Eurima (European Insulation Manufacturers Association)

Brussels, 26 January 2026 EURIMA position on the revision of the EU Public Procurement Directives: Enabling competitive, sustainable and resilient construction through performance-based procurement EURIMA, representing the European mineral wool insulation industry, welcomes the European Commission’s initiative to revise the EU Public Procurement Directives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurima (European Mineral Wool Insulation Manufacturers) supports the efforts of the European Commission on the revision of the requirements for packaging and packaging waste. Our industry is committed to constantly improve the packaging of our products by reducing the use of “fossil based/virgin plastic” and increase the recycle content when it is technically feasible and economically viable.

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to contribute to the European Commission's call for evidence on: Sustainable investment review of the EU taxonomy environmental delegated act. Please find the full contribution attached.

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to contribute to the European Commission's call for evidence on: Sustainable investment review of the EU taxonomy climate delegated act. Please find the full contribution attached.

EURIMA Position Paper on the revision of the Energy Performance of Buildings Directive (EPBD) March 2022 Introduction EPBD: the cornerstone of the Fit-For-55 Package EURIMA welcomes the European Commission’s proposal to revise the EPBD as part of the Fit-For55 Package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The review of the Energy Performance of Buildings Directive (EPBD) provides a much needed opportunity which will result in higher energy savings, reduced CO2 emissions and deliver a high societal return on investment through the multiple ancillary benefits of investing in the building and construction sector.

The European Insulation Manufacturers Association (EURIMA) welcomes the Commission’s intention to propose a Climate Law to put the 2050 climate neutrality objective into legislation. EURIMA is strongly committed to, and supports, the transition to a climate-neutral economy by 2050 at the latest.

Brussels, 22nd February 2022 For more information please contact: Eurima - [phone removed] Eurima considerations on the Environmental impact of Waste Management – revision of the Waste Framework Directive The European Commission has adopted the Circular Economy Action Plan in March 2020 - one of the main blocks of the European Green Deal, Europe’s new agenda for sustainable growth.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to the Commission proposal for a Certification of Carbon Removals Brussels, 23 March 2023 The European Insulation Manufacturers Association (Eurima) supports the development of ambitious policies fostering the achievement of a sustainable built environment based on significant emissions reduction targets for buildings and the broader construction ecosystem.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurima recognizes the contribution of carbon removals as a complementary solution to carbon emissions reduction in order to achieve EU Carbon Neutrality by 2050.The dimension of carbon removals needs to be accounted for in a separate manner, in order to not distract from the priority to reduce carbon emissions.

Eurima welcomes the Commission’s intention to harmonize and set a baseline for the substantiation of green claims for products and businesses. Our industry shares the concerns raised in the Roadmap regarding the detrimental impact of unsubstantiated green claims on consumers, both on B2B and B2C markets and on the internal market.

Eurima welcomes the Commission’s intention to harmonize and set a baseline of principles for a market of sustainable products in Europe. We support the objectives of the Circular Economy Action Plan in this regard as it will contribute to a fairer market and allow for a better valorisation of the more sustainable products in the construction sector.

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s work to enshrine the long-term objective of climate neutrality by 2050 in legislation and increase the EU’s climate ambition by 2030. Additional market economy measures are necessary to enable decarbonisation of the industry, while avoiding carbon leakage.

EURIMA Response to the European Commission’s proposal to revise the Energy Efficiency Directive Energy Efficiency First & 2030 targets An ambitious revision of the Energy Efficiency Directive (EED) is paramount for reducing EU greenhouse gas emissions by at least 55% by 2030 and achieving climate neutrality by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to revise the Energy Efficiency Directive in support of the EU’s higher 2030 climate target. Below we list our key priorities for this revision.

Eurima shares the vision that the EU ETS has proven to be effective in reducing GHG emissions of energy intensive industries. The Mineral Wool industry itself has undertaken important steps to reduce emissions in the manufacturing process as well as contributing to the transition to climate neutrality through its enabling, energy saving insulation products.

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)

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.

Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the CLP Regulation. Our sector represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH as bio-soluble. Mineral wool fibres manufactured today are exempted under the Note Q to Annex VI to the CLP Regulation.

EURIMA response to the European Commission’s Amendment to Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality EURIMA welcomes the Commission’s proposal to amend the European Climate Law to include a 2040 climate target, an essential milestone to keep the EU firmly on track towards climate neutrality by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EURIMA Position Paper on the revision of the Industrial Emissions Directive (IED) Key recommendations  Further clarify the BREF process to guarantee ambitious, yet achievable Emission Limit Values and ensure proportionality in the setting of those linked to Environmental Quality Standards; consider a transitional period as part of transformation plans.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to improve the design and implementation of the Industrial Emissions Directive (IED) in order to prevent, reduce and eliminate as far as possible pollution arising from industrial activities.

EURIMA POSITION PAPER ON THE NET ZERO INDUSTRY ACT Enabling the change through Energy Efficiency Brussels, June 2023 The Commission’s proposal for a Net-Zero Industry Act (NZIA) represents a significant milestone in tackling the obstacles hindering the advancement of the manufacturing of clean technology in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the REACH Regulation. Our association represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH and we have a long history of cooperating with EU policy makers to ensure the highest standard of safety of our products.

EURIMA welcomes the European Commissions work on the Affordable Housing Act (AHA) as part of the European Affordable Housing Plan. The AHA should help identify areas under housing stress, clarify which measures may be justified and proportionate, and support steps to increase housing supply, including through simplification.

EURIMA welcomes the European Commission's initiative to revise Regulation (EU) 1025/2012. As the voice of Europes mineral wool insulation industry, we support a strong and effective standardisation system that underpins the Single Market, EU legislation, and sustainability goals. Standardisation is a strategic tool.

Eurima Response to the European Commission's Call for Evidence on the Housing Simplification Package The construction sector is central to Europe’s competitiveness, supporting more than 12 million workers across over 3.8 million enterprises and accounting for more than 5% of EU employment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The escalating impacts of climate change - record-breaking temperatures, droughts, flash floods, wildfires, and strained health and energy systems - underscore the urgent need for robust climate adaptation across Europe. The built environment, a critical sector vulnerable to these impacts, also offers significant potential for resilience.

Eurima welcomes the opportunity to provide feedback on the calculation and verification of recycled content under the Packaging and Packaging Waste Regulation. We support a robust methodology grounded in verified physical material flows that protects fair competition and rewards investment in recycling. Please find our detailed recommendations attached.

EURIMA submits a unified response to the Electrification Action Plan and the Heating & Cooling Strategy to advance one system-level proposition for their success: deliver electrification and H&C decarbonisation through demand reduction and peak management at scale.

Eurima welcomes the revised Waste Shipments Regulation by the European Commission which better reflects the principles of circularity. The Waste Shipments Regulation (WSR) is a crucial step for the recovery of “post-consumer” waste that is generated during renovation or demolition/deconstruction project.

EURIMA submits a unified response to the Electrification Action Plan and the Heating & Cooling Strategy to advance one system-level proposition for their success: deliver electrification and H&C decarbonisation through demand reduction and peak management at scale.

Energy efficiency is a strategic pillar for the EUs competitiveness, energy security and climate neutrality. In the context of geopolitical instability and continued exposure to energy imports, the EU should avoid a transition built solely on supplying more clean energy without simultaneously reducing demand.

As Europe advances toward climate neutrality, addressing energy security challenges - rising energy demand, intermittent renewable generation, supply risks, and growing reliance on electrification - is critical. A demand-reduction-focused approach is essential for creating a resilient, cost-efficient energy system aligned with the EUs Fit for 55 objectives.