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European Autoclaved Aerated Concrete Association

EAACA

EAACA is a non-profit-making Association.

Lobbying Activity

Response to Review of the Construction Products Regulation

11 Jul 2022

EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe. The organisation was founded in 1988 and has members from 19 countries, operating more than 100 production sites and producing around 18 million cubic metres of AAC annually. The European Autoclaved Aerated Concrete Association (EAACA) acknowledge the release of the long-awaited Commission proposal for a new Construction Products Regulation which aims at solving the implementation issues construction product manufacturers have been facing. EAACA is a Member of the Construction Products Europe and we have provided input into their response. However, we would like to highlight a number of points here; Our feedback is attached.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

16 Mar 2021

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Energy Performance of Buildings Directive and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe. The organisation was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic metres of AAC annually. Firstly, we would like to emphasise that we appreciate and welcome the Commission’s ongoing efforts to increase energy efficiency rates across Europe and especially in buildings. Concerning the proposed potential measures that are outlined in the roadmap, we would like to comment on the following points: • Regarding the roadmap’s outlined potential phased introduction of mandatory minimum energy performance standards for different types of buildings, EAACA supports their introduction, but requests that all other aspects of the building performance requirements are also considered. (See our later comment). It is important that indoor air quality and comfort of the occupiers is considered. With climate change we need to recognise future increases in average temperatures and the buildings ability to control indoor overheating. • We further support the planned update of the framework for Energy Performance Certificates, with inclusion of additional information and more stringent provisions on availability and accessibility of databases. • EAACA believes that the Commission is right in addressing resource efficiency and circularity principles, to reduce whole lifecycle emissions, digitalisation, climate resilience and health and environmental standards. Increasing standards of resource efficiency in the construction sector is essential and emissions should be looked at holistically over the entire life cycle of products. It is important that in any future amendment, the legislation must remain material neutral. EAACA also believes that the revision of the energy efficiency performance measures for buildings should be coherent. In this regard, EAACA would like to highlight, that the Energy Efficiency Directive (2012/27/EU), which is also currently in review, includes several issues related to the energy efficiency of buildings. EAACA believes that all energy efficiency measures related to construction and buildings should be included in the EPBD to have a coherent policy framework and to decrease administrative burden for our industry. Further, the renovation of buildings can certainly support the enhancement of the energy efficiency of a building. At the same time, any measures included in the EPBD should not lead to unintended consequences. Other essential requirements of the built environment, that impact strongly on the long-term sustainability of dwellings must be considered. This includes for example the durability of a material, fire safety features, or the impact on the interior air quality of buildings. To be clear, the construction materials used while renovating a building should be guaranteed to not hinder or decrease the fire safety standards or indoor air quality. Buildings are not typical consumer goods and therefore require a long-term perspective by policy makers. Renovation is not always the best solution to guarantee the highest living standards for European citizens, given the quality of Europe’s post-War building stock. Revitalisation and new build can allow for buildings to be long-term sustainable, up to European quality standards, and tailored to the needs of the inhabitants.
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Response to Sustainable Products Initiative

12 Nov 2020

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s Sustainable Products Initiative and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe. The organisation was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic metres of AAC annually. Firstly, we would like to stress that we appreciate and commend the Commission’s ongoing efforts to enhance the sustainability of products on European markets. Overall, we support the aims of reducing the overall life-cycle climate and environmental footprint of the products placed on the EU market, achieving longer product lifetimes through more durable and reparable products, increasing circular material use rate, reducing waste and achieving higher recycling rates. For the construction sector in particular, we would however like to point out some specific comments regarding a number of issues. First and most important, while we agree with the objective of the Sustainable Products Initiative to establish overarching product sustainability principles, we believe that these must be material neutral unless it affects health and safety. Specific performance targets rather than prescriptive ones should be set, as this stifles innovation. When considering the sustainability of construction products, also other essential requirements of the built environment, that impact strongly on the long-term sustainability of dwellings must be considered. This includes for example the durability of a material, fire safety features, or the impact on the interior air quality of buildings. Similarly, regarding the possibility of new EU rules to be established for setting mandatory minimum sustainability requirements on public procurement of products, we believe that all aspects of the design requirements must be considered. Further we agree that, where this is possible, producers should be encouraged to provide more circular products and intervening before products can become waste. While we also agree that there should be a higher emphasis on Life Cycle Analysis of products in the construction sector, we do think that this should for example be done through a greater use of Environmental Product Declarations based on the revised EN 15804 from cradle to grave, rather than an ecolabel or other environmental passport, in order to avoid further complications and burden for construction stakeholders. Regarding measures to ban the destruction of unsold durable goods we believe that these would seem sensible and are in favour of reworking these if possible. Finally, we can see advantages in improved information flows and would be happy to support the Commission in realising the full potential of digitalisation of product information in the construction sector. We would like to emphasise again that we support the Commission in its endeavours to make products on European markets more sustainable. At the same time, we would like to highlight that we believe that the review of the eco-design directive and other additional legislative measures should not put any additional burden to the product manufacturers, who are especially during the current crisis already under increased pressure. We thank the Commission in advance for its consideration and efforts and would be glad to further support this process where needed.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The European Autoclaved Aerated Concrete Association (EAACA) was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic meter of autoclaved aerated concrete (AAC) annually. EAACA welcomes the European Commission's Green Deal and its increased ambitions to tackle climate change, as well as the Commission’s roadmap on the 2030 Climate Target Plan and the necessary according adjustments to the 2018 Renewable Energy Directive (REDII). We would like to thank the Commission for the opportunity to provide our views on this roadmap, as we recognise the need for an upward review of the minimum 32% renewable energy target to boost the installation of renewable energy appliances throughout Europe. That being said, we would like to stress that this review should be closely linked to the upcoming Renovation Wave – an initiative that is set to increase the use of renewable energy specifically in buildings. The importance of this interlink was already underlined as part of the recently published EU Energy System Integration Strategy. We consider that the deployment of more renewables in buildings as part of the Renovation Wave and the full integration of buildings in the energy system of tomorrow will pave the way for a sustainable and clean European economy. We thus believe that this will be a crucial step for enhancing the energy efficiency levels of the European building stock as a whole and therefore welcome this initiative. At EAACA, we promote the integration of on-site renewables and a focus on net-zero energy districts over single building units to ensure the complementarity of energy performance measures within connected urban spaces. Taking a district-level view allows us to facilitate the integration of buildings into the energy system. Crucial for energy- and space-efficiency in cities, will (next to more solar rooftop panels on buildings as desired by the Commission) also be the inclusion of buildings in the electric vehicle-charging infrastructure. Further, focusing on a holistic approach to achieving net zero houses over passive housing incentivises the integration of on-site renewables within the building envelope and creates the most cost-optimal solutions. We look forward to learn more about the Commission’s plans to review the REDII Directive in the public consultation process and are glad to further support this initiative where needed.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s ambitions to reduce greenhouse gas emissions and the associated initiative to review the Energy Efficiency Directive. EAACA was founded in 1988 and has members from 18 countries, which operate more than 100 production sites and produce around 16 million cubic meter of autoclaved aerated concrete (AAC) annually. As EAACA, we would like to emphasise that we welcome the Commission’s ongoing efforts to increase energy efficiency rates across Europe and especially in buildings. Regarding a review of the Energy Efficiency Directive and the associated roadmap and inception impact assessment, we would like to highlight the following points. We agree that efficient use of energy is key to achieving the European Green Deal’s objectives and therefore appreciate a possible review of the EED and any other relevant energy legislation is envisaged. We also expect and fully welcome that this will be included in the highly anticipated Renovation Wave, which will launch further initiatives to enhance energy efficiency levels of the European building stock. Regarding the evaluation section of the roadmap, we are looking forward to learn more about the achievements of the EED since its introduction in 2012. We would like to highlight that in construction, our business was mainly impacted through the energy efficiency provisions of the Energy Performance of Buildings Directive (EPBD). This has successfully driven changes in national legislation for lower energy efficiency spending in buildings, which were necessary and we would like to commend the Commission for. At the same time - as the roadmap also makes reference to the Covid-19 downturn of the economy - we would like to highlight that our industry has been hard hit by the crisis and that we are still recovering from its consequences. We therefore strongly recommend that a review of the EED and the accompanied measures should not bring additional costs and burdens for product manufacturers, as this will endanger the recovery of the construction sector. We believe that construction industry experts should be fully involved during the review of any issues in the EED that relate to the energy efficiency of buildings, in order to avoid placing unnecessary burden on our industry. The same goes for the introduction of new measures with the launch of the Renovation Wave initiative in Autumn. We would further like to comment on the link between the EED review to the Circular Economy Action Plan, which we fully support and believe is crucial to the future of the construction industry. A key measure to increase the energy efficiency of buildings across their life cycle is the responsible re-use and recycling of construction materials. AAC for instance is a material that is 100% recyclable and made from resources that are used carefully and effectively. The sustainable management of materials hereby mandates an ambitious approach to strengthen resource efficiency by reducing the input of raw materials for crucial energy savings over buildings life cycle. Finally, we believe that greater energy efficiency efforts can indeed likely lead to positive direct impacts for employment in sectors such as construction. However, this requires long-term planning to ensure that the necessary skills are readily available and that the competitiveness of the European construction industry is safeguarded. We need to increase investments to upskill our workforce and significant support to ensure the competitiveness of our industry, especially during Covid-19 economic downtrun. We thank the Commission in advance for its consideration and efforts and would be glad to further support this process where needed.
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Response to Review of the Construction Products Regulation

14 Aug 2020

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Construction Products Regulation and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic metres of autoclaved aerated concrete (AAC) annually. Firstly, we would like to stress that we appreciate and commend the Commission’s ongoing efforts to coordinate and standardise the processes around the development and distribution of construction products. Following the publication of the various CPR revision options by the European Commission, EAACA would like to emphasise the following points: We agree that there is insufficient market surveillance, confusion between national and CE marking, duplication in CE marking and DoPs and that the process of standardization cold be improved. Many of the issues under the current CPR can be addressed with minimal changes to the legal text of the CPR, or even with just guidance and clarifications to the current text. We believe that most of these issues can be dealt with under Option A. In any development of standards, the industry experts should be fully involved for each product family. CEN should remain in control of this and there is no need for other organizations to take over this route. CEN are organized in an effective way and we do not believe that harmonised CEN standards are of insufficient quality. CEN ensures the technical quality of standards through the necessary participation of all interested parties. In any standardisation process, any request should avoid be limited to a number of key parts namely; intended use, assessment and verification of constancy of performance, and listing the essential characteristics for each product. The CPR review should be used to introduce one harmonised method for determining and communicating the environmental impacts of construction products. This can be achieved by using the established Environmental Product Declarations according to EN 15804, which would avoid unnecessary cost and work. The recent amendment of EN 15804 to the product environmental footprint (PEF) methodology provides a suitable basis for going forward. We believe that there should be a harmonised method to determine and communicate the environmental impacts (LCA) of construction products. This can be achieved using existing methods of EPDs according to EN 15804. We would like to emphasise that any changes to the CPR should not require additional burden to the product manufacturers. We thank the Commission in advance for its consideration and efforts and would be glad to further support this process where needed.
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