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European Calcium Silicate Producers Association

ECSPA

ECSPA is a non-profit-making Association.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

see attached input
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Response to Revision of the Standardisation Regulation

21 Jul 2025

Harmonised European standards have been the backbone for placing our products on the EU Single Market since 20 years. The process has been slow and could be improved, but unlike other areas, the construction sector is and will remain very much ruled by national and regional laws, regulations and administrative provisions, unless Member States volunteer to align. For our construction products, the development of common European standards began in the 1980, long before the Construction Product Directive (89/106/EEC) was adopted and Mandate M/116 for developing harmonised standards for our products was issued. It followed a bottom-up approach where technical standards were adopted in a consensual, democratic, technically and scientifically driven process involving all stakeholders, big and small, and including regulators, with a view to providing an interconnected set of technical standards that allowed designing buildings according to the applicable requirement and specifying appropriate products. Consequently, given the different traditions and experiences, the process of developing the first set of harmonised construction product and supporting test standards took time. The first set of harmonised product standards were ultimately achieved by imposing predominantly a performance-based approach at the expense of the best practice and state of the art approaches that were well-established in many Member States. However, while an approximation of the technical foundation was achieved, the aim of the Construction Product Directive (89/106/EEC) was to approximate the laws, regulations and administrative provisions of the Member States. This goal was not achieved due to the subsidiarity and a lack of willingness to adapt. The Construction Product Regulation (EU) 305/2011 therefore no longer aimed at approximating Member States laws, regulations, etc., but on providing a common technical language for placing construction products on the Single Market. However, even this goal was never fully achieved, partly because of a lack of transparency and willingness of some Member States to engage in the process of notifying requirements as a condition for developing and completing an exhaustive common technical language. With the new CPR (EU) 2024/3110 and the revision of the CPR Aquis, hopes are high that this common technical language may finally be achieved. However, the way to achieving it is by including any performance information requirement claimed by any Member State in the respective Standardisation Request, without allowing the Technical Committee (TC) to question it. The role of technical experts in the TCs has thereby deteriorated to becoming fulfilment agents, subordinating their expertise to the strict conditions and requirements specified in the Standardisation Request by the Commission and the Member States. What was and in other areas still is a bottom-up approach has become a top-down approach for our standards. To deliver to the objectives of the CPR fast under the given circumstances: - Member States need to engage to ensure that the Standardisation Request are complete and need to engage in the standardisation process, to ensure the deliverables meet their requirements and understand necessary compromises. - The Commission needs to provide the financial means for the TCs to be managed professionally and to ensure that assessment methods are reproduceable and repeatable. The industry already bears the costs for delegating experts and supportive research and it can no longer be burdened with costs for the TC secretariats. - SMEs in our and other sectors have deliberately chosen and delegated the representation of their interest to their national and European associations, who ensure that information is shared with, and feedback is collected from them. Associations like ours must be recognised as the legitimate representatives of SMEs in standardisation and be eligible to financial support by the Commission.
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Response to Permanent storage of EU ETS emissions through carbon capture and utilisation

16 Jul 2024

ECSPA appreciates the opportunity to provide feedback on the draft Delegated Regulation supplementing Directive 2003/87/EC as regards the requirements for considering that greenhouse gases have become permanently chemically bound in a product. ECSPA particularly welcomes that the draft Delegated Regulation recognises that carbonation of minerals is a chemical process that permanently binds carbon in a product. We are however surprised that while the carbonation process is recognised in general, Annex I limits its utilisation for permanently storing carbon emission to a specific list of products, excluding by omission lime-based products such as calcium silicate masonry units and similar products. As it is being proposed, crushed calcium silicate masonry units (e.g. from production and/or construction waste) would fall under carbonated aggregates used unbound or bound in mineral based construction products and be considered, whereas the same material as an original product, would not. We therefore urge that the Delegated Regulation is amended to facilitate the binding of greenhouse gas emission in mineral carbonation in general, rather than to limiting it to a short list of specifically named products or to amend said list to include calcium silicate masonry units and similar products.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur)

4 Sept 2023 · RED III

Response to Review of the Construction Products Regulation

12 Jul 2022

A clear, lean and reliable legal framework is an essential prerequisite for an effective and economic functioning of the internal market for construction products as well as to contributing to affordably, green and digital objectives The persisting problems with the citation of CEN standard deliverables in the EU Official journal as well as with the revision of Mandates/Standardisation Mandates has put the construction products sector in a difficult situation. These ongoing difficulties are hindering the supply of products and product information as demanded by the market are therefore damaging the trust in and the support of European internal market for construction products among all stakeholders. These difficulties are also a reason why national and voluntary approaches continue playing an important and increasing role. ECSPA continues supporting and believing in the benefits of the single market for construct products and is fully committed to the objectives of the green and digital transition. We therefore welcome that the European Commission has presented a proposal for a new Construction Product Regulation, initiating the legislative process that is expected to offer solutions for the long-known issues and enable the green and digital transition of the construction sector as a whole. We look forward to engaging and contributing in a constructive manner to improving the proposal. We welcome that the European Commission’s proposal inter alia • maintains the concept of the “common technical langue” for which harmonised standards shall continue playing a key role • addresses sustainability and circularity objectives in construction • seeks to strengthen the single market for construction products, by obliging Member States to respect the harmonised zone • respects at the same time the competences of Member States by foreseeing a procedure to implement requirements that are not yet covered by the harmonised zone • aims at functioning as a “one-stop shop” for legal requirements related to construction products and the related economic operators, by integrating aspects of the ESPR and the GPSR • suggests a procedure aimed at facilitating the timely delivery and citation of CEN deliverables • simplifies the CE marking and allows fulfilling information obligations digitally by default • aims at strengthening Market Surveillance • clarifies the procedures to develop EADs/ETAs and limits the overlap of competences In contrast to the positive aspects and intentions that we identify in the proposal, we also identify issues of concern, such as the: • readability, comprehensibility and clarity of the legal text • extensive powers the proposal is giving the European Commission to amend and specify articles • modified scope and modified/new definitions • stepwise implementation of the proposed new Construction Product Regulation • procedure for assessing and adopting CEN standardisation deliverables • exclusion of EADs from the definition of harmonised technical specifications • missing common digital format for the content of the declaration of performance and conformity • common database • administrative burden for economic operators • possibility for Member States to exempt certain products from their territory • exemptions for used and remanufactured products • central complaints portal • random checks as proposed in the new Annex V • unclear reference to environmental product declarations (EPDs) • extensive information and requirements • sensible application of traffic light systems for construction products (see attached feedback document for further elaboration on the issues of concern)
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Response to Commission Communication – "Renovation wave" initiative for the building sector

9 Jun 2020

ECSPA, the European Calcium Silicate Producers Association welcomes the Commission’s initiative to scale up the energy renovation of the building stock. Our industry has been a front runner in providing energy efficient structural system solutions since the 1970s, always up to date and often even ahead of the prevailing standards. Our structural system solutions formed part of the first passive house in 1991 and continue contributing to meeting today’s highest building standards. Considering the building stock’s impact on energy consumption and GHG emissions, it is of greatest importance to urgently lift its energy efficiency to today’s standards and to scale up the renovation rate in order to achieve the 2030/2050 climate goals. To achieve a carbon neutral mobility and industry by 2050 we cannot afford wasting energy in buildings where today’s state of the building design and solutions already demonstrate energy wastage can be prevented. However, it is worth mentioning that buildings do not consume energy per se. Buildings serve different purposes and the energy is consumed by their users and inhabitants in the course of their working and living activities. Unlike other sectors where new products with better performances may contribute to creating consumer demand (irrespective of the products’ location), the building sector typically answers to the specific demands of owners and investors who commission the buildings and thereby to the complex needs and expectations of the buildings users and inhabitants. In some urban regions we continue observing since many years a continuous if not growing demand for living space which cannot be satisfied by renovating the existing building stock. Funding of new, highly efficient buildings in such areas should therefore have the same priority than renovation of the building stock. The roadmap rightly notes that approximately 80 % of today’s building stock will be still be in use 30 year from now, 75% of which is energy inefficient. However, the conclusion from these figures should not only consider climate change but also the demographic change needs. Already today there is a lack of elderly adequate housing creating a financial pressure on social security systems. By 2030 approximately one quarter of the German population is estimated to be 65 years of age or older. Enabling an aging population an autonomous life at home for as long as possible, supported where needed by inhouse care, reduces the cost for social security systems and consequently the finacial burden of future generations, which will also be burdened by the necessary investments envisaged in roadmap for the renovation wave. The older the building stock, the poorer its performances, the lesser it satisfies demands, the greater are the final and technical challenges. In each case it needs therefore to be carefully assessed if the renovation of a poorly performing building is always justified or if – all things, that is all needs considered – its demolition and replacement is not only the better alternative from a social, ecological and economical point of view. We urge the Commission to respect the given complexities by adopting a holistic and sustainable, that is an ecological, social and economical approach for the envisaged renovation wave and its funding.
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