EuroWindoor AISBL

EuroWindoor supports the general objectives of improving resource efficiency, facilitating recycling and stimulating demand for circular products in the internal market. However, we would also like to point out that any recommendation or requirement must be chosen with care, taking into account the differing situation of each product group especially in the construction sector with very long-lasting products.

EuroWindoor welcomes the opportunity to provide feedback on the proposed revision of the EPBD. We need an ambitious EPBD revision to enable the green transition of the European building stock and create more sustainable and healthier living conditions for all Europeans. This will require a close alignment with the Energy Efficiency First Principle and other relevant files from the Fit for 55 Package.

EuroWindoor welcomes the opportunity to comment on the Inception Impact Assessment on the Revision of the EPBD in the attached document. We believe that the upcoming revision is an opportunity to secure the introduction or the update of a coherent set of measures that will enable the green transition and benefit all Europeans.

EuroWindoor support to have one harmonized European method of making green claims. For construction products the CEN/TC350 suite of standards (EN 15804, EN 15978 etc.), aligned to PEF methodology, should be preferred with the arguments that: 1) the systems of EPDs for construction products and building evaluations are already somewhat well established 2) intermediate (construction) products and the final building as…

EuroWindoor appreciates the opportunity to give feedback to the ESPR consultation und supports the aim of making sustainable products the norm while at the same time strengthening a level playing field with a fair and smooth functioning internal market.

EuroWindoor welcomes the adoption of the European Commission proposal to revise the Energy Efficiency Directive on 16 July 2021 and appreciates the opportunity to provide feedback to feed into the legislative debate. The EuroWindoor feedback is summarised as follows: In the upcoming negotiations, we call on the EU Institutions to: i.

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.

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…

Issue: We very much welcome the progress made by considering curtain walls as windows. However, the technical screening criteria for the energy efficiency of transparent building components remain incorrectly defined, as neither climate differentiation nor solar energy gains are considered.

EuroWindoor appreciates the opportunity to provide feedback to the inception impact assessment on the revision of REACH Regulation. The small and medium sized companies of the European window, door and façade sector are downstream users at the end of a long supply chain and far away from the chemical industry.

EuroWindoor supports maintaining Regulation 1025/2012 as a key component of the EU's New Legislative Framework. Harmonised standards play a crucial role in the EU single market for windows and doors and are essential for implementing the Construction Products Regulation and other EU laws.

EuroWindoor welcomes the European Commissions objective to reduce regulatory and administrative burdens affecting housing supply and affordability. The feedback calls for better coordination between EU rules, simpler digital permitting and documentation and practical solutions that reflect the capacity of SMEs.

EuroWindoor welcomes the opportunity to contribute to the public consultation on the draft Implementing Regulation on the Digital Product Passport (DPP) Registry. We recognise the value of a well-functioning registry for transparency, market surveillance and the circular economy.

Dear Sir or Madam, Thank you very much for the opportunity to give feedback to the inception impact assessment on revision of the Machinery Directive. EuroWindoor suggests option 2. Please find attached the detailed feedback of EuroWindoor AISBL.

EuroWindoor appreciates the opportunity to give feedback to the evaluation of restrictions included in the RoHS Directive 2011/65/EU. EuroWindoor represent the interest of the European window, door and façade sector and has in this role previously provided input for a study initiated by the European Commission to analyse the impact on the industry when windows and doors with electrical function becomes part of the…

EuroWindoor is pleased to contribute to the feedback period on the draft supplementing Regulation (EU) 2024/3110 by laying down the conditions for Classification Without Testing (CWT) for reaction to fire class A1. We support the objective of ensuring continuity with the former system under Regulation (EU) No 305/2011 while avoiding unnecessary testing.