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European Association for External Thermal Insulation Composite Systems

EAE

EAE promotes the use of well approved External Thermal Insulation Composite Systems (ETICS).

Lobbying Activity

Response to European strategy for housing construction

18 Sept 2025

The EAE, European Association for External Thermal Insulation Composite Systems (ETICS), welcomes the European Commissions Call for Evidence in support of a European strategy for housing construction. With a holistic approach, coordinating the objectives of various EU policy objectives, the EU construction ecosystem offers a huge potential for Europes economic growth and strengthens the competitiveness of the sector whilst securing and increasing employment, and providing solutions for social, climate and energy related challenges. Our detailed feedback can be taken from the attached document.
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Response to Revision of the Standardisation Regulation

21 Jul 2025

The EAE, European Association for External Thermal Insulation Composite Systems (ETICS), welcomes the European Commissions Call for Evidence in preparation to a revision of the Standardisation Regulation. Establishing and strengthening the Single Market for construction products offers a huge opportunity for contributing to Europes economic growth and strengthens the competitiveness of the sector. According to DG GROW the construction industry provides 18 million direct jobs and contributes to about 9% of the EU's GDP. It creates new jobs, and provides solutions for social, climate and energy related challenges. The sector represents a huge number and broad variety of entities from global players to many SMEs, from stock-listed to family-owned businesses among those very often global market leaders and hidden champions. The single market for ETICS is at the core of EAEs activities. Hence, we are actively involved in standardization bodies at CEN and the development of EADs at EOTA. We are deeply convinced that removing barriers to trade by means of European harmonized technical specifications significantly lowers costs and efforts for the industry as fragmented national certification, approval, etc. is often based on different characteristics, test methods and criteria. Please, recognize hereafter our reflections and recommendations for future improvements considering the experience with the construction product External Thermal Insulation Composite System (ETICS). 1. EAE appreciates the entering into force of the revised Construction Products Regulation (CPR) 2024/3110 beginning of 2025. With this, the CPR Technical Acquis process has been formally established to collect member states requirements ahead of standardization requests. This marks a major step forward as previously the work of standardization committees was often delayed because of uncertainties about relevant national regulatory needs. Or regulatory needs were tabled at the far end of the standardisation process. Both required revisions of already broadly accepted draft standards and delayed the process, wasting valuable resources of all stakeholders. 2. We recommend to make sufficient capacities available at DG GROW to support both the CPR Acquis process (including subgroups for horizontal aspects and product related) and the standardization activities after a standardization request has been issued. Since many years our industry has demonstrated its commitment to invest huge amounts of time and money to develop both product standards and test standards. We continue. However, sometimes advice on how to comply with legislation is needed during the drafting process. It has turned out that discussions with EC representatives and their consultants help to clarify specific topics and thus speed up the standardization process. This requires availability of capacities at EC level. 3. We understand that the European Commission aims to involve all relevant stakeholders, including civil society, in standardization bodies. A fair balance of voting rights needs to be ensured both at Europeann level and in national mirror committees that ensures that the voices of the manufacturers of the product in question are equally represented. 4. CEN should remain the key standardization organization for construction products. Most existing product and test standards have been successfully developed and established via the CEN route over decades. This immeasureable source of knowledge and experience must be kept. Sufficient management resources need to be allocated to ensure support of standardization bodies as this helps to speed up the development of standards. More points can be taken from our position paper attached. We stand ready for further discussions.
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

The EAE, European Association for External Thermal Insulation Composite Systems (ETICS), appreciates the European Commissions Call for Evidence on the Industrial Decarbonisation Accelerator Act and thanks for being given the opportunity to contribute. Speeding up the decarbonisation of all economic sectors whilst ensuring the competitiveness of our industries will be key to achieve the objectives of the Clean Industrial Deal. We do understand that the focus of the initiative is on decarbonizing energy-intensive industries (EIIs). However, we remind legislators that holistic approaches and reliable framework conditions are needed for all sectors to plan their investments. In particular, industries that contribute to decarbonization with their final products must be equally considered in the impact assessment and in all foreseen support measures. To give an example: investing in the reduced energy demand of Europes building stock by minimising the thermal losses through building envelopes creates positive impacts on the overall energy infrastructure. Energy-efficient buildings, ideally combined with on-site renewable energy generation and EV charging points must be understood as as parts of our electricity systems, flattening the peak demand curve. This way they place less strain on power grids and heating systems, which can lead to smaller and cheaper grid solutions. By reducing peak demand and overall energy consumption, we can enhance the resilience of our energy systems and lower costs for all consumers, including industry. This also marks an example that supply and demand need to be thought together. We appreciate the European Commissions initiative to less bureaucratic and more digitalised procedures. Especially construction products manufacturers will benefit, as they are facing challenging economic circumstances. Regulation both at European and national level should not be too granular but focus on objectives. This will allow economic operators to constantly improve and to innovate new processes, products and services whilst reducing the time to market. Following some examples how to facilitate this, mainly to be addressed via a bold implementation of the Construction Products Regulation. Some aspects must be further discussed in the respective horizontal subgroups of the CPR Technical Acquis Process. For more details, we refer to the attached document. Thank you for considering EAEs views. We remain at your disposal for further discussion.
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Response to European Affordable Housing Plan

4 Jun 2025

Affordable Housing Plan: energy-efficiency as key enabler and less bureaucracy EAE, the European Association for ETICS, welcomes the initiative of the European Commission and the European Parliament to address the housing crisis via coordinated policymaking to be laid down in the upcoming EU Affordable Housing Plan. Housing is one of the essential needs of all Europeans. Since several years we observe in all member states of the European Union a significant lack of affordable homes or appartments whilst observing declining numbers of building permits for new residential units. Even worse, the rate of building renovations is still too low to meet EUs ambitions to decarbonise Europes building stock by 2050 as laid down in the European Climate Law - without leaving anyone behind. According to Eurostat almost one in ten EU households (9,2% in 2024, see [2]) is not able to keep the home adequately warm with rates of up to 19% in single countries (e. g. Greece, Bulgaria, Lithuania). All this contributes to social inequality and a lack of social inclusion, putting social security at risk. EAE calls on the European Commission and the European Parliament to take a broad and long-term perspective. Affordable housing needs to be addressed holistically. It must not only take in view the upfront costs for new housing or building renovations but the entire building lifecycle. In particular, the operating costs and the end of life need to be considered equally. Otherwise, measures might create quick benefits today but generate long-term lock-in effects. This is essential as buildings are true long-term assets. Everything built or renovated today will determine costs, environmental and societal impacts for decades. The existing residential building stock (101,5 million buildings) must not be forgotten when discussing affordable housing. As most of those buildings will still exist in 2050, they offer the greatest leverage for improvements; today they represent 27% of EUs total final energy consumption and 21,5% of GHG emmssions. 64% of the residential energy consumption is caused by heating and cooling and can be significantly lowered by thermal insulation of building envelopes. Investing in energy efficiency also has positive implications for the overall energy infrastructure. Energy-efficient buildings place less strain on power grids and heating systems, which can lead to smaller and cheaper grid solutions. By reducing peak demand and overall energy consumption, we can enhance the resilience of our energy systems and lower costs for all consumers. Energy-efficiency needs to be the guiding principle, as laid down in Article 3 of the Energy Efficiency Directive (EED). Public authorities shall lead by example (Articles 5 and 6 EED). This is essential as typically the worst performing buildings are occupied by the most vulnerable households. Affordability for them is closely linked to operating costs. Hence, investments in energy-efficiency improvements play a crucial role. In many urban areas we observe an increasing number of vacancies of office buildings or industrial buildings. Efforts should be strengthened to find ways to transform such places where technically and financially feasible to residential floor space. The same applies to floor additions or extensions of existing residential buildings. This will both support sustainability and make available urgently needed residential space without increasing land use. In parallel, barriers to new residential homes must be lowered especially the procedures for building permits must be shortened. For both, new construction and building renovation all stakeholders along the construction value chain require stable and predictable framework conditions, both in terms of regulation and financial support. We observe in several member states that stop-and-go policymaking leads to significant lower building and renovation demand due to uncertainties. For more, check our position paper.
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Response to Single Market Strategy 2025

31 Jan 2025

The EAE, European Association for External Thermal Insulation Composite Systems (ETICS), very much appreciates the European Commissions Call for Evidence on the Single market strategy 2025. Establishing and strengthening the single market for construction products offers a huge opportunity for contributing to Europes economic growth. According to DG GROW the construction industry provides 18 million direct jobs and contributes to about 9% of the EU's GDP. It creates new jobs, and provides solutions for social, climate and energy challenges. The single market for ETICS is at the core of EAEs activities. Hence, we actively support, among others, standardization bodies at CEN, the development of EADs by EOTA, the efforts towards a European assessment method for façade fire testing. Already years ago we voluntarily developed the first European Application Guideline for ETICS [1] to share our experience and to contribute to proper, safe and durable planning and installation of ETICS. The document has been translated by our national member associations and even beyond (China, Japan). We are deeply convinced that removing barriers to trade by means of European harmonized technical specifications significantly lowers costs and efforts for the industry as fragmented national certification, approval, etc. is often based on different characteristics, test methods and criteria. Please, recognize our reflections on the single market in the attached document.
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Response to Roadmap on REPowering the EU with Hydrogen Valleys

4 Sept 2023

EAE calls for holistic and sectoral approaches With interest we noticed the European Commissions Call for Evidence on REPowering the EU with Hydrogen Valleys (roadmap). EAE is fully committed to the objectives of the Green Deal and the REPowerEU initiative to reduce dependencies on energy imports. EAE welcomes all initiatives that lead that way. Finally, we need a mixture of different measures to achieve EUs ambitions and each of them needs to play its part. Having this in mind, EAE calls for holistic and sectoral approaches that help allocate limited resources to sectors and applications that will benefit most. Long-term reliable pathways will be essential to deploy investments in urgently needed additional capacities. This applies to hydrogen as well as to thermal insulation systems. Therefore, we urgently call for a level playing field of different solutions. Supporting single new technologies must not lead to disregarding of other technologies, especially reduction of financial support. As rightly said in the call for evidence, H2Vs need to be aligned with upscaling renewable energy generation to contribute to the decarbonisation of Europes economies. EAE strongly recommends to keep a clear sectoral approach. As for the coming decades the availability of green hydrogen will be limited, its use should be allocated to sectors and end-use applications that require it most because of lacking carbon-neutal alternatives. Examples might include energy-intensive industries, shipping, heavy trucks, railway services, maritime traffic. On the other hand, there are sectors where alternatives are already available on the market but need to be scaled-up. The construction sector marks a perfect example for the latter. Europes existing building stock represents 36% of all CO2 emissions and 40% of the EU energy demand. As the majority of todays buildings will still be in place in 2050, decarbonsation efforts need to keep strong focus on building renovation. Technologies are available and mature but need to be scaled up. Minimising the energy demand in the building stock as demanded by the recast Energy Efficiency Directive will indirectly contribute to the hydrogen strategy. Low energy demand for heating, cooling and warm water sets hydrogen capacities for other sectors free. Generally, we call on decision makers to focus in the current decade on the implementation and upscaling of already available technologies. Research and innovation in new technologies are necessary but will only become effective at scale towards the end of this decade. They will fully deploy their potential in the following one. Relying too much on R&I for the current decade might leave us with a crucial gap and might make the challenges for the future even harder and more expensive. On the other hand, expected R&I outcomes should be considered in the current development of the 2040 EU targets to achieve a long-term trajectory. EAE remains at your disposal for further discussion.
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Response to Review report on the Governance Regulation of the Energy Union and Climate Action

3 Aug 2023

With interest we noticed the European Commissions Call for Evidence Energy Union and climate action Review report on the Governance Regulation and we are thankful being invited to contribute with our views. EAE very much appreciates the efforts taken by the European Parliament, the Council of the European Union and the European Commission in recent years to create a coherent legislative framework and coordinated action towards the Energy Union and to mitigate climate change. In this regard, the Governance of the Energy Union and Climate Action (Regulation (EU) 2018/1999) and the European Green Deal as the overarching strategy of the current legislature mark important cornerstones. EAE is fully committed to the objectives of the Green Deal and the decarbonization of EUs economy by 2050. As this transition will be a marathon rather than a sprint, it needs to be continued in the following term. Although the EAE widely appreciates the achievements, we recommend updating the Governance Regulation and related procedures in the relation between the European Commission and member states as follows. Key messages - Align the Governance Regulation with other legislation, especially the outcomes of the legislative initiatives of the Fit-for-55 package and the REPowerEU initiative. - Highlight the efficiency-first principle as mandated by the new Energy Efficiency Directive. - Holistic approaches are needed: all technologies need to contribute to decarbonization. - Avoid new dependencies and lock-in effects because of short-term actions. - For the current decade focus on unleaching the potential of already existing technologies. - Make national plans manageable: measures and objectives need to be specific and measurable. Implementation must be monitored. - Volatile changes in policy making and financial support schemes create uncertainties for both private and institutional investors. - 2040 objectives should be included to support the long-term trajectory. - Involve stakeholders to achieve broad commitments and take people on board. For more details, please see our attached position paper.
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Response to Action plan on accelerating Heat Pump market and deployment

26 May 2023

With interest we noticed the European Commissions Call for Evidence on a heat pumps action plan to accelerate the roll-out across the EU. EAE is fully committed to the objectives of the Green Deal and the decarbonization of EUs economy by 2050. Europes existing building stock represents 36% of all CO2 emissions and 40% of the EU energy demand. As the majority of todays buildings will still be in place in 2050, decarbonization efforts need to have strong focus on building renovation. New buildings of today will need to meet the zero emission standard anyhow as they will most likely not undergo major renovation before 2050. Both, the intended revision of the Energy Efficiency Directive (EED) and the Energy Performance of Buildings Directive (EPBD) consider this from a holistic perspective. Key enablers must be: - the reduction of the energy demand (EED and EPBD explicitly mention the priority of the efficiency first principle) on the demand side and - the shift from fossil fuels to renewable energies on the supply side. The smaller the residual energy demand of sufficiently insulated building envelops, the easier the shift to renewables with existing technologies (including heat pumps) and grids. From our perspective this is sufficiently supported by the EPBD revision which sets a reliable and binding trajectory for improving the energy performance of buildings through minimum energy performance standards. This will be supported by one-stop-shops offering both technical and financial assistance to building owners. Building individual renovation roadmaps will provide guidance to building owners how to achieve the zero emission standards by 2050 with the final objective of deep renovation efforts. This holistic approach considers the status quo of individual buildings, helping to identify individual trigger points for single renovation measures and the cost-optimal mix of measures to achieve decarbonization. Instead of highlighting one single technology by a new action plan, the European Union should take care of immediate implementation of already existing or expected legislation, aligning it with long-term reliable financial support schemes with equal support of all measures and technologies. Finally, we will need all technologies to achieve the ambitious targets and to more than double renovation rates to unleash the full potential of the Renovation Wave. Heat pumps will and must be important pieces of the puzzle. But the same applies to building insulation, windows, photovoltaics, etc. As rightly said in Part A Political context, the REPowerEU plan calls for prioritizing investments on renewables and energy efficiency to reduce fossil-fuel imports. The proposed doubling of current roll-out rates of heat pumps applies equally to all other technologies as mentioned before. To avoid misallocations and to ensure a level playing field for all European manufacturers, we urgently call on holistic approaches. According to our experience, one of the key barriers to deploy the urgently needed potential of building renovation are unstable framework conditions, both on regulatory side and financial support side. We observe in many member states volatile funding situations and constant discussions on future building requirements. These uncertainties hinder both building owners and construction product manufcturers from making long-term investment decisions. This applies even more in case of stage-deep renovation plans if building owners cannot afford deep renovation in one step. The framework conditions are already very fragmented and should not be further increased by action plans fostering single technologies. More efforts and budget should be spent on information campaigns, easily understandably building requirements and funding schemes, and on the implementation of measures foreseen in the future EED and EPBD. The Italian Superbonus 110% demonstrated how clear messages help boosting building renovation and public awareness. ...
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Response to Review of the Construction Products Regulation

12 Jul 2022

Members of EAE, the European Association for External Thermal Insulation Composite Systems (ETICS), have recognized the publication the European Commission’s proposal for a revised Construction Products Regulation (CPR), dated 30 March 2022. We are pleased to contribute our views in the feedback period and stand ready for questions and to contribute to further improvements. EAE members appreciate the initiative of the European Commission to first overcome the problems with the current Construction Products Regulation (CPR) and second to align it with other important European policy initiatives - aiming to achieve the ambitions of the Green Deal. EAE members welcome in particular: - Establishing and strengthening a Single Market for construction products by providing a level playing field for all economic operators and removing barriers to trade – provided Member States will really refrain from additional requirements, which today is not always the case. - Fostering aspects of sustainability and circularity and applying the same regulatory framework conditions for reuse or recycled products as for new products. - Supporting European standardisation and CE marking as key elements for harmonization and making harmonized technical specifications binding for both economic operators and regulators in Member States. - Supporting the digitalization of the construction sector, in particular by paving the way to making available product information only by electronic means. - Strengthening the role of market surveillance authorities. - Clarification of procedures for European assessment documents, especially the explicit possibility for groups of manufacturers or associations to initiate an EAD request and involvement in its elaboration as previously recommended by EAE. - Clarification of the role and procedures of product contact points for construction. - Clarifying and simplifying procedures for economic operators doing business in several European countries and thus the bureaucratic and financial burdens. Analyzing the proposal EAE members identified some aspects of concern or in need of further clarification as listed in our attached document. Additionally, some of our national members reported about translation errors and incompatibility with the vocabulary of the current CPR in their national versions and would have appreciated a longer feedback period due to the complexity and relevance of this legislative proposal. Furthermore, the readability should be further improved to ensure that users easily understand the regulation. Generally, the proposal for a new CPR appears quite complex. It should be reviewed, which content is needed and creates added value to minimize the burden for the entire value chain. EAE members stand ready to contribute to further discussions and elaboration of this important piece of legislation.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The European Association for External Thermal Composite Systems (EAE) strongly supports the European Commission’s Green Deal to make Europe the first net-carbon neutral continent by 2050. As the Commission pointed out in the inception impact assessment on the revision of the Energy Performance of Buildings Directive (EPBD) 2010/31/EU, the construction sector must play a significant role as it stands for 40% of Europe’s total energy consumption and 36% of energy-related greenhouse gas emissions. EAE members stand ready to play their role making Europe’s buildings highly energy-efficient by contributing to the thermal insulation of buildings’ envelopes. In response to the Commission’s ropadmap for a EPBD revision we encourage EU and Member States to align it with the higher ambitions as set out in the Climate Target Plan 2030 and with other horizontal legislation. In view of the challenges we strongly believe that only consolidated action will enable achieving both the 2030 targets and the objectives for 2050. Please, find the detailed EAE position paper attached.
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Response to Review of the Construction Products Regulation

19 Aug 2020

The European Association for External Thermal Insulation Composite Systems (EAE) welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products. We encourage the European Commission, Member States, and stakeholders to take consolidated action to overcome the obstacles and uncertainties observed in recent years. This can only be achieved in a constructive and open-minded dialogue between all parties concerned. EAE strongly believes that a well-functioning single market for construction products providing a level playing field for all manufacturers will help bringing Europe’s economies back on a sustainable growth path and to achieve the objectives of the European Green Deal. In this regard EAE broadly agrees to the identification of current problems in the Commission’s inception impact assessment. Detailed feedback on the different options described under “B. Objectives and Policy options” we will consider separately and reply via the public consultation closing 31st August 2020. However, we would like to take the opportunity to already highlight some aspects that are relevant from our perspective and need to be considered in the ongoing process. Please find these aspects in the attached file.
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Response to Implementation modalities of the smart readiness indicator for buildings

16 Jul 2020

The European Association for External Thermal Insulation Composite Systems (EAE) thanks for the opportunity to comment on the European Commission’s draft implementing regulation on the arrangements for the rollout scheme of the ‘smart’ buildings - smart readiness indicator. Neither building insulation nor smart technologies or the use of renewable energy sources alone will lift the huge potential of GHG savings in the building sector. Considering this, the EAE has concerns that the rollout of the SRI as stand-alone certificate might lead to confusion at least among private investors if not communicated carefully. One building might have a mandatory energy performance certificate (EPC), a voluntary environmental certificate and in the future a voluntary SRI certificate. Interpretation of the different approaches and the different content might be well-understood by experts. However, many building owners might be confused and tend to draw misleading conclusions. A more holistic approach should be considered. Passive solutions to reduce the energy demand (efficiency first) in combination with flexible and renewable solutions would create best results on a building level.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

The European Association for External Thermal Insulation Composite Systems (EAE) welcomes the European Commission’s initiative for a new, more ambitious strategy to better adapt Europe’s society and economy to climate change. We encourage the European Commission to go ahead with its strategy to “build-back-better” or to “recover better” after the Covid-19 pandemic. Bringing Europe’s economies back on the growth path must not leave the long-term objectives of a carbon neutral EU in 2050 behind. In the contrary: recent studies and communications demonstrate that a “green recovery” can combine economic growth, job creation, climate protection, and improved health - without leaving anyone behind. Together with the findings of the Eurobarometer that a broad majority of citizens agree that adapting to the impacts of climate change can have positive effects for people, the EAE asks the European Commission and Member States to use this momentum for launching ambitious EU and national recovery packages that allow for prevention of and adaption to climate change. For us highest priority should be on prevention, meaning to limit the impacts of climate change as far as possible. Investing in this prevention would be the most sustainable investment and the best insurance. Reducing CO2 emissions will be key to achieve the ambitious 2050 objectives. The huge aging building stock (around 200 million buildings) offers a great leverage as it stands alone for nearly 40% of Europe’s CO2 emissions. Accelerating the renovation rate offers a key tool - not only in the fight against climate change. Highly energy efficient buildings reduce energy consumption, reduce CO2 emissions levels, bring benefits in different socio-economic dimensions (such as economic growth, job creation, health, well-being, and productivity). Taking the efficiency-first principle seriously will therefore contribute to limit the negative impacts of climate change as described in the inception impact assessment (e. g. extreme weather conditions, heat waves, storms, floods). Considering the calculated annual losses of at least 170€billion or 1,36% of GDP in case the EU economy is faced with a global warming of 3°C, we strongly believe that investing this amount of money in preventive measures finally pays off – especially considering our responsibility for future generations. Moreover, in view of the economic recovery latest findings state that investing 1 million€ in energy renovation crates 18 jobs in the EU economy at average. Reflecting the current situation focus should be on strengthening the implementation and market uptake of already existing solutions to achieve immediate effects. Renovation Europe’s call for a “Renovation Fund for All Europeans”, signed by 125 supporters from across Europe, aims to facilitate such immediate action. The members of the European Association for External Thermal Insulation Composite Systems (EAE) stand ready to support the European institutions and Member States. Through exchange with our partner associations in Canada, China, Japan, and the United States we might also support EU’s respective initiatives on a global level.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The European Association for External Thermal Insulation Composite Systems (EAE) welcomes the European Commission’s proposal for a Renovation Wave. Accelerating the renovation rate is a key tool not only in the fight against climate change, it will in addition deliver major benefits for people, their quality of life, and our economy. Considering the current economic situation across Europe after the Covid-19 crisis the Renovation Wave offers a huge leverage to accelerate the recovery as it addresses European industries and secures local employment. The full potential of the building stock (around 200 million buildings) can only be addressed by the European Green Deal if it is well-designed and ambitious. Highly energy efficient buildings reduce energy consumption, reduce CO2 emissions levels, bring benefits in different socio-economic dimensions (e.g. economic growth, job creation, health, well-being, and productivity). We note the Roadmap’s holistic approach in listing the barriers that have been hindering investments in energy renovation of buildings. We believe that beyond their further analysis, a process of ‘mix & match’ among best practices and successful initiatives at Member State-level, is what is missing. Identifying the “success factors” rather than just “pull factors” should be analysed and replicated. This would support the creation of stronger data which will lessen information barriers by creating awareness within an ever-increasing pool of actors. To achieve this, it seems clear that better communication between Member States and the EU Institutions is required. The initiative must be more strategic, as the need to mastermind an economic recovery in the months ahead gives us more motivation than ever to ambitiously and enthusiastically address energy waste in our building stock. Putting the energy-efficiency-first principle ahead will ease the way to shift to renewables and plus-energy buildings/areas through reduced energy demand on the way to achieving a carbon neutral society by 2050. The members of the European Association for External Thermal Insulation Composite Systems (EAE) are ready to support the European institutions and Member States.
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