European Federation of Building and Woodworkers

The European Federation of Building and Woodworkers (EFBWW) has 77 affiliated trade unions in 36 countries and represents a total of 1,5 million workers in the construction and woodworking sectors. The EFBWW considers public procurement to be crucial in counteracting harmful business models in the construction sector. Public procurement is an important economic source for the construction sector (approx.

The European Federation of Building and Woodworkers (EFBWW) strongly call on EU legislators to ensure that the EU Inc. regime is not applicable to the construction sector. Our position can be found in the attached file. The proposed regulation fails to account for the specific structural risks inherent to construction, thereby creating significant risks for abuse and spread of letterbox companies.

The EFBWW is particularly concerned that labour mobility is increasingly being instrumentalised in discussions on competitiveness, housing crisis and cross-border economic activities and promoted as a primary solution to labour shortages in the construction sector, as reflected in initiatives such as the European Single Market Strategy, the Strategy for Housing Construction and the proposed Construction Services…

EFBWW represents trade unions in the construction, wood, forestry, and building materials sectors across Europe. EFBWW calls for a VET Strategy that is worker-centred therefore ensuring that skills policies serve workers and society, not competitiveness alone.

The Fair Labour Mobility Package should be a package for improving working conditions and enhancing enforcement, not a package for deregulation. The Commissions own Call for Evidence identifies the right points, notably long subcontracting chains in high-risk sectors, rising numbers of posted TCNs and enforcement gaps.

Strengthening ELA is essential if the EU is serious about fair labour mobility. Fraud and abuse can only be tackled effectively with stronger enforcement capacity at all levels, particularly at the European level as we cannot allow accountability to stop at national borders. A revised ELA mandate must therefore provide the Authority with the resources and mandate to support effective cross-border enforcement.

The Construction Services Act should not liberalise at the expense of workers. It should be an instrument to improve working conditions and attractivity. This can only be achieved if we strengthen enforcement and tackle fraudulent and abusive business models that are over-reliant on subcontracting and bogus self-employment. Fraud and abuse flourish where enforcement is weak.

EFBWW welcomes the ECs 18 July 2025 proposal revising Directive 2004/37/EC on carcinogens, mutagens, and reprotoxic substances. According to EU-OSHAs 2024 WES, over 60% of construction and wood workers face multiple carcinogen exposures, often on mobile sites, short-term contracts, or as self-employed, with insufficient protection.

The EFBWW supports an ambitious ESSPASS that strengthens enforcement and worker protection while improving practical access to social security rights in cross-border situations. ESSPASS must deliver real-time verification and effective access to data, not simply a digital storage of scanned documents.