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Asociación Nacional de Fabricantes de Materiales Aislantes

ANDIMAT

ANDIMAT es la Asociación Nacional de Fabricantes de Materiales Aislantes y da cabida a todas las empresas fabricantes que operan en el mercado español.

Lobbying Activity

Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings

31 Oct 2025

ANDIMAT, the Spanish National Association of Insulation Materials Manufacturers, considers the proposed regulation is a necessary tool for the EPBD purpose. Clarity and homogeneity for the calculation of GWP of new buildings is key to establish values that represent well the reality, and therefore allow to walk the way to the challenge of full decarbonization. Giving a deeper Annex III for Member States will be extremely helpful for this objective. We fully agree on the consideration of all components in the building, including installations. They are also important elements in the building as a system, and therefore need to be taken into account. We also agree on the consideration of the stages mentioned in tables 2 and 5 in the draft as a common minimum for all Member States, not forgetting B6 due to its importance during the whole life of the building. As an example, insulation in the envelope plays a key role in the decarbonization of the buildings, so operational energy use is a stage that needs its inclusion. We consider it would be extremely important that EN 15804 reference is to EN 15804 latest version (today EN + A2). There are cases in which EPD use older versions. If used, calculations for the whole building would not be consistent and homogeneous. We agree with the inclusion of sectorial EPD as accepted data for calculating GWP. They represent a set of similar products and it is necessary to recognize their availability. Therefore, we agree with the intention of this draft regulation. As mentioned at the beginning, it is very positive to establish common rules for the calculation of GWP and how to include it into EPC. Thus, EPC will be more homogeneous among Member States.
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Response to Revision of the EU’s energy security framework

10 Oct 2025

Although this consultation seems to be mainly directed to the energy infrastructure in itself, we consider the sentence the energy transition to a decarbonised energy system will be characterised by an increase in electrification, as well as a expansion of renewable energy sources and the appearance of new carriers such as renewable and low-carbon hydrogen and the references to heating and cooling have an additional point of view that should be considered. The scenario is multi-factorial, and therefore a wide and horizontal approach considering complementary solutions should be taken. We all agree that the previously mentioned increase in electrification will suppose a higher pressure on the electrical network, with peaks and consequent risks of blackouts. In this sense, the reduction in the energy demand in edification is a relevant item that, in conjunction with other measures, will help to reduce the risks and keep the necessary system stability. Of course it is not the only tool, but it is a necessary partner in the journey to decarbonization and energy security. Energy demand reduction is closely related to one of the main areas for action identified at this stage mentioned in the reference document: consumer protection. The consultation document also makes reference to four policy options. In our opinion, policies number 2 and number 3 are the ones that take more into account this relationship between energy demand reduction and energy security: - Policy option 2 considers climate change and new political challenges. Both issues can be better addressed if energy demand reduction is taken on board: the less energy is required by buildings (residential, commercial and industrial), the less climate change will affect the energy infrastructures. As an example, heat waves in summer cause more electricity consumption at homes and businesses, but if buildings are thermally well insulated, there will be less need of electricity (which tends to passive confort, i.e., thermal confort with virtually zero energy consumption many days in the year). In addition, less energy demand implies less dependency on foreign energy sources. - Policy option 3 mentions explicitly the need to better engage the demand-side as well as decentralised actors. The core of this sentence aligns totally with our comments for policy option 2. Buildings can be considered as relevant decentralised actors on the demand-side, so actions should be directed to them. - On policy option 4, we consider that the EU shall, as is doing now, lead the efforts (Energy Performance of Buildings Directive, EPBD, for example). However, there is a need to coordinate with Member States so as regional particularities are considered. Therefore, concerning energy demand reduction, we consider policy option 4 is suitable, but needs to be complemented by option 2 or option 3. Hence, and based on the above comments, we consider that energy demand reduction measures in edification, via improving the insulation of buildings envelope, play a key role in the stability and security of energy networks. So, policies for the energy security framework should include the development of envelope directed renovations to reduce energy demand and improving efficiency. These measures, combined with other ones, will work together towards a more secure and sustainable energy network.
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Response to Citizens energy package – protecting and empowering consumers in the just transition

8 Sept 2025

The objective of leaving no one behind in the energy transition is multi-faceted. Among the aspects indicated in this consultation, there are references to the complexity and cost for consumers of "accessing to energy efficiency options" and "providing an effective response to demand". In addition, the objectives of the future legislative package include the just transition, the reduction of the energy poverty rate, the increase in consumers awareness and the support for people living in regions disproportionately affected by the transition by improving their access to energy efficiency measures. However, the consultation does not refer to direct measures to reduce this energy demand. The main measure in this regard are insulation actions on the envelope, which also improve comfort and health, aspects that are particularly sensitive for households in a situation of energy poverty. In a scenario of climate change and increasingly frequent and intense heat waves, maintaining comfort in buildings passively becomes increasingly necessary. On the other hand, the proposal includes a more coordinated consumer protection at European level, "although consumer protection is largely a national competence". Aligned with this, we believe that it would be very positive to recommend the Member States that they establish requirements or indicators for demand reduction in national energy efficiency legislation, as a means of reducing the differences between Member States and combating energy poverty. We are aware that this package will not include legislative measures, but recommending that Member States consider them in their respective countries would have a very beneficial promoting effect. Finally, and in line with the idea of "a broader communication and participation campaign, raising awareness of its objectives, promoting consumer participation and contributing to a more inclusive and fair energy transition", we believe that this should include aspects of demand reduction via passive measures on the envelope. Targets for home renovation and emission reductions in buildings are very ambitious, but unfortunately current renovation rates, at least in some countries, need to be significantly increased to achieve them. To do this, it will be necessary to deepen various measures, and consumer information and support shall be a fundamental part.
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Response to European Affordable Housing Plan

3 Jun 2025

Concerning the European affordable housing plan, ANDIMAT, the National Association of Insulating Materials Manufacturers in Spain, would like to highlight certain aspect that we consider relevant. Firstly, we would like to express our satisfaction with this future plan. It is an excellent opportunity to solve several issues: - improve on the climate challenge, - help citizens be able to afford a house to live in, - fight against the energy poverty, - boost the European economy. All are issues that worry European citizens and need an answer as soon as possible. It is extremely important that this plan engages well with the current construction legislation in terms of sustainability, efficiency and environmental issues in general. EPBD is clear in requirements and timelines for full decarbonization of building stock in Europe, and this plan for affordability shall work together with it, and shall not be seen as something apart from it. Balance is necessary, therefore. And for this reason, all actors in the construction sector, including manufacturers, shall be taken into account as a collaborative partner to get that double objective: affordability as well as decarbonization. Also an important aspect is the need to consider both the construction of new buildings and the renovation of the existing ones. In both cases the above mentioned balance between affordability and efficiency is key. On one hand, new buildings shall have more ambitious rules for incorporating more and more in their design sustainability and energy efficiency minimum requirements (the new CPR and the EPBD will be important tools for that); on the other, reducing the energy demand of existing buildings is absolutely necessary. Both cases will help to reduce emissions, energy consumption and therefore bills at home, climate change effects, and energy poverty, and will also increase confort, health and resilience to that climate change and more extreme temperatures. Therefore, measures shall continue to be taken to enhance the energy efficiency of buildings, through incentives to renovations, legal efficiency requirements for new buildings, etc. It is important to highlight that reducing the energy demand, via renovation of the envelope of the buildings, is an important support to electrification and the use of renewable energy, as it lowers the peak demand and elps to increase the flexibility of the electricity network. In addition, in case of blackout, confortable and healthy conditions can be maintained for hours with no need of energy consumption. Therefore, incentives to that reduction in the demand shall be considered in this future plan. As climate conditions and building stock in each Member State vary highly, it is important that this plan considers this. There are many related legislations, for example EPBD, CPR and Energy Efficiency Directive, among others. Some of them need transposition, some not; some are European, some are purely national. But all have to be considered for implementing an effective and efficient financing and aids environment. We think it is extremely important that this is considered, so as the needed renovation of building stock is enhanced and incentivized to comply with the economic, social and environmental challenges. Considering that financing plays a key role in terms of reducing the energy demand (insulating the envelope requires more initial investment, but produce higher savings from the beginning during decades), we highlight the importance of guaranteeing that aids and finance are adequately distributed, with special consideration to vulnerable housings. Multiannual Financial Framework (MFF) funds, Social Climate Funds (SCF), Recovery and Resilience Fund (RRF) and others must be effective, well known by citizens, easy to obtain, fast in reaching the final target, etc. Only in this way the current building stock will evolve to an efficient one in a reasonable timeline. On the effective use and distribution of funds,
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