will solve the addressed problems for certain issues.
Norwegian Building Authority We welcome the revision of the Construction Products Regulation (CPR), Regulation (EU) No 305/2011. We support the aim to create a better functioning single market for construction products and contribute to the green and digital transition, and product safety of construction products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sirs You'll find enclosed the comments of Cofrac on the "Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011". Best regards [name removed] [name removed] manager/ Certification department
FACHVERBAND SANITÄR-KERAMISCHE INDUSTRIE e.V. Ref. Ares(2022)4785901 - 30/06/2022 2022-05-30 Draft revision of Construction Products Regulation COM(2022) 144 final from 2022-03-30 Comments of FECS -TC We appreciate the efforts from of the European Commission to include sustainability and environmental aspects into the proposal for the revision of the construction product regulation (CPR) with document COM(2022) 144…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Cerame-Unie, the European Ceramic Industry Association, welcomes the publication of the Commission’s proposal for a revised CPR and fully supports its objectives to achieve a well-functioning single market for construction products as well as to contribute to the green and digital transition for a resource-efficient and competitive construction industry.
ELA position is to ensure that Lifts, escalators and moving walks and lifting appliances as well as their components are excluded from the scope of CPR. In the current proposal, COM (2022) 144 final, the commission excludes only lifts and escalators plus components.
The Wienerberger group operates 215 production sites in 28 countries with 17,624 employees and is the world’s largest producer of clay bricks and blocks and the market leader in clay roof tiles in Europe as well as concrete pavers in Central-Eastern Europe and pipe systems in Europe.
SBMI notes that the new document is not shorter and clearer as was the intention of the revision, but instead longer and more complicated. The revised document adds new terms, concepts and processes that complicate rather than clarify.
The careful analysis of the proposal from the European Commission identified points which would result in a severe impact to manufacturer. Some of these are for example fixed deadlines for harmonized technical specifications, marking requirements, validity of notified bodies certificates and manufacturer obligations. The attached document list these and other points in detail and propose how they shall be improved
EuroWindoor appreciates the opportunity to give feedback to the proposal from the European Commission for a new regulation replacing the CPR. EuroWindoor is a firm supporter of the concept of the single European market for construction products and sees the EU CPR as the main instrument to obtain a well-functioning internal market.
UEPG Initial Response to the proposal for the revision of the Construction Products Regulations UEPG welcomes the release of the long-awaited proposal for a new Construction Products Regulation aimed at resolving the current operational issues aggregate producers are facing and modifying the Regulation in line with the objectives set by the Commission in the Green Deal.
Stockholm, 28. June 2022 Nordic Ecolabelling feedback on the EU Commissions proposal for a Regulation laying down harmonised conditions for the marketing of construction products Thank you for the proposal for a Regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011 and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
While the revision of the CPR is a serious progress towards the EU targets to reduce by 55% the GHG emissions by 2030 and achieving climate neutrality in the EU by 2050, there still are important missing points to be addressed.
Dear European Commission, The GNB (Group of notified bodies) has organized an extraordinary meeting on the 12th of May, dedicated to the proposal for a revision of the CPR releazed on the 30th March. The French NBs have scrutenized this proposal, exchange their questionnings and understandings.
Article 2(3) of the proposed Regulation states: This Regulation shall not apply to: traffic signalling products. It is unclear whether products such as traffic lights and variable signs will be regulated within a different regulation than the CPR. The impact assessment report (30.03.2022) does not clarify the consequences for these products and the associated optical CE approval.
Comments on Document „Proposal for a Regulation of the European Parliament and of the Council laying down harmonized conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011” 2022/0094 (COD) 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
While the revision of the CPR has been triggered by the adoption of the EU Climate Law, which aims at reducing 55% of GHG emissions by 2030 and achieving climate neutrality in the EU by 2050, the legislative file lacks the understanding and tackling of embodied carbon. Nowadays, the reported emissions from buildings only consider operational use and oversee their whole-life impact.
The original CPR had an issue with products with multiple intended uses - falling under scopes of two or even more harmonised EN standards. And after studying the revised proposal, cannot see this issue solved. And examples presented in attached presentation.
In view of the elements mentioned below, it is essential that the sector’s requests can be heard and that a dialogue can be established between its representatives and the European institutions. This dialogue should focus on legislative simplification so as not to increase the administrative burden on the actors in the sector, but also to avoid compromising synergy with the rest of the European legislative…
Filed in French · English published by the European Commission
The German Fastener Association has reviewed the proposed revision of the CPR and added it´s remarks related to mechanical fasteners made from iron or steel. The German Fastener Association is requesting the EU-Commission to consider the following adjustments to meet the needs of the German and European Fastener Industry.
Good days, I am writing to you on behalf of AFASEMETRA. Our Association, which has for more than 35 years been committed to the quality of signalling products, is made up of nine leading companies in the sector, namely API MOVILIDAD, S.A.; DÍEZ, S.A.; GIVASA, S.A.; INDUSTRIAS SALUDES, S.A.U.; PROSEÑAL, S.A.; REYNOBER, S.A.; SIGNPOSTS VILLAR, S.A.;TEVASEÑAL, S.A. and VISEVER, S.L.
Filed in Spanish · English published by the European Commission
It's important to simplify procedures: EOTA approach is to be used for all innovative products while a specific path for product standards related with CPR should be funded in order to accelerate standardization at CEN level.
We are the Spanish Association for Manufacturers of Ceramic Sanitaryware (ANFACESA). Enclose you will find our comments to the Draft revision of Construction Products Regulation COM(2022) 144 final from 2022-03-30. Best regards [name removed] Secretary General of Anfacesa Spain
PRODUCTS UNDER MANDATE M/110 SANITARY APPLIANCES (HEALTH CASSETTES PER TOILET) SHOULD REMAIN UNDER THE CPR AS THEY ARE KEY PRODUCTS FOR PERSONAL HYGIENE. THEY ALSO CONTAIN IMPORTANT HEALTH REQUIREMENTS, AS COMPONENTS WITHIN RISK BOXES MUST PROTECT THE DRINKING NETWORK AGAINST POLLUTION. THE EXCLUSION OF SUCH PRODUCTS FROM THE CPR WOULD UNDERMINE THIS REQUIREMENT, WITH IMPORTANT CONSEQUENCES.
Filed in Italian · English published by the European Commission
The draft revision of the Construction Products Regulation was published at the end of March 2022 by the European Commission, with negotiations now to last until at least 2023. CLER — Energy Transition Network proposes its contribution to this draft text, which has the potential to contribute to reducing environmental impacts throughout the life cycle of buildings, including carbon emissions.
Filed in French · English published by the European Commission
FRENCH ASSOCIATION OF DOORS, GATES, BLINDS AND SHUTTERS MANUFACTURERS POSITION ON THE REVISION OF THE CONSTRUCTION PRODUCTS REGULATION General remarks Reasons for revising the CPR The introduction of the current projet for the revision of the CPR states that the main problem for revising the document is that the single market for construction products has not been achieved.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Key positions by the Austrian Federal Economic Chamber There are several issues of concern that require further clarifications. 1. Scope (Article 2) The proposal presented by the Commission, while excluding some products that are covered by the current CPR, seeks to extend the scope of the current Regulation to include families of products which currently are not considered as construction products (3D-datasets…
The Construction Products Regulation Revision is key: The well-functioning European Single Market for construction products is a major prerequisite to promote affordable construction and renovation activities in order to enable an effective fight against climate change.
Good days I note the following proposal in respect of standard EN 12676 and the obstacle to affixing the CE marking in accordance with the abovementioned standard. There is only one notified body (Polish ITB), depending on the base, we have been in that laboratory in Warsaw without any guarantees from the laboratory to obtain the tests. We are talking about times.
Filed in Spanish · English published by the European Commission
I enclose the comments of the Public Procurement Authority. Comments are limited to matters relating to public purchasing and procurement. The procurement directives also deal with construction works products. There are rules on the order of priority between harmonisation, standards and treatment of equivalent products, there are rules on labelling. The procurement directives cover sustainability aspects.
Filed in Swedish · English published by the European Commission
Contributions to doc. COM_2022_144_1_EN_ACT_part1_v10 --- by Mario Sanvito – Consultant for standards, quality, CE marking and in name of ACMI Association of the Italian manufacturer of technical doors and shutter ( Fire, energy saving, burglar resistant, manual and or powered /automatic doors and similar) --- 28 April 2022 --- Pag.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Harmonised standards (hENs) are powerful tools to ensure a uniform internal market within the European Union. The existence of national marks and certification requirements has historically been a financial and administrative burden on the industry and their removal (and prevention of proliferation) was welcome.
Speaking as a researcher with the professional experience in both the public and private R&D construction sectors and a member of the scientific associations making their voice heard in science policy, here applied to the natural and artificial resources of the construction industry particularly, I would like to express my honor to contribute and call the EU attention to every necessary arrangement regarding the…
The European Association for External Thermal Insulation Composite Systems (EAE) welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products.
PU Europe, representing the European polyurethane insulation industry, welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment for the future of the Construction Product Regulation (CPR) and would like to contribute with the following points in the attachment.
ECIA – the European Cellulose Insulation Association – welcomes the opportunity to comment on the Inception Impact Assessment and relevant possible scenarios lined out for the future of the Construction Products Regulation. ECIA is going to submit a full response to the consultation on options in the public consultation phase. Please find further comments in the attachment.
Please, find attached FEAD’s full feedback to the EC Roadmap on the Review of the CPR. FEAD, representing the private waste and resource management industry across Europe, welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR).
NSAI supports the overall position of CEN/CENELEC, (submitted separately). NSAI accepts that there are issues in relation to delivery of standards under CPR. However, Option A implies that the problems with the CPR are solely in relation to the delivery of standards by CEN/CENELEC, (also listed in Annex III of Refined Indicative options rev 2), which we find difficult to accept.
UL welcomes the opportunity to submit feedback on the European Commission’s Roadmap regarding the Review of the Construction Products Regulation (“CPR”). UL has a solid experience with construction products, especially with regards Regulation (EU) 305/2011, including as an independent entity providing product certification pursuant to the Construction Products Regulation, namely as it relates to fire safety…
The European Tyre & Rubber Manufacturers Association (ETRMA) and its members count around 4.300 companies in the EU employing directly 360.000 people. ETRMA tyre corporate companies represent globally 59 % of world sales and 7 out of 10 world leaders are our Member. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres.
Revising the CPR for sustainability The construction sector has a significant global impact on the environment, including here in Europe. Business-as -usual is no longer an option, but the current regulatory framework is not sustainability-ready.
Construction Products Europe industry cannot wait until the end of the review process to find solutions to the implementation problems related to the CPR. We are committed to work together to find short-term solutions so that the internal market for construction products can function in an efficient and effective way, in particular as regards the situation of harmonised standards.
The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association (pinfa) is in favour of Repairing CPR as described in policy options B & D and aligned with the position paper sent by Construction Products Europe (CPE), which we support. Pinfa welcomes the proposal to revise the CPR in coherence with the Green Deal.
Input VVVF and VLK on CPR Review: A full revision of the CPR is not supported by VVVF and VLK. Neither is a withdrawal of the CPR. The current systems should be maintained and only there were absolutely necessary changes should be made. It is of the upmost importance that no additional bureaucracy or administrative burden is added.
EUEW, the European Union of Electrical Wholesalers, welcomes the opportunity provided by the Commission to comment on the roadmap for the CPR review. Herewith, EUEW wishes to contribute the views of European electrical wholesalers to this public consultation.
Input NVTB on CPR review EU No 305/2011 NVTB does not support a complete revision of the CPR. Nor does NVTB want a withdrawal of the CPR. NVTB wants to keep all positive functions of the CPR as they are, as much as possible and see corrections in the CPR where it is really necessary. Where possible, solutions could and should be the result of additional policy, possibly outside the CPR.
The German Rubber Industry Association (wdk) is the umbrella organisation of German manufacturers of tyres and technical elastomer products (TEE). It represents around 170 companies with around 73 000 employees and a total annual turnover of almost eleven billion euros.
Filed in German · English published by the European Commission
Finnish Association of Construction Product Industries RTT RTT thanks European Commission for the opportunity to give feedback to this initiative. This inception impact assessment document must be regarded in connection with the more extensive and detailed commission document on the same subject Future options for the review of the Construction Products Regulation (CPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Danish Asphalt Pavement Association (Asfaltindustrien), representing the Asphalt producers in Denmark has the following feedback in relation to this review: - Having considered the most recent communications from the Commission regarding revision of the CPR.
EuroWindoor believes CPR in present format is overall well-functioning and therefore we are leaning towards Option A – Baseline scenario as defined as Option I in 2018. EuroWindoor is of the opinion that the insufficient quality of harmonized standards highlighted in the impact assessment is due to the fact that those standards being evaluated by the Commission now have been written before new guidance on…
EUMEPS position paper: how to fix the CPR? EUMEPS’ objectives Aug 2020 1. General EUMEPS , the European Association of producers of EPS insulation welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Small Business Standards (SBS) would like to make some comments on the role of the standardisation system in the current CPR. Standardisation plays a crucial role for the European construction sector. Construction product manufacturers and contractors strongly rely on standards and need them to remain aligned with changing market and regulatory demands.
The German Confederation of Skilled Crafts (ZDH) represents more than 1 million skilled crafts enterprises from Germany, many of which are also active in the construction sector. The Construction Products Regulation (CPR) and its revision is therefore of particular importance for ZDH and should take at least the following aspects into account: No obligation for CE-marking in case of individual production: The…
BIBM welcomes the European Commission’s initiative to solve the issues linked with the implementation of the Construction Products Regulation and improve it. BIBM fully supports the views of Construction Products Europe, who is not in favour of major changes in the CPR and definitely rejects the option of repealing this Regulation.
Sandbag welcomes the opportunity to comment on the Roadmap for the revision of the CPR and emphasises the role which the revised regulation should play in the achievement of the goals of the European Green Deal. The scope of the CPR must therefore be expanded to include the setting of environmental standards for construction projects.
Fire Safe Europe welcomes the opportunity to provide feedback on the inception impact assessment for the review of the Construction Products Regulation (CPR). On a general note, we would like to emphasise that the (CPR) is a key legislation for fire safety in buildings, which should be maintained and built upon.
The construction sector has a significant global impact on the environment, including here in Europe. Business-as -usual is no longer an option, but the current regulatory framework is not sustainability-ready. The planned revision of the Construction Product Regulation (CPR) can play an important role in reducing the impact of the sector, but incremental change will not be enough.
Summary : the Construction Products Regulation (CPR), together with several other elements such as national building codes & regulations, plays an essential role for the safety of construction works, including for fire safety of buildings. Any change considered must carefully assess the potential safety impact and the potential for improvement which can mainly be found in better implementation and enforcement.
My proposal would be to consider for which kind of products it is usefull to do CE marking. Since the start of CE marking a lot of steel products have to be CE marked while they are semi-finished products. After further processing there is always another kind of CE marking of the "more finished"that is used in it's application (e.g. construction steel according EN 10025).
SMEunited called for a consultation on the Review of the Construction Products Regulation among their members. As result SMEunited has concerns over the radical changes proposed by the European Commission in the Refined Indicative Options for the Review of the Construction Products Regulation of 8 April 2020, especially with regard to the possible discontinuation of the ETA route.
Safety & Security Division 17 August 2020 KRA ZVEI Safety & Security Division – Who we are The ZVEI represents the common interests of the electrical industry in Germany. It has over 1,600 member companies, together accounting for around 90% of all employees in the German electrical industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Support a resource efficient construction sector The construction sector generates a large proportion of society’s waste, during construction, management and demolition. The composition and climate impact of a construction product are crucial parameters for calculating the short-term impact and future risks for human health and environment.
Shortcomings: 1. Duplication of information between the CE-marking and the declaration of performance (DoP) unnecessarily increases the administrative burden without improving the quality of the information (see also evaluation report (SWD(2019)1770). 2.
Eurima welcomes and supports the continuous efforts of the European Commission to safeguard and improve the European internal market for construction products. We strongly believe that a well-functioning and transparent internal market is the basis for continued sustainable growth and a major enabler for a sustainable built environment.
European Copper Institute (ECI) represents the Copper Industry and welcomes the opportunity to provide input for the review of the Construction Products Regulation. Copper is used extensively (34% EU annual use) in technical building systems for delivering electricity, heating and water services.
The Belgian Technical Committee on Construction agrees, such as other stakeholders already mention in their comments, that the European Commission’s questionnaires fail to reflect adequately the problems that the sector faces in the practical implementation of the CPR (e.g.
The existing CPR gives manufacturers a wide opportunity to place their products in the harmonized area on the market. The often severely incomplete performance data in DoPs does not always provide users with adequate information. Despite minor shortcomings, the system provided by the current CPR is also fundamentally operational.
The Fédération Française du Bâtiment (Fédération Française du Bâtiment) pays attention to the work carried out by the European Commission in connection with the revision of Regulation (EU) No 305/2011 (‘the PRC’), which establishes ‘harmonised conditions for the marketing of construction products’.
Filed in French · English published by the European Commission
FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Review of the Construction Products Regulation” (CPR). The review of the CPR will be a unique moment to address its current weaknesses and ensure that is really supporting a truly functioning Single Market for construction products.
The future EU legal framework must take into account the shared competences at the interfaces between the internal market and national building law. The question of the scope of harmonisation must be identifiable in each individual case on the basis of objective and unambiguous criteria. More information can be found in the attached document.
Filed in German · English published by the European Commission
As manufacturers of construction products, the cable industry is severely affected by the CPR and any change of the legal framework. Summary of the positions - No legislative change, but improving implementation. - In the field of cables, the performances which have an impact on the basic requirements of construction works are sufficiently harmonized.
The safe and efficient use of heating products requires the specification of performance criteria. Chimneys and flues are designed to optimise the performance of an appliance. Operating outside of the prescribed performance criteria not only raises performance issues, it also can lead to safety problems.
The European Organisation for Technical Assessment (EOTA) is concerned over the radical changes proposed by the European Commission in the Refined Indicative Options for the Review of the Construction Products Regulation of 8 April 2020, especially with regard to the possible discontinuation of the ETA route.
PlasticsEurope’s comments on the Inception Impact Assessment “Review of the Construction Products Regulation” PlasticsEurope is one of the leading European trade associations with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris, with more than 100 member companies, producing over 90% of all polymers across the EU28 member states plus Norway, Switzerland and Turkey.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Construction Products Regulation and would like to thank the Commission for the opportunity to provide its views on the associated roadmap.
CEN and CENELEC work across the construction sector, developing harmonized European standards in support of the Construction Products Regulation (Regulation EU 305/2011 - CPR). Harmonized standards provide a common technical language to be used by manufacturers to express the technical performance of their products, by regulators to express their requirements and by designers, contractors and other construction…
The CPR plays a vital role in the window industry, considering the fact that window profiles are construc-tion products with a long-lifecycle that are manufactured by European companies, acting across national borders on the European market.
VELUX welcomes that the European Commission has started an evaluation process on a potential revision of the Construction Products Regulation (CPR), identifying existing problems the initiative aims to tackle to improve the functioning of the single market for construction products.
The European Environmental Bureau welcomes the revision of the Construction Products Regulation (CPR). Construction sector consumes nearly half the material resources used in Europe and construction products consequently represent a tremendous potential for circular economy, resources use optimisation and (hazardous) waste prevention.
The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the review of the Construction Products Regulation EU No 305/2011. The wood-based panels industry produces sustainably sourced bio-based circular products that can be used for energy-efficient and climate-friendly construction and renovation.
The European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on the review of the CPR. CEMBUREAU ranks the revision of the Construction Products Regulation (CPR) high on its priorities, given the importance of this file for our sector.
The CPR has created a single european market for construction products for the benefit of all manufacturers in the member states During the last years we have seen problems for EK and CEN to develop and publish hENs in a technical proper and judical correct way in due time. Out of these reasons we are aware, that CPR needs a revision.
A revision of the CPR needs to be built on a “reliable standardization process” and an “alternative way” which considers the innovation dynamics for new products and / or applications. The alternative approach to the hEN route on construction products – called ETA route – has started with the implementation of the CPR on 01.07.2013. The last approvals from the previous CPD process expired on June 30th, 2018.
VinylPlus’s comments on the Inception Impact Assessment roadmap “Review of the Construction Products Regulation” VinylPlus is the voluntary commitment of the European PVC industry. It establishes a long-term framework for the sustainable development of the industry in the EU-27, UK, Norway and Switzerland.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
the Federation of Architects of Réunion supports the idea of excluding the ultramarins from the CE marking. The facilitation of short supply chains must be a priority: The internal market in the outermost regions does not allow local businesses to carry out the CE marking for their production.
Filed in French · English published by the European Commission
1) Exclusion of the French outermost regions from the PRC: Far too risky to open doors to materials that do not meet the requirements of the building standards, it will be the construction companies (and their decennial) that will have an impact, they often do not currently check that the materials they buy are in line with the standards.
Filed in French · English published by the European Commission
FNADE, the french association for waste management and environmental services, welcomes the next review of the Construction Products Regulation and would like to suggest some improvements in order to facilitate the reuse and the recycling of construction materials. First of all, ecodesign is a necessary requirement to facilitate the deconstruction and dismantling of buildings.
The European Steel Association, EUROFER, wishes to express its views on the consultation for the revision of the Construction Products Regulation (CPR). Over 30% of steel produced is used in the construction sector, and steel construction products play a vital role in the construction of stable, durable, energy efficient, and ultimately reusable and recyclable buildings.
Answer from Santiago del Pozo – ITeC Barcelona, 30 July 2020 We consider that a revision of the Regulation can be positive, especially if it improves the effectiveness of its instruments for a better service to the construction sector. Option B and combinations of Options B, C and D introduce a wide number of relevant changes.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Europacable, the voice of Europe’s leading wire and cable manufacturers, welcomes the opportunity to provide its feedback to the ongoing consultation on the review of the CPR. With the attached paper, Europacable would like to outline its recommendations for an effective review of the CPR which would promote sustainable construction products and improved safety levels for European citizens while recognising the key…
Harmonised standards (hENs) are powerful tools to ensure a uniform internal market within the European Union. The existence of national marks and certification requirements has historically been a financial and administrative burden on the industry and their removal (and prevention of proliferation) was welcome.
The CPR aims to remove technical barriers to trade in construction products within the European single market: The initial impact assessment rightly draws attention to the economic consequences and impact on the turnover of such a proposal, even though it is very desirable for a process of harmonisation, since they are particularly significant and could unfortunately — in such a context of such difficulties as a…
Filed in Italian · English published by the European Commission
FIEC welcomes the opportunity to comment on the Inception Impact Assessment and the possible future options outlined for the CPR. The federation will submit a full response to the consultation on the future options and with this short feedback comments only on some issues raised in the Inception Impact Assessment. Problem the initiative aims to tackle: FIEC broadly agrees with the problems outlined in the document.
In order to revise the harmonised conditions for the marketing of construction products (CPR), I have 2 comments: 1/Všechny The products of the members of the Union’s Alicharmakers of Bohemia and Moravia conform to the corresponding harmonised specifications, the parameters are certified by the appropriate certifying services and conspired with the terms and conditions of the CE marking.
Filed in Czech · English published by the European Commission
The future CPR should: (1) Fully keep up, further develop and optimise the internal market for construction products and its advantages. Irrespective of the complex division of competences between the Member States and the European level, the Construction Products Regulation (CPR) has brought about a single market ‘light’ which benefits manufacturers: Instead of 27 different test methods for one essential…
Filed in German · English published by the European Commission
I have been following the CPR since its inception and I have very disappointed with its activities. The idea was excellent, but the implementation was very disappointing. In an earlier survey, I replied to the possibilities offered by the CPR that “should be continued, but major shortcomings should be removed”.
Filed in Finnish · English published by the European Commission
The CPR has caused considerable confusion in the market. There is an expectation that construction products should be CE-marked and that this confirms their fitness for purpose. It does not. Instead it confirms that one test in a harmonised standard has been conducted.
Future Options for the Review of the Construction Products Regulation (CPR) Fields marked with * are mandatory. Future options for EU legislation on construction products This consultation is open to any interested party, in particular experts and practitioners. For a wider picture of the process, please listen first to the online presentation published here by the Commission services.
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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.
