Compagnie de SAINT-GOBAIN

Saint-Gobain is a global leader in sustainable construction, producing materials for buildings and industry across 80 countries.

Lobbying Activity

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and Lysios Public Affairs

9 Jan 2026 · Product inclusion in the steel trade measure

Meeting with Christophe Grudler (Member of the European Parliament)

2 Dec 2025 · Politique énergétique européenne

Meeting with Susana Solís Pérez (Member of the European Parliament)

2 Dec 2025 · Steel

Meeting with François-Xavier Bellamy (Member of the European Parliament)

26 Nov 2025 · Protection de l'acier

Meeting with Alexandre Paquot (Director Climate Action)

25 Nov 2025 · Decarbonisation of the glass sector

Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

18 Nov 2025 · Steel safeguards

Saint-Gobain urges EU to harmonize building material recycling rules

5 Nov 2025
Message — Saint-Gobain calls for a unified EU framework for recycled building materials. They advocate for mandatory digital passports to track materials and improve recycling. The company supports rules making landfilling more expensive to encourage material reuse.12
Why — Uniform waste standards would lower administrative costs for Saint-Gobain's cross-border operations.3
Impact — Landfill operators face economic losses as the proposal seeks to make disposal expensive.4

Meeting with Michele Piergiovanni (Cabinet of President Ursula von der Leyen)

22 Oct 2025 · To present the group’s activities in more detail and to discuss the current and future European framework governing public procurement, particularly in the water sector

Response to New European Bauhaus

17 Oct 2025

Please find attached the feedback from Saint-Gobain to the New European Bauhaus - achievement and future developments call for evidence.
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Meeting with Sacha Halphen (Cabinet of Executive Vice-President Stéphane Séjourné)

15 Oct 2025 · -Les normes environnementales et la réduction des émissions de carbone - Le rôle de l’innovation industrielle dans la construction

Saint-Gobain urges EU to prioritize industrial competitiveness in housing

18 Sept 2025
Message — The organization advocates for a roadmap that strengthens industrial competitiveness while integrating life-cycle sustainability. They request secure access to raw materials and mandatory green public procurement criteria.123
Why — Secured material access and mandatory green criteria would strengthen their market position.45
Impact — Traditional builders competing solely on low price would lose market access.6

Meeting with Denis Redonnet (Deputy Director-General Trade)

18 Sept 2025 · Anti dumping proceeding AD 720 Fused Alumina

Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

Saint-Gobain urges green procurement and trade defense measures

8 Jul 2025
Message — The company wants mandatory sustainability and local content rules for public contracts. They also request trade defense measures against subsidized imports. Finally, they seek faster permitting for decarbonisation projects.123
Why — These measures would protect their market share and reward existing green investments.45
Impact — Subsidized foreign manufacturers would lose the advantage of lower environmental standards.67

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

25 Jun 2025 · A 40' brief on the workings of the EU institutions for a group of visiting managers of the Saint Gobain Company

Meeting with Christophe Grudler (Member of the European Parliament)

25 Jun 2025 · Politique industrielle européenne

Saint-Gobain urges technology neutrality in EU bioeconomy strategy

23 Jun 2025
Message — The organization demands technology neutrality and science-based assessments for all construction materials. They also request that biogenic carbon be accounted for separately from fossil carbon.12
Why — Maintaining a level playing field protects their investments in decarbonizing traditional mineral-based products.3
Impact — Specialized bio-based producers lose potential competitive advantages gained through material-specific regulatory preferences.4

Meeting with Virginie Joron (Member of the European Parliament)

11 Jun 2025 · Préférence européenne - emploi en France - réciprocité

Response to European Affordable Housing Plan

4 Jun 2025

Saint-Gobain, global leader in sustainable and light construction, welcomes the European Commissions initiative to develop the European Affordable Housing Plan. We fully support the Plans ambition to address the housing crisis while aligning with the EUs climate, energy, and competitiveness objectives. The housing crisis is driven by a complex mix of factors, including rising energy costs, limited housing supply, and regulatory barriers. Addressing it requires a holistic approach integrating energy performance of buildings, innovation, and competitiveness of the EU construction industry. A stable regulatory framework and long-term market visibility are essential to enable companies to plan investments, scale up production, and train workers. Energy efficiency must be at the center of the EAHP. Energy-efficient buildingsboth new and renovatedare essential to reducing energy bills, improving comfort, and achieving climate targets. The Plan should promote the full implementation of the Energy Performance of Buildings Directive (EPBD) and the Energy Efficiency Directive (EED), while incentivizing deep renovation of the worst-performing buildings. The deployment of Building Renovation Passports and Minimum Energy Performance Standards (MEPS) will be key to guiding and scaling renovation efforts. Life-cycle costing, based the Level(s) framework, should be promoted in public procurement to reflect long-term savings from energy efficiency and encourage sustainable construction. Public procurement should show exemplarity and lead the rest of the market in this regard. We must also ensure a predictable, multi-year financing perspective. Avoiding stop-and-go funding cycles is essential to give companies the confidence to invest, scale up production, and train workers. Public and private financing must be unlocked in a coordinated way, leveraging EU funds in the next MFF, and directing Social Climate Fund and ETS II revenues to support low-income households with energy renovation. Private financing must also be boosted, through innovative instruments like renovation loans and blended finance, to make energy renovation affordable and accessible to all. To meet urgent housing needs while ensuring quality and sustainability, the EAHP must support the acceleration of the adoption of modern construction methods in building codes, urban planning rules and permitting. Modular and offsite construction offer significant potential to reduce costs and timelines, while maintaining high standards of performance. The Plan should also encourage vertical extensions, retrofits, and adaptive reuse of existing buildings to optimize land and resource use and limit urban sprawl. Lightweight construction systems also provide cost-effective and resource-efficient options for both new builds and renovations. To ensure long-term resilience of the built environment, climate adaptation and resilience measures must be mainstreamed into construction and renovation guidelines and procurement criteria. A resilient and competitive construction sector is essential to delivering affordable housing at scale. Ensuring secure and sustainable access to key raw and secondary materials, such as gypsum, insulation, and glass, is critical to this effort. The Strategy for Housing Construction should support an EU-wide mapping of material needs and streamline permitting and financing for domestic resources. Circularity must be promoted through recycling targets, secondary materials markets, and incentives for closed-loop recycling. The Plan should align with the Clean Industrial Deal to support decarbonization, innovation, and investment across the construction value chain. Saint-Gobain stands ready to contribute to the success of the EAHP by leveraging its expertise. We urge the Commission to adopt a forward-looking, integrated approach that ensures housing is not only affordable but also energy-efficient, sustainable and climate resilient.
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Meeting with Giorgio Gori (Member of the European Parliament)

25 Apr 2025 · EED, EPBD, ETS2

Meeting with Alexandre Paquot (Director Climate Action)

27 Mar 2025 · Decarbonisation of the construction materials sector

Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · marchés publics

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné) and Lysios Public Affairs

19 Mar 2025 · Exchange of views on the revision of the Public Procurement Directives

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and Lysios Public Affairs

19 Mar 2025 · Evaluation of the Public Procurement Directives

Saint-Gobain urges EU to prioritize European products in procurement

7 Mar 2025
Message — Saint-Gobain calls for a mandatory "Made in Europe" preference for utility infrastructure. They request stricter reciprocity rules to block subsidized competitors from non-European countries. Contracts must prioritize environmental quality and total ownership costs over initial price.123
Why — Stricter rules would protect their market position against low-cost, subsidized foreign imports.4
Impact — Non-European manufacturers would lose access to the EU's open public procurement market.5

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and BASF SE and

19 Feb 2025 · Exchange on Housing and Efficient buildings initiatives in Europe

Meeting with Pascal Canfin (Member of the European Parliament)

9 Jan 2025 · Clean Industrial Deal

Meeting with Dan Jørgensen (Commissioner) and

4 Dec 2024 · Union´s energy and housing agenda

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

22 Oct 2024 · Buildings Directive / Renovation of schools

Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Saint-Gobain Urges Taxonomy Recognition for Building Product Manufacturing

3 May 2023
Message — Saint-Gobain requests that the taxonomy explicitly cover the manufacturing and distribution of circular construction products. They argue current primary raw material thresholds for gypsum and glass are unrealistic.123
Why — The company would secure a rewarding mechanism to access sustainable finance for its manufacturing investments.4

Meeting with Stéphane Séjourné (Member of the European Parliament)

7 Mar 2023 · Directive performance énergétique des bâtiments (équipe)

Meeting with Pascal Canfin (Member of the European Parliament)

6 Mar 2023 · Green Deal

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Stichting European Climate Foundation and

7 Feb 2023 · EPBD

Meeting with Mairead McGuinness (Commissioner) and

10 Jan 2023 · Taxonomy, ESG ratings, CSRD

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Aluminium AISBL and

20 Oct 2022 · circular economy and construction sector

Response to Review of the Construction Products Regulation

12 Jul 2022

Please find attached our feedback to the public consultation on the CPR revision
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Saint-Gobain welcomes the 2021 EPBD revision proposal as a much needed cornerstone to articulate a solid decarbonisation path by 2030 towards a highly efficient, climate neutral building stock by 2050. A number of elements however need to be substantially enhanced to secure a tangible progress in the energy performance of both new and existing buildings by 2030, in line with the 2050 EU ambition. Importantly, the role of the building sector in the overall energy and climate transition needs to be better considered when designing this new EPBD and related files of the Fit for 55 package, in terms of GHG emissions, citizens’ buy-in, and energy system costs. Not least, it is vital to place the energy efficiency first (EE1) principle at the heart of the EPBD, and to factor into the directive’s tools the full costs and benefits of energy efficiency for climate, health, jobs and energy security. Our comment focus on the following four main dimensions (see details in the attached document) 1. Minimum Energy Performance Requirements (MEPS) should deliver much more 2. On the road to ZEB: Securing low energy needs in new and renovated buildings (deep renovation) 3. National Buildings Renovations Plans should become more operational 4. A more solid framework towards environmental performance We will welcome the opportunity to further exchange on these topics in the months to come.
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Meeting with Mattia De' Grassi (Cabinet of Vice-President Dubravka Šuica) and France Industrie and

15 Sept 2021 · Exchange on the Conference & Reflection on the Future of Europe

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Saint-Gobain welcomes the roadmap consultation and the opportunity to express our views on the EPBD revision, which we see as a key success factor for the EU Green Deal and the Renovation Wave. Please find below the summary of our position paper attached. 1) We support option 3 of the roadmap and further enforcement of existing measures (option 2). A new, more dynamic and more impactful regulatory framework is needed to boost the renovation rate and depth of buildings. In spite of many progress, incl. Long Term Renovation Strategies (LTRS), financing and support schemes, no regulatory perspective is yet visible to owners regarding the needed improvements. We thus fully support the option 3, namely to develop minimum energy performance standards for existing buildings, as a way to create demand and align perspectives among actors of a complex and scattered value chain. MEPS should be designed at national level, with sufficient lead time. MEPS should help accelerating demand for energy renovation, notably in the worst performing buildings, but they also have a more fundamental role to play in signaling higher performance as this will drive more transformative measures. In the case of public buildings, more ambitious objectives should be put in place from the start, given the involvement of public funding (class ‘B’ for the renovation of public buildings is suggested in Denmark). 2) Key tools to deliver more impact and ambition for new and renovated building Energy Performance Certificates: EPCs should build on more comparable methodologies across the EU. Certifiers should meet minimum qualification requirements, and the building should always be visited before enacting the document. These are important elements to build trust in the tool. Initiatives towards making EPCs available in a more timely manner for the rental and buyers’ markets, and making them obligatory and enforceable will also raise their quality. Building Renovation Passports (BRPs): BRPs must complement EPCs in order to equip building owners with tailor made recommendations for energy efficiency measures to deliver improvements towards the best energy class. Near Zero Energy Buildings: nZEB definitions should be more ambitious, better aligned with the principle of reducing demand first and with our EU 2050 goals. Deep Renovation Standard: It should support the transformation of the entire building stock towards levels compatible with our long term decarbonisation goals (nZEB or equivalent level). Typically, a deep renovation will deliver around 60-70% of reduction in energy needs, at least for the major share of the buildings that are in the ‘D’, ‘E’, ‘F’, ‘G’ or ‘H’ classes. A ‘deep renovation’ of the EPBD: Given what is needed to make building stock aligned with the carbon neutrality goals, we believe that this revision should be comprehensive (not only a targeted revision). 3) Beyond energy efficiency Driving the reductions of other impacts of buildings is important given the environmental challenges as well as the health & comfort expectations linked to sustainable buildings. The EU Commission has recently launched Level(s), a voluntary framework to assess the sustainability of buildings, which we believe should be the reference guiding any evolution of the EU regulatory framework. Such evolution could happen step by step, following a progressive introduction of Level(s) core indicators. The EPBD should remain the main instrument for regulating buildings impacts. When introducing concepts such as whole life carbon of buildings, one should avoid to consider the embodied carbon impact of components in a way that is disconnected from the role they fulfil in a building. Requesting the disclosure of a building’s Global Warming Potential indicator (GWP, as defined in Level(s)) could make sense to help gather data for new buildings and for the major renovation of public buildings.
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

16 Mar 2021 · Draft Delegated Act, EU Taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

12 Jan 2021 · Taxonomy and climate objectives in the building sector

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Jan 2021 · EU taxonomy for sustainable activities

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Decarbonised buildings are essential for the EU climate transition. Saint-Gobain’s products and solutions are essential to meet such ambition. Our distribution activities are also an essential channel for the climate transition in the sector, notably through the training of professionals. We strongly welcome the EU’s leadership and efforts to put in place an ambitious sustainable finance framework. The EU Taxonomy is a crucial instrument to achieve EU climate objectives - it is essential to get it right. We believe that there are major gaps in the Delegated Act, which excludes a number of activities that are crucial for ensuring energy efficient buildings. This would not only hamper the full potential of the Taxonomy, but also alter the playing field in the construction sector. Based on the above, we ask for the following adjustments: • Distribution of construction products and equipments: - Rephrase Section 7.3 into “Distribution, installation, maintenance and repair of energy efficiency equipment”, incl. NACE code F46. - Distribution plays an important role in creating market uptake for innovative solutions supportive of climate goals through the supply of appropriate materials, but importantly also through the training of professionals, including craftsmen. • Manufacturing of insulation products and solutions: - Bring insulation products in point 3.4 “Manufacture of energy efficiency equipment for buildings. This should include codes 23.14 and 23.99. - Not including mineral wool insulation products under point 3.4 would jeopardize the roll-out of the Renovation Wave and lead to a differentiated treatment of building envelope elements. • Flat glass transformation - Bring flat glass transformation activities in paragraph 3.4 “Manufacture of energy efficiency equipment for buildings”. This should include code 23.12. - The manufacturing of efficient glazing products for use in efficient windows relies on the production of flat glass (23.11) and its transformation (23.12). • Gypsum manufacturing - Bring gypsum activities in paragraph 3.4 “Manufacture of energy efficiency equipment for buildings”. This should include codes 23.52 and 23.62. - Lightweight construction materials such as gypsum products are integral part of insulation systems, where they play an essential moisture buffering and temperature equilibration role. • Manufacturing of mortars for façades - Bring façade mortars in paragraph 3.4 “Manufacture of energy efficiency equipment for buildings”. This should include code 23.64. - Industrial mortars are essential for construction and renovation: they are widely used, for example, for the protection and insulation of facades, flooring, interior walls, are a key component of the external thermal insulation composite systems (ETICS) that result in energy savings. • Building Renovation - Renovation works should be combined to achieve a minimum of 60% primary energy savings if the building is very poorly performing (classes D, E, F or G). - Any taxonomy compliant renovation should be supported by an individual roadmap (‘Building Renovation Passport’) offering a plan for the asset to reach nZEB level. A dynamic perspective should be provided with progressive tightening of criteria, and the “deep renovation” standard should be integrated. • Call for additional stakeholder dialogue - Given the rapidly expanding scope of references to the Taxonomy in the EU legislation, the rationales behind the selection of sectors and the methodology used to elaborate criteria have to be well understood by stakeholders, who will have to use these criteria and report on how their activities are aligned to such criteria. - The fact that reporting requirements are proposed and will be applied within a very short timeframe causes real challenges of accuracy and liability. - The Commission should consider an additional consultation to gather further input on the expected practical implications.
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Meeting with Pascal Canfin (Member of the European Parliament) and ENGIE

3 Dec 2020 · Renovation wave

Response to Sustainable Products Initiative

16 Nov 2020

Saint-Gobain welcomes the European Commission’s Sustainable Product Policy Initiative: sustainable products are at the heart of Saint-Gobain, a multinational company that designs, manufactures and distributes construction products and services to improve our habitat and achieve sustainable buildings. For Saint-Gobain, sustainable products have reduced environmental and health impact throughout their entire life cycle, while delivering increased sustainability benefits for customers; the company equipped itself with strategy and tools for their development and wider-uptake in the market. Yet to ensure that sustainability progressively becomes the norm, the right policy framework needs to be in place. We see the following five areas as essential to accelerate the move towards sustainable products in the construction sector. 1. Improving knowledge, by disclosing the life-cycle assessment of products: the disclosure of the information regarding the impacts of products, including the climate and environmental ones, represents a key first step: it is the key to enable constant improvement, while providing relevant and transparent information to customers. This is specifically true for buildings, where in order to assess the sustainability performance of a building over its entire life cycle and make informed decisions at building-level, it is necessary to rely on consistent data (provided according to common standards) for the construction products and materials used. The best way to assess and disclose information is through the use of Life Cycle Assessments (LCA), whose results shall be displayed in Environmental products declarations (EPDs). The science-based assessment reference standard for construction products should be the existing EN 15804, and the recent EN 15804+A2, developed with engagement of the whole construction sector. Aware of the importance of disclosing information, Saint-Gobain has published 1255 verified EPDs for a wide range of products, in 31 countries (August 2020). 2. Strengthening the CPR to drive sustainability: the Construction Product Regulation offers a reliable framework, where requirements on circularity aspects could be made mandatory and integrated in the existing Declaration of Performance (DoP). We favor this option over a possible extension to the eco-design framework, which has been designed for end-use products; if the eco-design option is pursued, this would lead to overlaps and parallel regulation creating confusion for market players. 3. Stimulating better design of products and solutions via Eco-innovation: eco-innovation plays a center role in moving towards a circular economy. It should be encouraged as a way to optimizes environmental and economic outcomes across the full life-cycle of the product. To this aim, in 2017 Saint-Gobain developed SCORE, a tool allowing to evaluate our products according to sustainability criteria on the basis of 21 indicators, grouped into 5 categories (energy and climate, health, materials and circular economy, water, local value creation). Internally, it helps managers to improve the performance of our product portfolio. Externally, it helps delivering more transparent information to our customers. 4. Ensuring supportive circular economy policies: banning landfilling for recyclable construction and demolition waste (C&DW), clear recycling goals, support for circularity services, “end of waste” enabled for all the waste streams that can be safely treated: these are key necessary complementary policy elements to enable a transition towards resource efficient, circular products. 5. Facilitating the move towards a non-toxic environment via health transparency: we support the development of a European standard for content disclosure and hazard assessment, a tool to help harmonize how increasing demands from the market on content in products can be answered, in line with European regulations.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Saint-Gobain welcomes the intention to revise the Energy Efficiency Directive: the full potential of energy efficiency across all the sectors of the economy, and in particular in the building sector, needs to be untapped to achieve a reduction of at least 55% of GHG emissions by 2030. Moreover, as recognized by the IEA, 76% of the EU emission reductions required to keep temperature increases below 1.5°C must come from energy efficiency. In order for energy efficiency to become the first fuel of this transition, we would like to highlight the following recommendations, while pointing out to the importance to referencing the Energy Efficiency First principle in this directive to help ensuring its application across the different sectors and Member States: - The Energy Efficiency target should be increased and made binding across Member States. Europe’s cost-effective energy efficiency potential has been estimated at 40% by 2030, level to which the target should at least be raised. In addition, in order to trigger structural changes across Europe. Member states should be implementing nationally binding targets, reflecting their respective energy efficiency potentials, and expressed systematically in both primary and final energy. - Public Buildings must become a truly lighthouse for renovation: public buildings are estimated to account for 12% of the whole EU building stock. However, the current directive only covers a tiny fraction of this portion, limiting its provisions to centrally and owned and occupied buildings. The revision should expand its 3%/year renovation target to all public buildings, including schools, hospitals and social housing. At the same time, minimum energy performance standards should be introduced and tightened over the time, contributing to create a positive market dynamic stimulating the required renovation volume and depth, and putting the sector in the position to achieve a highly energy-efficient and decarbonized building stock by 2050. In parallel, alternative measures, such as selling buildings or behavioral changes, should be deleted, as these do not enable the achievement of structural long-term savings and related multiple benefits. - Holistic building renovation should be incentivised: Article 7 of the EED can play a significant role in the implementation of the long-term renovation strategies, especially via the Energy Efficiency Obligations Schemes (EEOs). In this light, EEOs should support the realization of holistic and deep building renovations, focusing on the end-use energy savings that directly benefit citizens and businesses. In parallel, this article should ensure better articulation with other incentives for renovation, both financial and regulatory ones. - Application of the neighbourhood approach: Building renovation dynamic at city and district level should be encouraged and the role of one stop shops recognized. This will help to maximize involvement of all actors, and inclusive deep renovation dynamics. -Off balance sheet treatments: a better recognition and promotion of the Eurostat Guidance Note on the recording of energy performance contracts in public bodies’ accounts should be fostered. - Energy Efficiency in industry should be further reinforced. The industry potential is still largely untapped; for instance, it is estimated that industrial insulation would deliver around 37 Mt annual cost-effective CO2 savings, or around 4% of industry’s total annual CO2 emissions (EiiF, 2020). The implementation of recommendations stemming from energy audits should therefore be made mandatory, especially for measures with a short pay-back period. A timely and effective revision of the EED has the potential to contribute to a deep economic transformation for a green recovery post COVID-19. We look forward to exchanging on the matter with the European Commission and other policymakers and stakeholders.
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Response to Chemicals strategy for sustainability

20 Jun 2020

Environment and health protection are at the core of Saint-Gobain’s commitment to offer sustainable products and solutions for the construction, mobility and life-science sectors: this goal is supported by a continued product development, where the environmental and health impacts are reduced throughout the entire life cycle of a product and the benefits for customers increased. In this light, we welcome the upcoming Chemicals Strategy for Sustainability and the willingness to address the gaps identified in the regulatory framework for chemicals, notably by the Communication of the interface between chemical, product and waste legislation. We would like to raise the attention on two dimensions this strategy should address: health transparency and the synergies with the circular economy. 1. Health Transparency: A renewed attention towards health and the development of the circular economy in construction has led to an increasing market demand for transparency around the ingredients contained in construction products and the hazards associated with these ingredients. The Group is in favor of greater transparency and keen to provide a proper, comprehensive and considered response to this demand that is consistent with existing regulations. Yet Saint-Gobain noted that there was no general consensus on the market around a standard methodology for providing such information and manufacturers are today faced with an increasing amount of schemes and methods for content declarations, often lacking harmonization with the EU regulatory framework. In this light, we believe that the method to declare the content of products as put on the market should be harmonised throughout Europe, by developing a European standard for content disclosure and hazard assessment for construction products. Such a standard will encourage the use of non-toxic and recyclable materials, while providing the necessary information to the different players in the value chain to manage their operations with the necessary knowledge level and improve the human health and the environment risk management. This information should be included in material passports as part of building passport, and remain accessible when the building and/or products reach their end-of-life, therefore facilitating the reuse or recycling. Such tools should seek consistency with existing databases. 2. Synergies with circular economy: Reuse and recycling of products starts with the development of infrastructure for selective sorting on jobsite, separate collection and take-back services. Over the past years, our insulation, glass and gypsum activities have all developed circularity services. In France, our Building Distribution activity created a structure to take-back waste from construction materials, products and equipment, becoming the first private network of collection points for waste from construction and civil engineering sites. But for circularity to happen at a greater scale in our sector, deconstruction (vs demolition) should become the guiding principle, and (non-weight) targets for the recycling of specific streams of construction products should be set. In addition, as the transformation of waste into valuable materials also relies on its correct treatment: in order to facilitate the recycling of different waste streams, it would be useful to define a clear and easy way to fix the end-of-waste criteria for products at the EU level. For products which provided their content declarations, the definition of these end-of-waste criteria should be easier, as the definition of these end-of-waste criteria is product specific and not substance specific. This gives the opportunity for the products which have a harmonised standard to integrate their specific end-of-waste criteria. We stand ready to complement the above information and we look forward to continuing working with the European Commission and stakeholders in this important area.
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Meeting with Pascal Canfin (Member of the European Parliament)

11 Jun 2020 · Green recovery

Response to Strategy for smart sector integration

8 Jun 2020

Saint-Gobain welcomes the initiative ‘An EU Smart Sector Integration Strategy’ and its goal of linking different sectors of the economy to deliver on the objectives of the European Green Deal in a cost-effective manner. Our contribution focuses on the role that buildings can play in enabling the decarbonisation of the other sectors, highlighting how an energy efficient and decarbonized building stock has a pivotal role in facilitating the further integration of the energy system. We call for the Sector Integration Strategy to be based on the following principles: 1) The Energy Efficiency First principle is the primary vehicle to decarbonize the energy system. Europe’ success in achieving climate neutrality across all the sectors of the economy depends on its ability to apply this principle as the cornerstone of every action in the policymaking, planning and investment sphere: it should therefore be the guiding pillar of the Strategy for the Smart Sector Integration. As it has been identified in the 2050 long-term strategy, achieving climate neutrality requires more than halving of today’s energy demand. Moreover, energy efficiency enables higher shares of renewable energies. If pursed together, energy efficiency and renewables enable faster reduction in energy intensity, lower costs for energy systems and social and environmental benefits. 2) Saving energy in buildings brings flexibility to the power sector, reducing the peak demand and facilitating the integration of renewable energy sources. If no action is taken to increase depth and rate of the current level of renovation, a study [1] has shown that electricity demand for the building sector will increase by about 79% compared to today’s levels, putting further stress to the power sector and making the decarbonisation of other sectors harder to achieve (e.g. in transport, where electrification is key for its low-carbon transformation). Moreover, the integration of higher shares of variable renewable energies in the power mix requires higher flexibility on the both demand and supply side to avoid power shortfalls. Next to larger grid infrastructure and energy storage options, highly efficient buildings are a key part in the solution, by increasing the demand-side management (DSM) potential to answer the flexibility requirements, thanks to the physical characteristics of an efficient building envelope. Indeed, a building with more thermal inertia allows more flexibility, e.g. disconnecting from the grid, without compromising on range of comfort requirements defined by its occupants. The peak capacity also benefits from energy efficient buildings, both on a seasonal (deep renovation can limit to 13% the 32% increase in buildings peak power demand estimated in EU scenarios) and on daily-demand basis (average of 30% peak demand reduction, with 40% operational cost savings) [1]. 3) Ensure alignment with 2050 objectives. While enhancing the cost-effective contribution of each sector to decarbonisation, the Strategy should build on the long-term goals already enshrined in the legislation. The Energy Performance of Buildings Directive fixed the 2050 objective of reaching a highly energy efficient ad decarbonized building stock, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings. In order to optimize the energy system and avoid lock-ins effect, this long-term objective should inform the decisions regarding future energy supply of buildings. The Smart Sector Integration Strategy should build upon the increasing performance of buildings. We look forward to exchanging on the matter with the European Commission and other policymakers and stakeholders. [1] Climact, 2018.The key role of energy renovation in the net-zero GHG emission challenge. Study commissioned by Eurima.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

Saint-Gobain welcomes the Renovation Wave initiative: the building sector should be treated as a strategic priority given its potential to deliver on the Green Deal and to be an immediate enabler for the green recovery. Achieving the full decarbonisation of the sector requires to triple the current renovation rate. Each renovation should reach an average of 75% energy savings (ClimACT, 2018). Decarbonising the building sector should be considered for its direct and indirect benefits as well as for its enabling role in decarbonising the wider economy: lower energy demand in buildings reduces the peak demand and facilitates the integration of renewables. The Renovation Wave should enable synchronized progress in 3 areas: First, consolidating the EU policy framework for renovation requires strengthening the long term renovation strategies (LTRS), which should be fully integrated in the National Energy and Climate Plans (NECPs), their timeline and review process. As an essential step, Member States (MS) should be further required to provide visibility regarding how intermediate milestones for 2030 and 2040 will enable to reach the 2050 objectives, both for the renovation rate and depth, making LTRS operational planning tools rather than reporting documents. On the rate, measures and financing should be made more specific to each segment of the stock and calibrated according to number of buildings to be renovated in a given period. Public buildings such as schools should be renovated as a priority matters. As for the depth, any building going through a renovation (deep or staged deep) should become at least nZEB equivalent or climate neutral compatible – and not only when a “major renovation” is carried. Deep renovations should be rewarded by policies and financing schemes, e.g. via preferential conditions according to the level of energy improvement. Second, driving demand for renovation requires to look for solutions that embrace the regulatory, financing and supporting dimensions. Concrete steps should be undertaken to phase out the worst performing buildings (e.g. F&G class buildings) in the next decade, via the introduction of minimum energy performance standards (MEPS) adapted to buildings types and ownerships. MEPS will provide visibility of the role that all buildings have to play in decarbonising the sector, while helping millions of European get out of energy poverty. Key changes in ownership or occupancy (trigger points) should be generalized to perform energy efficiency works. Additionally, simple, adequate and tailored financing scheme are needed, with a focus on vulnerable households. On financing, the EU should make the difference by creating a dedicated Renovation Fund that will support the national financing capacity, notably via boosting Technical Assistance and project bundling capacity, in support of local project development. Not least, building renovation passports (BRP) should be generalized as part of the next EPBD revision, as a tool to encourage action with targeted support, overcome technical complexities and reduce the risks of lock-in effect. Third, the Renovation Wave should foster training and preparedness in the whole value chain. LTRS and MEPS will give visibility to all actors and align on what’s need to be done. The Renovation Wave should encourage new business models and solutions, e.g. prefabricated solutions. It should also foster the development of accreditation schemes for SMEs to support higher quality and performance. The role of public and private aggregators such as one-stop-shops should be encouraged, given that only 5-7% of existing SMEs currently have the ability to handle multi-tasks renovation projects (cf. INNOVATE H2020). The functions of auditing, identifying needs, elaborating improvement plans, specifying and coordinating works and monitoring outcomes are essential. Boosting local project management and coordination capacity is a prerequisite to scaling up renovation.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and

4 May 2020 · Renovation wave and recovery

Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · Follow-up call on the crisis’ impact on the built environment sector

Response to 2030 Climate Target Plan

15 Apr 2020

Saint-Gobain endorses the objective of achieving a climate neutral Europe by 2050 and welcomes the initiative of increasing the 2030 climate ambition in order to have a gradual, predictable and stable reduction pathway. As warned by the UN Intergovernmental Panel on Climate Change (IPCC), the 2021-2030 decade will be crucial to avoid the worst consequences of climate change. We support the proposal to reduce GHG emissions by 55% by 2030, compared to 1990 level. Saint-Gobain designs, manufactures and distributes materials and solutions that can be found everywhere in our living places and our daily life: in buildings, transportation, infrastructure and in many industrial applications. They provide comfort, performance and safety while addressing the challenges of sustainable construction, resource efficiency and climate change. In 2019, Saint-Gobain signed the Global Compact pledge “Business ambition for 1.5°C”, committing itself to reach net-zero emissions by no later than 2050 in line with the goal to limit the rise of global temperature to 1.5°C. The Group is currently working on an internal roadmap with intermediate milestones towards the objective. A clarification on the intermediate EU GHG reduction target for 2030 objective will clarify the European collective effort and further input the internal road-mapping exercise. It is well acknowledged that in the transition, all sectors of the economy and the society will need to contribute. In this light, we believe that the full potential stemming from the building and construction sector should be fully captured in the upcoming impact assessment. In the modelling exercise, we therefore recommend to take the following points into account: • Consider the Energy Efficiency First principle: this principle should drive any new impact assessment work regarding the trajectory towards carbon neutrality in 2050, and milestones in 2030 and 2040. Respecting it will be essential to understand the synergies between energy efficiency and renewable energies and the sub-sequential raise of these targets. It has already been shown that the EU cost-effective energy savings potential lies at 40% by 2030. The whole policy framework would be strengthened if these targets would be made binding. • Recognise the contribution of building renovation as a cornerstone of any scenario: a study [1] demonstrated that to stay on track toward climate-neutrality, a minimum of a 3% renovation rate per year combined with an average energy efficiency improvement of 75% need to be reached by 2030, reiterating the how crucial the next decade is. Otherwise, if the building sector fails to deliver its share of GHG emission cuts, it will leave a GHG reduction gap of 10% to 14% percentage points. • Ecompass the multiple benefits and the cost of non-action: the non-financial impacts connected to increased ambition (e.g. jobs created, reduced air pollution, health improvements, avoidance of environmental damages…) should be factored in the analysis to account for the full reality. Importantly, an increase in the ambition in the energy efficiency and in the renovation agenda has the potential to create a new green stimulus for the economy, providing jobs and growth. The 2015 Energy Productivity and Economic Prosperity Index estimates that up to 1.8 million new jobs could be created if Europe’s energy bill was cut by 200€ billion. This economic boost would translate into 40€ billion in extra net income to public finances and would be in the form of direct jobs, which cannot be delocalised. We look forward to exchanging on the matter with the European Commission and other policymakers and stakeholders. [1] Climact, 2018.The key role of energy renovation in the net-zero GHG emission challenge. Study commissioned by EURIMA.
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Meeting with Thierry Breton (Commissioner) and Bayer AG and

7 Apr 2020 · The impact of COVID-19 on the built environment ecosystem

Response to Climate Law

6 Feb 2020

Saint-Gobain endorses the objective of achieving a climate neutral Europe by 2050 and welcomes the upcoming Climate Law enshrining this objective in the EU legislation. Saint-Gobain designs, manufactures and distributes materials and solutions that can be found everywhere in our living places and our daily life: in buildings, transportation, infrastructure and in many industrial applications. They provide comfort, performance and safety while addressing the challenges of sustainable construction, resource efficiency and climate change. In 2019, Saint-Gobain signed the Global Compact pledge “Business ambition for 1.5°C”, committing itself to reach net-zero emissions by no later than 2050 in line with the goal to limit the rise of global temperature to 1.5°C. The Group is currently working on an internal roadmap with intermediate milestones towards the objective. We believe that the Climate Law should contain: 1.A clear direction of travel at EU level will be crucial to make the transition irreversible for all actors – markets players, institutions, finance and citizens, to catalyse their respective efforts and provide predictability for investments. A stable legal framework toward 2050 will enable the various instruments, e.g. carbon pricing, to deliver their full impact. 2.The recognition of the Energy Efficiency First (EE1) principle as overarching principle for the climate and energy transition. This principle enables a fair assessment of the direct and indirect benefits of energy efficiency options compared to supply-side options. The principle must apply to all policy-making and investment decisions at EU and national level, and it should drive any new impact assessment work regarding the trajectory towards carbon neutrality in 2050, and milestones in 2030 and 2040. Embracing the EE1 in any modelling work, e.g. the impact assessment that will be presented in Summer 2020, will be essential to understand the synergies between energy savings and the integration of renewables. 3.A call for setting intermediate targets and ensure a monitoring of the developments. The law should call for setting targets for 2030 and 2040, according to the current climate and energy target architecture. The whole policy framework would be strengthened if these targets would be made binding. This would translate in a more solid monitoring and when needed adjustment and revision of the concerned policies to bring the targets in line with new long-term objectives. If we want to meet the 2050 target, progresses need to be monitored in order to ensure readiness for bridging gaps. The National Energy and Climate Plans (NECPs) should form the basis for tracking these progresses. In the building sector, the starting point should be the analysis of the Long-Term Renovation Strategies. 4.A consideration of sectorial potentials: in order to provide predictability and long-term vision, the Law should present efforts expected from the different sectors of the economy. It should also encourage the development of sectorial roadmaps, building upon solid stakeholders and citizen’s engagement. This is particularly true for the building sector: the Climate Law should reference the objective already affirmed in the Energy Performance of Buildings Directive (EPBD), as to achieve a highly energy energy-efficient and decarbonized building stock by 2050, while embracing the buildings’ whole life carbon perspective (as already explored in the Level(s) voluntary framework). As a reminder, a Climact study commissioned by Eurima demonstrated that to stay on track and to reach a net-zero scenario with efforts shared across sectors, buildings need to play a pivotal role: renovation rate need to be ramped up to at least 3%/year with an average energy efficiency improvement of 75%, both reached at the latest by 2030. See : https://www.eurima.org/uploads/ModuleXtender/Publications/174/Climact_Role_of_Energy_Renovation_in_Net-Zero_GHG_Emission_2050-Final.pdf
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Response to A new Circular Economy Action Plan

20 Jan 2020

Saint-Gobain welcomes the initiative of adopting a new Circular Economy Action Plan and especially the willingness to put the construction sector at the top of the agenda. Being today a resource intensive sector, the potential for improvement is high: the right policies, including a long-term vision for how the construction sector can evolve and transform itself, will spur the move towards circularity, while creating economic growth, jobs, new services and activities. We have identified 5 key areas that can contribute to the move towards full circularity in the construction sector. 1. Moving away from landfill. A ban on landfilling for recyclable Construction and Demolition Waste (C&DW), coupled with clear C&DW recycling goals, should be set. Specifically, the objectives for recycling should be based on a targeted approach, ensuring the capture of non-heavy weight and precious materials. These goals should be accompanied by milestones supporting their achievement. 2. Managing the end-of-life. Reuse and recycling of products starts with the development of infrastructure for selective sorting on jobsite, separate collection and take-back services. During the past years, our insulation, glass and gypsum activities have all developed circularity services. For this to happen at a greater scale, deconstruction (vs demolition) should become the guiding principle. Buildings’ pre-demolition inventories / audits and building's passports are key instruments to achieve this goal and should be made mandatory. The use of digital tools should make this easier to achieve. 3. Facilitating a greater use of secondary raw materials. The enabling factors for transforming waste into value fall in two categories: Firstly, the knowledge of the product and, once waste, the recognition of the right status. To answer the increasing demand for health transparency and facilitate the move towards a non-toxic environment, the EU should work alongside stakeholders to develop a European standard for content disclosure and hazard assessment, in order to get more knowledge about product’s content; “End of Waste” status should then be enabled for all the waste streams that can be safely treated. S econdly, higher demand. To create the demand, public procurement should be used to encourage recycled content in certain products. The exemplary role of publicly funded buildings should be promoted, e.g. via setting mandatory targets for the use of recycled materials (with minimum recycled content, to be defined by product categories). 4. Consuming less and better designing products and solutions via Eco-innovation. Eco-innovation plays a center role in moving towards a circular economy, as it optimizes environmental and economic outcomes across the full life-cycle analysis of the product (calculated according to the ISO and EN norms). The uptake of eco-innovation should thus be fostered as a key tool to develop low carbon products, and it should be accompanied by the encouragement to adopt EPDs (Environmental Product Declarations) for the disclosure of life-cycle impacts. Saint-Gobain has developed an internal tool, SCORE, to boost eco-innovation and improve product performance against sustainable development criteria (see: https://www.saint-gobain.com/en/score-puts-sustainability-core-saint-gobains-business) 5. Level(s): encouraging a full life-cycle approach and making it a central pillar for the sustainability of buildings. The voluntary sustainability assessment scheme Level(s) has generated a positive dynamic and boosted skills on the application of the Life-Cycle Approach. To ensure sustainable buildings becomes the new norm, it is now time to capitalize on the outcome of the testing phase to refine Public Procurements Guidelines (creating a positive dynamic on the market) and develop a new way forward to integrate the impacts covered by Level(s)’s macro-objectives in policies, starting with GHG emissions and resource and circularity agenda.
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Response to Commission Regulation amending Annex XIV to REACH

22 May 2019

On behalf of the company Kaimann Saint-Gobain and vicariously for the Saint-Gobain Group we would like to express our heavy concerns with the Annex XIV inclusion proposal for ADCA. The impact on business, employment -and not to forget the climate protection targets of the EU- of such decision against ADCA cannot be overestimated. Kaimann is a leading manufacturer of foam products -foamed with ADCA- that are mainly used for energy efficiency applications, i.e. insulation. We have an almost 40 years history of use of ADCA in an order of magnitude of >30,000 tons in total, and no case of irritation or sensibilisation could ever be identified among our staff, even during times where ADCA was used as pure powder on open mixers. Today, our processes are running in closed mixing systems where ADCA is put into the mixers in fully closed bags and cannot be released into the environment, which we prove regularly by 3rd party measurements. Once mixed, ADCA is completely bound into a matrix and due to its nature as blowing agent it is fully decomposed and no more present in the final products we supply. The insulation products our industry is manufacturing are saving a huge multiple of the CO2 needed for their manufacturing during their use, which is proved by life cycle assessment and 3rd party EPDs. The products' properties required for such performance can only and exclusively be achieved by the use of ADCA. All so-called alternatives proved to be totally useless (such as NaHCO3) and/or show insufficient expansion together with notable toxicity (such as 5-PT, TSH, OBSH). Means, as a consequence of an Annex XIV listing of ADCA this entire class of products could and would no more be manufactured in the EU. However, as they are essentially required for today's building and machinery industry, they would be manufactured under conditions the EU cannot influence and then would be imported from abroad. This would be completely contradictory to several of the EU's targets. Additionally, there is of course an impact on employment, means in practice we would shut down in the EU. However, the impact is not only short-term, but also on future competitiveness of the European industry: currently the by far biggest reasearch and development work on ADCA expanded materials is done in the EU. By listing this material a notable part of the EU industry, from automotive & transportation to building & construction, would lose ground, and the excellence for chemically expanded foams would shift abroad. For all a.m. reasons we clearly have to state that the proposal of including ADCA in annex XIV is not at all proportionate compared to the substance's risk potential -which still has to be questioned- but would lead to seriously negative consequences. We therefore propose that the European Commission and the Reach Committee -should exclude ADCA from the proposed list of substances for inclusion in Annex XIV of REACH; -should set the necessary steps to establish suitable alternative measures, such as a European-wide occupational exposure limit for ADCA, to further ensure that worker exposure is minimized and controlled at European level.
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Meeting with Miguel Arias Cañete (Commissioner)

21 Feb 2019 · Climate natural strategy

Meeting with Dominique Ristori (Director-General Energy)

25 Sept 2018 · le potentiel d'efficacité énergétique, de décarbonisation, de développment économique et de création d'emplois autour de la rénovation des bâtiments

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and Beiten Burkhardt

8 Jun 2017 · Antidumping investigation on open mesh fabrics of glass fibres

Meeting with Pierre Moscovici (Commissioner)

3 Feb 2017 · Le paquet législativ "clean Energy for all" et les opportunités économique que ce paquet peut générer en Europe.

Meeting with Dominique Ristori (Director-General Energy)

1 Jun 2016 · Energy policy