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European Association for External Thermal Insulation Composite Systems

EAE

EAE members share one common goal: we develop the use of well approved External Thermal Insulation Composite Systems (ETICS) both to improve the energy efficiency of new and existing buildings all over Europe.

Lobbying Activity

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

The European Association for External Thermal Insulation Composite Systems (EAE) has been working towards a “culture of sustainability” in the construction sector for more than 10 years now. The members of the EAE include 11 national ETICS associations, six major European supplying materials‘ associations and nine supporting members. The EAE represents enterprises from international operating companies to SME’s. Their common aim is to improve the energy efficiency of the European building stock. Our members have major concerns and reject the proposed classification. A potential labelling will entail strong consumer uncertainty and reservation. This may have significant impact on achieving Europe’s targets on climate action and energy efficiency: TiO2 is used in system components of External Thermal Insulation Composite Systems (ETICS). Our systems are required to contribute to achieving EU’s energy efficiency objectives. To our opinion alternative regulatory options are available which would better address the potential concerns, including EU harmonised health and safety measures. It's not about the substance titanium dioxide, but dust in the workplace. Most Member States have already introduced national dust limits. A European harmonization of these national limits would be useful and has already been initiated by DG Employment. According to our knowledge there is not enough scientific evidence that titanium dioxide poses risk to humans: the proposed classification is based on a single controversial study on rats in 1995 and is therefore very weak. On the other hand extensive epidemiological studies on 24,000 employees in titanium dioxide factories over many decades showed no negative health effects for humans. For rendering systems used as ETICS components there is no equivalent alternative to titanium dioxide, neither in terms of its performance nor its availability on the world market. Also, this rating would have a significant negative impact on the sustainability since no other pigment has similar hiding power and weatherability.
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