EUPAVE - European Concrete Paving Association
EUPAVE
EUPAVE MISSION Advocate and enable wider use of cement and concrete applications in European transport infrastructure by engaging with EU, national and local decision makers, by disseminating technical know-how and communicating benefits and by promoting innovation and best practices in the sector.
ID: 76295483387-66
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
27 Nov 2025
As EUPAVE, the representative organization for the concrete paving industry in Europe, we believe that some of the technical screening criteria dealing with the use of concrete for roads could be improved. So, we would like to make some specific comments on the following sections: §3.4 (p. 61/164): Maintenance of roads and motorways, including routine and preventive maintenance as well as rehabilitation, where both asphalt and concrete pavements are considered. §3.5 (p. 63/164): Use of concrete in civil engineering for new construction, reconstruction, or maintenance of civil engineering objects, with road surfaces falling under §3.4. Our main concern relates to the requirement in §3.4 to use at least 50% recycled or reused materials, in mass, of the structural road element. While we fully support the promotion of circular economy principles, this target poses significant technical challenges. The formulation of this requirement is strange as it expresses the objective as a mass percentage, without mentioning aggregates or raw materials. Indeed, for a concrete element, recycling 50% in mass would mean that all of the coarse aggregates must come from recycled materials and this is almost never possible. The conditions for concrete in structural engineering (§3.5) are expressed in a clearer way and seem more appropriate; we suggest they could also be used for concrete in road maintenance activities. Another comment is about creating a level playing field between concrete and asphalt pavements, taking into account the maintenance frequency and the service life of the road. Indeed, maintenance activities and lifetime of the pavement will also impact the need for new resources and thus is of importance in the light of this regulation. We have detailed our comments and suggestions in the attached document.
Read full responseResponse to Proposal for a Regulation on Military Mobility
8 Oct 2025
EUPAVE the European Concrete Paving Association supports the initiative on strengthening military mobility . The need to invest urgently in 4 critical corridors and upgrade essential dual-use infrastructures has been clearly identified. Resilience and resistance to the consequences of climate change have also been identified in the Action plan on military mobility 2.0. The four priority corridors require the availability of all transport modes: rail, road, sea and air. For all modes, there is a need for (re)construction, adaptation, repair, extension and upgrading in terms of capacity and resilience of the infrastructure assets for road- and railways, bridges, airfields and multimodal hubs. From a strategic perspective it must be pointed out that concrete is a local building material and thanks to the decarbonisation of the cement production it is hardly dependent on (imported) fossil fuels. Concrete pavements and engineered structures show superior load bearing capacity, durability and climate resilience.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
EUPAVE, the European Concrete Paving Association, supports the principles of circular construction in the Commission Delegated Regulation on Taxonomy. However, the imposed recycling rates are not defined in a clear way and the mandated recycling fractions for road pavements go beyond technically feasible limits and thus risk compromising the roads durability and consequently its sustainability. Indeed, a shorter lifespan of the pavement leads to a higher use of new materials and thus goes against the rules of circular economy. We also demand for a more holistic approach in order to create a level playing field between asphalt and concrete pavements. After all, the longer service life of a concrete road avoids periodic renewal of layers and thus avoids the use of new resources. We remain available for further discussion and technical support.
Read full response18 Dec 2020
The road is a vital link in transport infrastructure. Harmonisation in quality of the road and operation as well as the capacity of the infrastructure can provide continuous mobility on European corridors. The challenge is to improve the road network in order to ease traffic flow, reduce congestion, reduce journey time and enhance road safety, whilst contributing to decarbonisation.
The solutions used in road construction shall provide the technical qualities that the new TEN-T sets, most notably resilience and sustainability. The choice of appropriate pavement structures and materials plays an important role in the selection of these optimal solutions. In the specific case of TEN-T motorways, concrete roads offer several significant advantages.
For instance, fuel consumption of heavy vehicles is lower on concrete roads compared to asphalt roads. That is because concrete pavements are rigid structures, which show less deflection under heavy traffic. The effect of a deflected pavement under a wheel load is the same as if the vehicle would constantly drive uphill and would consequently consume more fuel and emit more CO2. Based on data from the European road transport network, changing from flexible asphalt to rigid concrete creates over 50 years a difference in Global Warming Potential estimated to be 78 kg CO2/m2 of pavement, more than offsetting its own CO2. Considering the total motorway network and freight road transport in Europe, there is a potential of saving 2.5 million tonnes of CO2 per year.
Moreover, concrete surfaces show a high albedo; this means they reflect light rays and thus energy, and consequently slow down global warming equivalent to a CO2 reduction of 25 kg/m². In addition, this reduces the Urban Heat Island Effect, saves costs and energy for road lighting, and offers better visibility.
Concrete pavements need less repair, thus reducing congestion and improving safety. The higher time without maintenance compared to other pavements, such as asphalt, entails a lower lifecycle cost, as well as a reduction in public expenditure.
Furthermore, concrete pavements offer optimal solutions for automated, connected, and electric vehicles. Finally, the latest construction techniques have significantly reduced the rolling noise levels of vehicles.
We believe that the future TEN-T strategy has to be coupled with updated and innovative public procurement guidelines or directives which give more weight to sustainable solutions. The number and quality of criteria to reach a sustainable solution for infrastructures and, in particular, roads must increase in line with the objectives of the European Green Deal.
Nowadays, the share of concrete pavement represents less than 5% of EU’s total, due to the lack of open competition between different types of pavement. However, it should no longer be determined by an only-price approach, and, instead, other factors such as MEAT should be prioritised. Sustainability aspects such as circular economy, CO2 reduction, LCC and LCA must be an integral part of the contractor’s final offer. This would, in turn, increase the competition between more innovative solution for roads. And, indeed, more competition considering the referred criteria rebounds positively in safeguarding the environment.
To sum up, the revision of TEN-T should include a more holistic vision, which envisages investment not only to new, but into safer, smarter, more sustainable and long-lasting infrastructures. They shall take into account both mobility and green challenges.
Under Next Generation EU, it seems only natural to invest more into innovation for road infrastructure, which gives path to a more connected Union, especially with those regions which are not reached by other infrastructures. Therefore, the European Commission and, later, the Member States should set ambitious goals whereby they commit to invest in adapted, safer, more integrated and more resilient roads.
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Read full responseResponse to Assessment and management of environmental noise
2 Sept 2020
Regarding Table F-4 on page 42 of the Draft Annex to the Commission Delegated Directive, we have the following comments:
- In table F-4 on page 42, the following terms: “brushed down concrete”, “optimised brushed down concrete”, “worked surface” are not correct. They are wrong translations from Dutch words and are not understandable for someone who doesn’t know the Dutch expressions.
- Table F-4 on page 42 is (exclusively) based upon experience in the Netherlands. Other countries, however, have more experience and more data about some of the road surfaces. This directive should not be based upon just Dutch data. These data should not be generalised. Input from CEN TC227 WG5 should be asked.
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