OpenLobby.EU
Explore

European Insulation Manufacturers Association

EURIMA

Eurima represents Europe's mineral wool insulation manufacturers, employing over 20,000 people and supporting 300,000 installation jobs.

Lobbying Activity

Insulation manufacturers demand inclusion in Advanced Materials Act

13 Jan 2026
Topic — EU initiative to strengthen research and production capacities for strategic industrial materials.
Message — EURIMA requests that mineral wool be explicitly recognized as an advanced material. They advocate for a material-neutral framework based on functional performance and whole-life sustainability.12
Why — Inclusion would facilitate faster market uptake and secure financial support for industrial electrification.34
Impact — Bio-based material producers may lose competitive advantages if specific material classifications are removed.5
Read full response

Response to Classes for resistance to fire

17 Dec 2025

EURIMA supports the migration of the existing reaction-to-fire and resistance-to-fire performance classes into the new framework. These classes are an essential instrument for Member States when defining pre-accepted and material class based fire-safe design solutions in regulation, thereby enabling cost-efficient construction while maintaining a high level of fire safety. It is therefore vital that the well-established classes under CPR 2011 can continue to be used seamlessly under CPR 2024. The classification of construction products based on their reaction-to-fire performance is a cornerstone of fire safety policy and practice, reflecting the material-related requirements embedded today in the national regulatory provisions of several Member States. However, we would like to highlight two issues: 1. The Euroclass system, on which these delegated acts are built, has proven highly effective in ensuring a harmonized European approach to fire safety while also allowing Member States to regulate fire safety based on national and local requirements. The new CPR system should build on and strengthen this well-functioning system in order to keep a high level of fire safety in all building applications notably facades and roofs. 2. The draft delegated act on reaction to fire introduces dated references to standards, which was not required previously. It needs to be considered that this may create complications when using existing or future downstream test evidence: It still needs to be clarified to what extend and under which exact circumstances previous versions of standards can exceptionally accepted. We remain at your disposal for any further clarification or follow-up regarding the above remarks.
Read full response

Response to Classes for reaction to fire

17 Dec 2025

EURIMA appreciates the European Commissions two draft delegated acts on the establishment of performance classes for reaction to fire and resistance to fire, which help to preserve continuity between Regulation (EU) 305/2011 (CPR-2011) and Regulation (EU) 2024/3110 (CPR-2024). Representing the European mineral wool insulation manufacturers, EURIMA speaks for an industry that plays a key role in delivering the EUs climate and energy-efficiency objectives through fire-safe, high-performance insulation solutions. EURIMAs membership is predominantly European-based, with manufacturing sites and jobs spread across numerous Member States. EURIMA supports the migration of the existing reaction-to-fire and resistance-to-fire performance classes into the new framework. These classes are an essential instrument for Member States when defining pre-accepted and material class based fire-safe design solutions in regulation, thereby enabling cost-efficient construction while maintaining a high level of fire safety. It is therefore vital that the well-established classes under CPR 2011 can continue to be used seamlessly under CPR 2024. The classification of construction products based on their reaction-to-fire performance is a cornerstone of fire safety policy and practice, reflecting the material-related requirements embedded today in the national regulatory provisions of several Member States. However, we would like to highlight two issues: 1. The Euroclass system, on which these delegated acts are built, has proven highly effective in ensuring a harmonized European approach to fire safety while also allowing Member States to regulate fire safety based on national and local requirements. The new CPR system should build on and strengthen this well-functioning system in order to keep a high level of fire safety in all building applications notably facades and roofs. 2. The draft delegated act on reaction to fire introduces dated references to standards, which was not required previously. It needs to be considered that this may create complications when using existing or future downstream test evidence: It still needs to be clarified to what extend and under which exact circumstances previous versions of standards can exceptionally accepted. We remain at your disposal for any further clarification or follow-up regarding the above remarks.
Read full response

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and Glass for Europe and

9 Dec 2025 · Implementation of the Construction Products Regulation (CPR)

Meeting with Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis) and Eurogypsum and Bureau International du Béton Manufacturé

9 Dec 2025 · Implementation of the Construction Products Regulation (CPR)

Insulation manufacturers urge EU to simplify building sustainability rules

5 Dec 2025
Topic — This consultation reviews technical criteria for sustainable financial investments in construction and renovation.
Message — Eurima proposes an 80% limit for primary raw materials and mandatory carbon reporting for all new buildings. They also seek clarity that manufacturing additives should not disqualify products from being labeled sustainable.123
Why — These changes would protect the industry's access to green finance and reduce compliance complexity.45
Impact — Environmental advocates lose if the Taxonomy allows products with high primary material content to be labeled sustainable.6
Read full response

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs), Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

27 Nov 2025 · Participation as speaker at Eurima Management Board

European insulation industry urges harmonised building carbon calculation rules

31 Oct 2025
Topic — The consultation defines a framework for calculating life-cycle greenhouse gas emissions from new buildings.
Message — EURIMA calls for a clear legislative commitment to align calculation scopes and prioritize producer-specific data. They recommend using the full life cycle as the primary performance metric.123
Why — Harmonized standards prevent insulation manufacturers from being penalized by incomplete emission calculations.4
Impact — Fragmented national rules harm investors by increasing regulatory complexity and project costs.5
Read full response

Response to New European Bauhaus

17 Oct 2025

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to provide feedback on the European Commission's Call for Evidence on The New European Bauhaus: Achievements and Future Developments.
Read full response

Insulation manufacturers urge building upgrades to enable heat pumps

9 Oct 2025
Topic — EU strategy to accelerate the decarbonisation of industrial and residential heating.
Message — EURIMA demands that building insulation be the mandatory first step for decarbonising heat. They propose specific checks to ensure buildings can support smaller heat pumps.12
Why — Mandating insulation before heat pump installation would significantly increase demand for association members' products.3
Impact — Grid operators lose investment opportunities because insulation reduces the need for network expansion.4
Read full response

Insulation manufacturers urge building upgrades before EU electrification

9 Oct 2025
Topic — The European Commission is seeking feedback on plans to decarbonize the energy system.
Message — The organization demands that building renovation and insulation become a prerequisite for electrification to manage peak demand. They recommend linking financial support to low-temperature readiness and promoting integrated funding for fabric upgrades.12
Why — Prioritizing building envelopes creates massive demand for mineral wool insulation while lowering factory operational costs.34
Impact — Manufacturers of oversized cooling systems lose as passive insulation reduces the need for active units.5
Read full response

Meeting with Robert Nuij (Head of Unit Energy)

8 Oct 2025 · Exchange on the concept of tripartite contracts for energy efficiency

Insulation manufacturers call for harmonized EU housing construction rules

17 Sept 2025
Topic — The consultation addresses the supply gap and competitiveness of European housing construction.
Message — The association requests harmonized sustainability metrics and faster, digital building permit processes. They also prioritize insulating building envelopes to reduce energy demand and costs.1234
Why — Consistent EU standards would protect their investments and ensure fair competition across markets.5
Impact — National regulators using unique sustainability models risk seeing their systems replaced by EU rules.6
Read full response

Insulation manufacturers urge EU to prioritize energy efficiency targets

17 Sept 2025
Topic — The European Commission is amending the Climate Law to include a 2040 target.
Message — The organization advocates for legally anchoring the Energy Efficiency First principle to ensure long-term predictability for industrial investments. They propose a dedicated 2040 energy efficiency target to guide national building renovation policies. Furthermore, they demand a whole-life carbon approach that recognizes only permanent carbon removals in construction.123
Why — These regulations would secure demand for mineral wool and provide certainty for decarbonization investments.45
Impact — Future generations and industries using temporary carbon storage materials face greater risks and costs.67
Read full response

Insulation industry demands fair state aid for stone wool

5 Sept 2025
Topic — Consultation on updating state aid rules for electricity-intensive industries facing carbon leakage risks.
Message — EURIMA calls for revising Annex I to include stone wool alongside glass wool. This recognition would provide industry certainty and support electrification.12
Why — The revision eliminates competitive distortions and offsets rising indirect electricity costs.34
Impact — Glass wool producers lose their exclusive financial advantage over stone wool competitors.5
Read full response

Insulation industry urges EU to prioritize mineral wool for resilience

4 Sept 2025
Topic — The European Commission is creating a framework to address escalating climate risks.
Message — EURIMA calls for mapping climate risks and integrating building adaptation into current energy directives. They want mineral wool recognized as a priority for fire-safe, resilient construction.12
Why — These measures would establish mineral wool as the primary material for EU-funded renovations.3
Impact — Competitors selling combustible insulation face exclusion as fire safety standards for buildings tighten.4
Read full response

Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and Glass for Europe and Glass Fibre Europe

4 Sept 2025 · Trade policy, trade defence instruments

Response to Revision of the Standardisation Regulation

21 Jul 2025

EURIMA welcomes the European Commission's initiative to revise Regulation (EU) 1025/2012. As the voice of Europes mineral wool insulation industry, we support a strong and effective standardisation system that underpins the Single Market, EU legislation, and sustainability goals. Standardisation is a strategic tool. It harmonises technical language, ensures transparency, and enables common product assessment procedures. In doing so, it supports fair competition and regulatory compliance. The challenge today is to ensure that the system is fit for the future, able to respond effectively to evolving policy objectives, market developments, and technological innovation. At the same time, it must contribute to strengthening Europes strategic autonomy. We recognise the Commissions identified challenges regarding inclusiveness, speed of delivery, and governance. These must be addressed constructively, while preserving the core principles of the European Standardisation System (ESS): stakeholder balance, consensus-based development, technical integrity, and the legal certainty provided by harmonised standards. Our industry remains committed to contributing actively and responsibly to standardisation at both European and national levels. In the context of the construction sector, we consider that the current ESS provides a solid foundation for supporting Europes strategic interests. However, targeted improvements are necessary to clarify procedures, define responsibilities more clearly, and improve coordination among the different actors. This will help avoid unnecessary delays. Further details in the attached position.
Read full response

Insulation manufacturers demand material neutrality in EU bioeconomy strategy

23 Jun 2025
Topic — The consultation seeks views on updating the EU's strategy for a sustainable and competitive bioeconomy.
Message — The organization demands a material-neutral approach where all construction products are evaluated based on objective, scientifically validated performance metrics. They argue the strategy should not overestimate the carbon removal potential of bio-sourced products or create artificial regulatory advantages.12
Why — Ensuring material neutrality prevents mineral wool from being disadvantaged by rules favoring bio-based alternatives.34
Impact — Bio-based material producers lose the specialized regulatory support needed to expand their emerging market share.56
Read full response

Response to European Affordable Housing Plan

4 Jun 2025

EURIMA welcomes the European Commissions initiative to develop the first-ever European Affordable Housing Plan (EAHP) as a key opportunity to align climate and social policy. To make the plan effective, EURIMA highlights five bottlenecks currently hindering the delivery of affordable, sustainable housing, and proposes evidence-based solutions. 1. Imbalance between renovation and new construction: 8595% of todays buildings will still exist in 2050, with over 70% built before energy efficiency standards. Renovating these buildings, especially the worst-performing ones, offers faster, more cost-effective gains than new build. EURIMA calls for prioritising energy-efficient renovation to reduce bills, enhance resilience, and unlock systemic benefits, including 44.2 billion in annual avoided grid costs and 312 billion in total savings versus alternatives. 2. Rising housing and energy costs: Low-income households are disproportionately affected by volatile energy prices and inefficient buildings. EURIMA advocates for sustainable, high-performance construction materials, which reduce long-term costs without increasing upfront investment. To ensure sustainability drives affordability, the EAHP should mainstream the Level(s) framework as the EUs sustainability tool, and integrate Life Cycle Costing (LCC) in housing policy. Training and capacity-building should support implementation, especially for municipalities and SMEs. 3. Fragmented, bureaucratic and contratictory regulation: Overlapping permitting and environmental rules slow projects and deter investment. EURIMA calls for simplifying permitting processes, aligning major EU legislation (e.g., EPBD, EED, CPR, RED), and preventing new compliance burdens. Specifically, EURIMA urges the Commission to accept existing Environmental Product Declarations (EPDs) under EN 15804 during CPR transition, and to exempt construction products from reuse obligations in the Packaging and Packaging Waste Regulation (PPWR, Art. 29), where these risk economic inefficiency and limited environmental benefit. 4. Financing gaps and accessibility: Despite available EU funds, access remains difficult. EURIMA proposes extending the Recovery and Resilience Facility (RRF) to 2028, ringfencing MFF and Cohesion Funds, and frontloading the Social Climate Fund (SCF) to support low-income renovations. The Commission should also avoid 100% financed schemes and instead encourage co-investment models. One-stop-shops must be expanded and remain neutral, while instruments like InvestEU and ELENA should support technical assistance. Private finance should be unlocked via loan guarantees, renovation loans, and performance-based mortgage standards. 5. Skills and workforce shortages: Labour gaps threaten the scale, speed, and quality of renovation. EURIMA calls on Member States to dedicate a portion of housing funds to certified training in energy renovation, building fabric, and the Level(s) framework. EAHP workforce efforts should align with the Green Deal Industrial Plan and Net-Zero Industry Act. Public-private partnerships can strengthen delivery capacity, especially among SMEs. The EAHP should serve as a catalyst for socially just and climate-resilient transformation. By addressing regulatory, financial, and skills-related bottlenecks, and placing renovation and energy efficiency at its core, the plan can ensure housing is affordable to build, affordable to live in, and fit for the future. EURIMA and its members stand ready to support this vision. Please see attached the detailed version of EURIMA's feedback, which inlcudes further suggestions, elaborations and supporting references.
Read full response

Meeting with Rosalinde Van Der Vlies (Director Energy) and

3 Jun 2025 · The role of the insulation manufacturing industry in the wide energy efficiency and competitiveness agenda.

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

26 May 2025 · New European Bauhaus and the upcoming Circular Economy Act.

Insulation industry urges EU to prioritize building fabric improvements

7 May 2025
Topic — The Commission is revising the methodology for calculating cost-optimal energy performance in buildings.
Message — The association wants 'emission performance' anchored to annual savings to prevent electrification bias. They also propose a 50-year calculation period to capture long-term insulation benefits.12
Why — Proposed changes would shift focus from short-term equipment to long-term insulation products.3
Impact — The renewable energy sector may lose subsidies if grid electricity is not considered carbon-free.4
Read full response

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

28 Apr 2025 · Housing and energy performance of buildings

Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

In light of the EUs commitment to strengthening European competitiveness, while maintaining its leading role in sustainable innovation and climate neutrality, Eurima the European Insulation Manufacturers Association urges the European Commission to use all available legislative tools, including the Net-Zero Industry Act (NZIA), to create the necessary framework that truly enables all European industry, including those that provide proven, locally manufactured, and readily available net-zero solutions. The NZIA should acknowledge the essential role of energy-efficient building technologies, such as high performing insulation materials, in Europes industrial and climate strategy. Reducing energy use reduces costs and this, in turn, improves competitiveness. As highlighted in the recently published Competitiveness Compass, energy efficiency is a key driver of the EU economys competitive edge. However, this priority is not consistently reflected across all relevant initiatives something that must be addressed without delay. The European Union remains a net importer of CO, which undermines both independence and competitiveness. If this does not change, Europe will struggle to maintain a strong industrial base. This delegated act presents an opportunity to reinforce the Energy Efficiency first principle and send a strong signal to manufacturers of proven solutions, such as mineral wool insulation. This is necessary to strengthen Europes energy efficiency manufacturing base an enabling sector that is essential for reducing energy demand and achieving climate neutrality. Buildings account for 40% of energy consumption and 36% of CO emissions in the EU. Without targeted support for energy-efficient building systems and equipment, the sectors potential for emission reductions will remain untapped. As electrification increases, so does the demand for clean energy, which puts pressure on electricity grids and drives up costs for citizens and businesses. Reports such as the Peak Demand Study show that energy-efficient buildings, through renovation and optimised construction, help to reduce pressure on the grid, lower the cost of infrastructure investment and stabilise energy prices in EU Member States. In line with the objective of the Clean Industrial Deal the NZIA is an important tool to incentivise the production and use of energy efficient building systems and equipment. In line with the methodology outlined in the delegated act and the staff working document defining final products and primarily used components as essential, specific, and commercially available, with the appropriate level of detail and technological developments, Eurima proposes the following additions to the Annex: Under category "Energy system-related energy efficiency technologies" and the sub-category "Other energy system-related energy efficiency technologies" add the final product "Energy-efficient building systems and equipment " and the primary used component "High-performance building insulation materials".
Read full response

Insulation manufacturers demand unified EU rules for construction sector

31 Jan 2025
Topic — A consultation on strengthening the EU single market to improve global competitiveness.
Message — The group requests a uniform application of construction rules to end market fragmentation. They advocate for shared standards to measure carbon impacts and strict EU-wide bans on landfilling recyclable waste.123
Why — Unified regulations would lower administrative costs and prevent national policies from disadvantaging their products.4
Impact — Citizens and the housing market face higher prices if confusing national regulations persist.5
Read full response

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and

28 Jan 2025 · Exchange of views on policies for the construction industry including the Implementation of the Construction Product Regulation, the Affordable Housing Plan, the Clean Industrial Deal, and the Circular Economy Act.

Meeting with Yvon Slingenberg (Director Climate Action)

15 Jan 2025 · Eurima's presentation on Peak Demand Study – Insights on Strategic and Cost-Effective Climate Policy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

13 Jan 2025 · Energy performance of buildings

Eurima urges EU to prioritize insulation for energy security

26 Nov 2024
Topic — Evaluation of the European Union's energy security legislative framework and architecture.
Message — Eurima calls for prioritizing building renovations and energy efficiency within the EU’s energy security framework. They recommend mandatory renovation targets for all buildings and subsidies for insulation audits.12
Why — The proposal would boost demand for insulation products and ensure stable market conditions.34
Impact — Fossil fuel suppliers would face a sharp decline in demand for heating fuels.567
Read full response

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to provide feedback on the European Commission's guidance on applying the 'do no significant harm' principle to the Social Climate Fund. Kindly find our feedback to this initiative attached.
Read full response

Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to provide feedback on the European Commission's upcoming report 'Energy efficiency - assessing the level of EU & national funding'.
Read full response

Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to provide feedback on the European Commission's upcoming report assessing the state of public funding and the capacity of EU countries to increase the uptake of private investment in energy efficiency.
Read full response

Insulation industry urges confidentiality in climate neutrality plans

1 Sept 2023
Topic — This consultation establishes requirements for climate-neutrality plans under the revised Emissions Trading System.
Message — Eurima requests that climate-neutrality plans remain confidential to protect strategic factory-level data from public disclosure. They advocate for adaptable long-term strategies that reflect industrial investment cycles rather than detailed requirements. Finally, they call for consistent terminology across different EU regulations to avoid confusion.123
Why — This would protect business-sensitive information and reduce the risk of revealing competitive strategies.45
Impact — Restricted public access prevents citizens and environmental groups from monitoring corporate decarbonization progress.6
Read full response

Eurima urges inclusion of energy efficiency in Net-Zero Act

27 Jun 2023
Topic — European legislation proposed to scale up the manufacturing of clean energy technologies.
Message — The organization calls for including energy efficiency products like mineral wool in the definition of strategic technologies. They also advocate for faster permitting and a pan-European funding system to support industrial decarbonization.123
Why — The association would secure faster operational approvals and access to new subsidies.45
Impact — Previously prioritized technology sectors may lose their exclusive status and administrative advantages.6
Read full response

Insulation industry urges EU to prioritize building decarbonization targets

23 Jun 2023
Topic — The European Commission is establishing a climate target for the year 2040.
Message — Eurima requests a binding energy efficiency sub-target and increased funding for industrial transitions. They advocate for prioritizing the building sector to address easily achievable carbon reductions.12
Why — Higher efficiency targets would drive demand for insulation by mandating faster building renovations.3
Impact — Infrastructure developers may lose out on massive investment projects as efficiency reduces grid demand.4
Read full response

EURIMA: Pair heat pump rollout with ambitious building renovation

26 May 2023
Topic — A European Commission strategy to accelerate heat pump deployment and building decarbonisation.
Message — EURIMA insists that heat pump deployment must be accompanied by equally ambitious energy efficiency measures. They argue for improving building envelopes to manage peak electricity demand and ensure consumer affordability.12
Why — Mandatory building renovations would create sustained demand for mineral wool insulation products.3
Impact — Low-income families risk higher energy bills if heat pumps enter uninsulated homes.45
Read full response

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Please find Eurima's position on new product priorities for Ecodesign for Sustainable Products attached.
Read full response

Eurima urges realistic raw material targets for building insulation

3 May 2023
Topic — EU consultation on establishing sustainability criteria for circular economy and pollution activities.
Message — Eurima requests product-specific requirements instead of combined material totals to reflect unique industry challenges. They propose an 85% primary raw material threshold due to limited access to secondary waste. The group also suggests a dynamic target-setting approach based on regular market reassessments.123
Why — Adjusted thresholds would help manufacturers maintain compliance despite persistent external barriers to circularity.4
Impact — Environmental groups lose when inadequate national sorting schemes prevent the effective recycling of demolition waste.5
Read full response

Eurima urges permanent storage focus in carbon removal certification

23 Mar 2023
Topic — European Commission proposal for a regulatory framework certifying sustainable carbon removals.
Message — Eurima requests that the EU prioritise permanent storage and use standard life cycle assessment methodologies. They believe certification must require proof of ecological management to prevent market distortions.12
Why — This ensures mineral wool producers avoid competitive disadvantages against materials claiming temporary carbon storage.3
Impact — Bio-based material producers lose the advantage of accounting methods that favor early-life carbon sequestration.4
Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

13 Mar 2023 · Eurima's climate neutrality roadmap

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Aluminium AISBL and

20 Oct 2022 · circular economy and construction sector

Response to Review of the Construction Products Regulation

8 Jul 2022

Please find attached the submission by the European Insulation Manufacturers Association (Eurima).
Read full response

Insulation manufacturers urge separate accounting for carbon removals

2 May 2022
Topic — The EU is establishing a regulatory framework to certify and monitor sustainable carbon removals.
Message — Eurima requests that carbon removals be accounted for separately to ensure priority remains on reducing emissions. They support using established European standards for life cycle assessments instead of simplified national models.12
Why — This prevents competitors from using skewed carbon storage accounting to hide their total environmental impacts.34
Impact — Future generations lose out when emissions and environmental impacts are shifted into the future.5
Read full response

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Please find attached the Eurima contribution to the consultation.
Read full response

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Response to Revision of the Energy Tax Directive

20 Oct 2021

EURIMA welcomes the opportunity to provide feedback on the European Commission's proposal to revise the Energy Taxation Directive. Please consult the attached document to view our contribution.
Read full response

Response to Updating the EU Emissions Trading System

15 Oct 2021

Please consult the attached document to view EURIMA’s response to the European Commission’s proposal to extend the EU ETS to heating fuels for buildings.
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

15 Oct 2021

EURIMA welcomes the opportunity to provide feedback on the European Commission's proposal to revise the Energy Efficiency Directive. Please consult the attached document to view our contribution.
Read full response

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager)

28 Sept 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy

Response to Standardisation Strategy

23 Jul 2021

Eurima welcomes the intention of the European Commission to improve the European Standardisation System (ESS) to strengthen the single market. Standardisation is indeed a highly strategic activity as it ensures harmonization of the technical language, transparency and the use of common procedures to assess the products placed on the single market leading to fair competition among manufacturers. Today’s challenge is to ensure that the system is future-proof ready to answer the regulatory and market needs in terms of quality, fairness, speed of delivery and innovation. With regards to the construction sector, we believe that the current ESS fits for purpose to support European strategic interests. However, some adjustments would be needed to clarify some procedures and responsibilities and guide the different organizations involved thus avoiding the current standstills. Here, we mean in particular that: - There should be a reliable mechanism at CEN level to promote a consensus-based approach. We suggest putting in place robust rules-of-procedure, including clear structure and governance by CEN, as well as increased guidance by the European Commission, based on clear and broadly supported standardisation requests. - To improve overall understanding and compliance, CEN should offer support and training to convenors and secretaries of the different Technical Committees and Working Groups. The increased use of web-based meeting platforms and related digital solutions can help the standardisation process. - The strategic involvement of the European Commission and/or HAS consultants throughout the drafting process can support the improved governance and implementation of standardisation. Regular communication and exchange are also needed with CEN, we therefore welcome the creation of the joint task force between the Commission and the European standardization organizations. - The technical committees in CEN should continue to develop assessment methods for essential characteristics. Allowing one unique method per EU characteristic is the only way to safeguard common technical language. - To anticipate and define standardization priorities, Member states must commit by providing the human resources which would share the right regulatory expectations of the country. This is the only way to ensure inclusiveness and exhaustiveness. - It is important to involve all stakeholders from the beginning of the process, especially industry which usually holds the technical expertise. To achieve the new European goals in terms of digitalization and circular economy, here harmonized European standards are not enough. The European commission has an important role to play in the creation of supporting European common databases and/or harmonizing the rules, structure and data quality of these databases. This is essential to ensure reproducibility, transparency and fair competition on the single market. To ensure that EU can leverage and promote global leadership in standards setting, we think that similar agreements such as the Vienna and Frankfurt agreement should be established with other international standardization organizations (such as ASTM, IEC, etc), ensuring if possible, that CEN/CENELEC lead in standard developments for global usage. This would certainly require additional human and financial resources, however necessary to ensure the EU competitiveness in the global market.
Read full response

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the CLP Regulation. Our sector represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH as bio-soluble. Mineral wool fibres manufactured today are exempted under the Note Q to Annex VI to the CLP Regulation. We have a long history of cooperating with EU policy makers to ensure the highest standard of safety of our products. Interface between CLP and other sectoral pieces of legislation Eurima calls on the Commission to find a coherent and consistent approach when further integrating regulatory processes under CLP, REACH and sectoral legislation. We agree that the CLP Regulation should be the central piece of legislation to initiate hazard assessments of substance involving the RAC at ECHA. Sectoral pieces of legislation are the most appropriate framework to then inform specific risk assessment based on exposure and uses (e.g. waste classification, the CAD for workers exposure, REACH for consumer articles). It is important that risk assessment continues to take into account exposure and uses in an appropriate manner. We believe sectoral legislation and the committees set under it are the best place to assess risk. Introduction of new hazard categories Eurima takes notes of the proposal to classify ‘complex substances’ and reminds the Commission that ad-hoc discussions on multi-constituent substances must follow legal definitions under the REACH Regulation and involve relevant actors of the supply chain to find adjustments that are fit for purpose. Eurima would welcome more clarity on the European Commission’s plan to introduce new categories of hazard classes. Clarity would also be needed as to the possible introduction of information on hazard on the label of products outside of the scope of CLP. Such measures may require a separate impact assessment as they go beyond the scope of the basic act.
Read full response

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the REACH Regulation. Our association represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH and we have a long history of cooperating with EU policy makers to ensure the highest standard of safety of our products. The current revision process presents unique opportunities to make European chemicals regulation work better and deliver more for European citizens in the context of the European Green Deal and the Circular Economy Action Plan. Eurima calls on the Commission to find a coherent and consistent approach when further integrating regulatory processes under CLP, REACH and sectoral legislation on chemicals. We agree that the CLP Regulation should be the central piece of legislation to initiate hazard assessments of substances involving the RAC at ECHA. Sectoral pieces of legislation are the most appropriate framework to then inform specific risk assessment based on exposure and uses (e.g. the CAD for workers exposure, REACH for consumer articles). Circular Economy We underline the importance of efficient cross-committee cooperation and holistic regulatory strategies on substances to attain the goals of the Circular Economy Action Plan. For the construction sector, a clearer regulatory environment where restrictions apply to products containing recycled material and placed on the market and not on the incoming material that will be transformed into valuable secondary raw materials. This would facilitate the circular economy. We believe that recyclability and amount of recycled content in products are better regulated through waste and product legislation (i.e. the Waste Framework Directive and the Construction Products Regulation). To enable more circulation of recycled materials, there should be better interlinks between Waste and Product legislation with REACH and CLP but not additional requirements in chemicals legislation. Increased registration requirements Eurima welcomes the Commission’s intention to explore options to increase information requirements on the safe use of substances. There are open questions on how to integrate the concept of the environmental footprint to REACH information requirements. Eurima cautions the European Commission to avoid double-regulation and stresses that such holistic exercise must be aligned with upcoming product requirements on environmental footprint as parallel initiatives under the Ecodesign Directive, the Sustainable Product Initiative and the Construction Products Regulation and ensure that resulting product standards are aligned across all pieces of legislation. We re-iterate support for a common platform of information exchange between product legislation and REACH. Mixture Assessment Factor Eurima calls on the European Commission to be careful when setting new models of hazard assessment that requires a careful approach. It is important to explore ways to measure cocktail effects. Therefore we call on the Commission to develop methodologies that take into account of the realistic uses of substances. In the case of mineral wool fibres, our sector is available to provide information on the different use patterns that may be relevant in the discussion of a future MAF. Essential uses Eurima cautions the European Commission to adopt a measured definition of essential uses that takes the whole life cycle benefits of substances, this includes contributing to the decarbonisation of the building stock and the principles of the Circular Economy. Imports The REACH Revision should tackle the issue of imported goods that currently do not follow the same rules as products produced in Europe. If information is missing for those products, it will continue to hamper recycling. Substances placed on the EU market must follow the same rules as the substances and mixtures imported into the EEA.
Read full response

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The review of the Energy Performance of Buildings Directive (EPBD) provides a much needed opportunity which will result in higher energy savings, reduced CO2 emissions and deliver a high societal return on investment through the multiple ancillary benefits of investing in the building and construction sector. We encourage increasing the ambition of the EPBD in alignment with the fit for 55% agenda, the 2050 climate neutrality agenda, and the Renovation Wave Strategy, and therefore support option 3 of the Roadmap, which should be combined with the enforcement of the current EPBD and the further deployment of supporting measures such as technical assistance. The EPBD should set a clear renovation target in line with the Renovation Wave (25 million building units deeply renovated by 2030). Our suggestions include: ● When reviewing the EPBD, a coherent, consistent and mutual reinforcing framework must be ensured with the full package of legislation and measures supporting the implementation of the European Green Deal objectives. ● The Energy Efficiency First principle should be recognised as the guiding and overarching principle in the EPBD revision, prioritising the improvement of the performance of the building envelope, according to the Trias Energetica. ● We support the introduction of phased Minimum Energy Performance Standards (MEPS) in the EPBD, which will be instrumental to put the building stock, i.e. worst performing buildings, on the right trajectory towards delivering a NZEB building stock by 2050 and supporting the overall deep renovation of the building stock. ● Introducing a deep renovation standard at the level of at least 60% (final) energy need*1 would help clarify the right level of ambition. Deep renovation requires improvements in the energy efficiency of the building and should not be solely achieved via fuel change. ● Improving Energy Performance Certificates (EPCs), notably by ensuring that all EPCs are done by professionals fulfilling certifications, and using common agreed EPB standards. ● Deploying Building Renovation Passports (BRPs) at wide scale, as tools that should complement EPCs and can help renovations align with long term climate goals, but also as accompanying documents for owners. BRPs should be digital and user friendly and eligible for subsidy programmes. Given that real performance solutions are increasingly available, real performance metrics should progressively complement the calculated performance of the EPCs. ● Progressively, real performance metrics should complement calculated performance, which would also facilitate the financing of energy renovation linked to guaranteed savings. ● Regarding new buildings, the Commission needs to further support deployment of more ambitious nZEB standards. It should be assessed if (and how) cost-optimality should remain a pillar of the EPBD given the 2030 and 2050 climate objectives and how co-benefits of building renovation including socio-economic impacts could possibly be taken into account. The EPBD should continue to prioritise the reduction of operational carbon through the reduction of energy demand in order to unleash the mitigation potential of the EU building stock. Providing additional understanding and visibility over a new building’s whole life carbon emissions could be an additional driver to reduce both the operational and embodied parts, but the modalities, as well as the benefits for our climate goals (vs. the existing framework), should be well assessed. Any new approach to address the whole life cycle emissions of buildings should be based on the further deployment of Level(s), and on developing a solid harmonised framework on Environmental Product Declarations based on agreed EN standards (EN 15804 / EN 15978). *1 : For more explanation on why energy needs matter, please see: https://www.eceee.org/all-news/press/press-2017/epbd-must-focus-on-reducing-energy-needs-and-avoid-double-counting-of-renewables/
Read full response

Response to Technical amendments to the annexes to the Fertilising Products Regulation

15 Mar 2021

Please see the attachment for our full opinion on the Proposal for a Delegated Act Amending Regulation (EU) 2019/1009.
Read full response

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

17 Feb 2021 · Draft Delegated Act on Taxonomy

Response to Climate change mitigation and adaptation taxonomy

15 Dec 2020

EURIMA fully supports the role of EU Taxonomy to drive the investments needed to reach climate neutrality but would like to raise some important questions and reservations regarding the recently published draft Delegated Act (DA) as subject to this consultation. Insulation products are a key component to deliver energy-efficient solutions for buildings. This was rightly reflected by the TEG Report that placed insulation together with the other products listed under "Manufacture of eligible energy efficiency equipment for buildings" in section 3.1 "manufacture of low carbon technologies". Yet, in the draft DA, the manufacturing of insulation products no longer appears in the list of manufactured EE equipment for buildings (now section 3.4). It is now by default in section 3.5. “manufacture of other low carbon technologies”, not only indirectly questioning whether insulation is an energy efficient solution for buildings and what role it would play for the Renovation Wave but also directly creating an uneven playing field among EE technologies. The EU building stock represents 40% of EU energy consumption and 36% of EU GHG emissions. Improving energy efficiency of the building envelope, by both increasing the rate and depth of renovation as stipulated in the EU Renovation Wave Strategy, should thus be an area of investments clearly supported by the EU Taxonomy. The proposed DA is not only raising concerns for the mineral wool producers but investors too are questioning this omission, triggering unnecessary doubts regarding the role of insulation in the future decarbonising of the building sector. We therefore strongly recommend to include the insulation sector in section 3.4, in line with the original recommendation provided in the TEG report, for the following reasons: 1. Insulation products are key components of the building envelope. They play the biggest role in reducing energy consumption and contributing to climate goals: they should thus be part of section 3.4 energy efficiency measures. It is also a matter of legal consistency as the list of products and systems for which specific requirements are listed, such as roofing systems or cladding systems, include by default insulation products to reach the suggested performance levels. 2. The requirement under section 3.5 to demonstrate substantial life-cycle GHG emission savings compared to the best performing alternative technology simply does not fit the purpose for insulation products. Insulating buildings delivers the most energy and CO2 savings compared to other EE measures. Emission savings for all insulation materials will by far outweigh the GHG emissions from their production due to their long lifetime exceeding 50 years. The discrepancy introduced between EE products that fall in the EE family (3.4), and insulation products when placed in (3.5), introduces a questionable difference of treatment: all other EE solutions would by default classify as compatible with the criteria of the taxonomy (provided they meet some performance requirements), whereas for insulation - another evaluation dimension is introduced, i.e. life-cycle GHG emissions savings compared to best performing alternative technology. We are also concerned with the screening criteria for building renovation in section 7.2, which allows a reduction of primary energy demand of only 30% to be taxonomy eligible. This is not aligned with the Commission’s Renovation Wave and its broader ‘fit for 55% GHG’ commitments. A renovation achieving a 30% reduction in primary energy demand, especially for a building in a very low energy class, is a ‘shallow’ renovation which could make more comprehensive measures in the future costlier. Therefore, we would recommend aligning this screening criteria with the definition of deep renovation of at “least 60% improvement” as recalled in the Renovation Wave Strategy, unless it can be ensured compliance with the national standard for Nearly Zero Energy Building (NZEB).
Read full response

Response to Updating the EU Emissions Trading System

26 Nov 2020

Eurima shares the vision that the EU ETS has proven to be effective in reducing GHG emissions of energy intensive industries. The Mineral Wool industry itself has undertaken important steps to reduce emissions in the manufacturing process as well as contributing to the transition to climate neutrality through its enabling, energy saving insulation products. In the light of future evolutions of the EU ETS, we would like to draw the Commission’s attention to the following points: • A well-functioning EU ETS, with a sufficiently high carbon price, is an effective tool for incentivising the decarbonisation of industry; simultaneously, the EU should continue to ensure protection from carbon and investment-leakage to maintain industrial production within the EU. Any revision of the EU ETS should aim at ensuring long term consistency and predictability for industries to avoid price volatility. Any change in allocation approach and short-term steep reduction in free allowances should be avoided and carefully assessed. A one off reduction of the cap should be thoroughly evaluated to avoid unintended consequences on industry’s ability to invest in low carbon technologies. • The Fit for 55 Package should aim at creating a coherent policy framework, avoiding overlapping legislations. Attention should be put on the possible impact on industry’s competitiveness both within and outside the EU resulting from the interaction between the revision of the EU ETS and measures stemming from the introduction of CBAM, the EED and ETD revision. • The EU ETS revision should be used to channel a higher share of the auction revenues towards climate-proof investments. This will support the deployment and the scale up of innovative low-carbon technologies as well as the transition of the industry and early retirement of old technologies. Revenues should also be used to foster energy efficiency renovation of the worst performing buildings, especially for low-income/energy-poor households, contributing to the objectives set in the EU Renovation Wave Strategy. This means further deployment of the Innovation and Modernisation Funds, aligning the use of the latter with the Energy Efficiency First principle. • Regarding the possible inclusion of “buildings’ emissions” under the EU ETS, we believe that climate policies should promote the reduction of GHG emissions as well as the overall societal wellbeing. Besides contributing to climate objectives, investing in building-renovation delivers a high social return on investments through the multiple ancillary benefits, directly enhancing EU citizens’ life, which risk to be undermined if buildings are brought under the EU ETS. This makes other policy tools more appropriate than the EU ETS to deliver both substantial GHG emissions reduction from the building envelope while, at the same time, incentivising deep renovation and contributing to economic recovery and sustainable inclusive growth. Due to the very nature of the building sector, relative unresponsive to the carbon price and characterized by non-economic barriers, instruments like the EU ETS would have little additional impact on the emissions of this sector and only a very high carbon price would trigger modest reductions [Cfr. Cambridge Econometric]. This high carbon price would significantly increase the living costs for poorer households, leading to higher energy bills for tenants or homeowners who are not able to, or cannot afford to, renovate their homes. The responsibility of acting on buildings should remain in the hands of governments rather than being put on heating fuel suppliers, as the firsts can put in place programs to accelerate building renovation and alleviate energy poverty. The interaction with existing policies covering the building sector should be carefully assessed, especially if an obligation is put on fuel suppliers, as this could distracts from taking effective measures for the decarbonisation of the building stock.
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Eurima believes that the current structure of Europe’s climate policy - composed by a GHG emissions reduction target setting the ambition and two instruments for its achievement, namely the EU ETS Directive and the Effort Sharing Regulation (ESR) - should be maintained. Focusing on the building sector, we would like to make the following remarks: • The building sector should be kept under the ESR: Regarding the phasing out of the ESR or reducing its scope linked to a possible inclusion of buildings under the EU ETS, Eurima believes that climate policies should promote the reduction of GHG emissions as well as the overall societal wellbeing. Besides contributing to climate objectives, investing in building renovation delivers a high social return on investment trough the multiple ancillary benefits, directly enhancing EU citizens’ life. This makes other policy tools more appropriate than the EU ETS to deliver both substantial GHG emissions reduction from the building envelope while, at the same time, incentivising deep renovation and contributing to economic recovery and sustainable inclusive growth. • Due to the very nature of the building sector, relative unresponsive to the carbon price and characterized by non-economic barriers, instruments like the EU ETS would have little additional impact on the emissions of this sector and only a very high carbon price would trigger modest reductions [1]. This high carbon price would however significantly increase the living costs for poorer households, leading to higher energy bills for tenants or homeowners who are not able to, or cannot afford to, renovate their homes. Moreover, the responsibility of acting on buildings should remain in the hands of governments rather than being put on heating fuel suppliers, as the firsts can put in place programs to accelerate building renovation and alleviate energy poverty. Thus, we recognize the value of keeping the building sector under ESR and would discourage the phasing out of this legislative framework as for Option 1, without strengthening energy efficiency measures such as the EED’s energy savings obligations under Article 7. • The ESR ambition should be increased: we believe that the overall ambition of the ESR should be derived from the cost-effective contribution of effort sharing sectors to overall emission reductions. Energy efficiency represents the most cost-effective way to reduce emissions in the building sector, and it should therefore be incentivized. Reducing energy use in buildings through deep renovation is a crucial factor to reach higher emissions reduction under the ESR. When it comes to the building sector, a recent study by Climact [2] shows that buildings must make a major and irreplaceable contribution in reducing GHG emissions. If the building sector fails to deliver its share of GHG emission cuts, it will leave a GHG reduction gap of 10% to 14% percentage points compared to the net-zero goal. This gap cannot be filled even if other sectors were to decarbonize fully. • Parallel policy framework, as put forward in Option 2, should be avoided: The interaction and the complementary with other polices should be carefully assessed in other to create a coherent policy framework, avoiding overlapping legislations. Attention should be put on the possible impact on the industry competitiveness that might result from the revision of the EU ETS, EED and ETD. Also, being the building sector already covered by a variety of policies (next to the ESR, EED, EPBD, Governance Regulation), placing buildings under the ETS could create another layer of administrative complexity. [1] Cfr. Cambridge Econometric, 2020. The risks of extending the EU Emissions Trading System [2] Climact, 2018. The key role of energy renovation in the net-zero GHG emission challenge
Read full response

Response to Sustainable Products Initiative

16 Nov 2020

Eurima welcomes the Commission’s intention to harmonize and set a baseline of principles for a market of sustainable products in Europe. We support the objectives of the Circular Economy Action Plan in this regard as it will contribute to a fairer market and allow for a better valorisation of the more sustainable products in the construction sector. The Circular Economy Action Plan is one of the pillars of the EU Green Deal and is largely in line with priority subjects, challenges and opportunities as identified by our industry. Construction products can have an enormous contribution to achieve the targets towards sustainability and climate neutrality by 2050. In particular, we believe that policies for sustainable construction product should rely on key principles such as: • Environmental performance across the full life cycle of the building; • Recycled content and recyclability; • Transparent and clear information on the content of the construction products accessible to all; • Durability; • Social indicators inclusion such as thermal comfort, acoustic properties and fire safety; When it comes to improving construction product’s sustainability, one has to bear in mind that the purpose of construction products is their use in the context of the building. Currently, the applicable regulation for construction products is the Construction Products Regulation (CPR) which defines a framework to facilitate the delivery of environmental information from construction products and can implement any requirement derived from environmental needs. Eurima believes that CPR is the most appropriate legislative instrument to introduce sustainability principles for construction products. The Construction Products Regulation (CPR) Basic Work Requirements (BWR) 3 and 7 define the regulatory framework for the mandatory declaration of the social and environmental impacts of construction products. Declarations under BWR 3 and 7 relate to hygiene, health and environment over the entire life cycle, and sustainable use of natural resources, respectively. Indicators included in the CPR could contain a core set of indicators which would be used at the building level as notified by EU member states. Eco-design regulation mainly focuses on end products and the end products which incorporate the construction products would be the final buildings. Buildings are regulated by the EU national building codes. Having both CPR and Eco-design covering construction products would likely results in double regulation. This would therefore create confusion and burden to the market. This would be against the principles of smart regulation and will lead to a reduction in the competitiveness of SMEs. Creating an additional framework for the same aspect would be an unnecessary burden. Where certain characteristics are not yet covered, e.g. resource efficiency, these can also be dealt with through the CPR (and Basic Requirements for Construction Works – BRCW). For construction products, Environmental Product Declarations (EPDs) based on the recognised standard EN 15804 provide a science based tool to communicate about the life-cycle environmental impact of products. EPDs have developed in a voluntary manner; today they provide adequate answer to market players’ and are also embedded in policy developments. The mineral wool industry can be seen as a leader in the development and use of EPDs, and more specifically of third party verified EPDs. In addition to the optimization of building designs, the EPDs also feed the different building assessment schemes to allow reliable environmental impact assessment of buildings. Moreover, the manufacturers use it for external communication but also for internal improvement and optimization of the manufacturing processes towards reductions of environmental impacts. --> Please read the attachment for our full contribution.
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to revise the Energy Efficiency Directive in support of the EU’s higher 2030 climate target. Below we list our key priorities for this revision. Firstly, the energy efficiency first principle must be central in the efforts to increase the EU’s greenhouse gas emission reductions target for 2030, and as such should be referenced in the directive to help ensure its application across the different sectors and MS. This means that the EU’s 2030 energy efficiency target must be increased to tap into the cost-effective potential of at least 40%. It should be expressed in both primary and final energy, and complemented by a clear indication of the contribution expected from building renovation. Secondly, in many countries, the delivered energy savings are insufficient to achieve the national targets. Progress in achieving the 2020 targets has slowed down, in part due to insufficient measures implemented at the national level. National binding energy efficiency targets need to be introduced to overcome similar issues for the 2030 target, as also called for by the European Parliament. Thirdly, there is still a lot of untapped energy efficiency potential in the building stock, with the weighted energy renovation rate at a persistent low 1%. Two recent studies by RAP (2020) and CE Delft (2020) have shown that Minimum Energy Performance Standards can fill the EU policy gap by stimulating the required volume and depth of renovation. The revision of the EED should introduce such standards for all public buildings, including schools, hospitals and affordable/social housing in view of reaching a highly energy-efficient and decarbonized building stock by 2050. Together with the Renovation Wave, and additional measures and financing opportunities across the whole building stock, this would support MS in meeting the increased 2030 energy efficiency objective. Moreover, Art. 5 should be extended to cover all public buildings, representing around 12% of the EU’s building stock: centrally and owned and occupied buildings by central government account only 1% of the total stock. At the same time, to increase its impact, alternative measures should be deleted. Fourthly, the credibility of MS’ energy savings under Article 7 of the EED needs to be reinforced. A report by Jan Rosenow and Stefan Scheuer (2019) has exposed the dangers with a situation where countries can freely credit all energy taxes as energy savings, regardless their real impact: this could render the Article 7 energy savings obligation meaningless. It therefore has to be ensured that new and additional savings are triggered via article 7 and that these savings will focus on end-use energy savings, such as building renovation, that directly benefit citizens and businesses. The role of article 7 energy savings obligations in realizing deeper renovation should be stimulated, as well as its better articulation with other incentives for renovation. There also needs to be increased transparency and accountability so that reported energy savings are more accurate and consistent across MS. A public scrutiny board, consisting of Commission officials, experts and civil society stakeholders, that looks at Member States’ measurement, verification and evaluation frameworks needs to be created for this purpose. Finally, Art. 8 should be revised to further unlock the energy efficiency potential in industry. The implementation of recommendations stemming from energy audits should be made mandatory, especially for measures with a short pay-back period. There is still significant energy efficiency potential of industrial insulation representing around 37 Mt annual cost-effective CO2 savings, or around 4% of industry’s total annual CO2 emissions (EiiF, 2020). Eurima looks forward to work with the Commission and other policymakers & stakeholders on the evaluation and revision of the Energy Efficiency Directive
Read full response

Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Eurima welcomes the Commission’s intention to harmonize and set a baseline for the substantiation of green claims for products and businesses. Our industry shares the concerns raised in the Roadmap regarding the detrimental impact of unsubstantiated green claims on consumers, both on B2B and B2C markets and on the internal market. We therefore support the objectives of the Circular Economy Action Plan in this regard as it will contribute to a fairer market and allow for a better valorization of the more sustainable products in the construction sector. Eurima believes in: - the importance of making sustainability performance an integrated part of the EU building’s policy; and of encouraging manufacturers to communicate about such performance; - the need to address the impact of buildings across their full life cycle accounting in particular for both embodied and operational carbon; Building level assessment based on the EN15978 standard. - environmental performance of construction products assessed according to the EN15804+A2 standard; For construction products, Environmental Product Declarations (EPDs) based on the recognised standard EN 15804 provide a science based tool to communicate about the life-cycle environmental impact of products. EPDs are today mostly voluntary but have already been in use for many years for different purposes. The mineral wool industry can be seen as a leader in the development and use of EPDs, and more specifically of third party verified EPDs. In addition to the optimization of building designs, the EPDs also feed the different building assessment schemes to allow reliable environmental impact assessment of buildings. Moreover, the manufacturers use it for external communication but also for internal improvement and optimization of the manufacturing processes towards reductions of environmental impacts. At the same time, construction products differ from end products and considered intermediate as the environmental impact shall be considered based on their application and at the building level. When it comes to green claims, EPDs are requested in some countries. In Belgium, a royal decree for building materials requires to have an EPD for making an environmental claim on the packaging. In France, EPDs are also considered as the reference to make environmental claims. And EPDs will be part of documents to be produced to comply with the forthcoming environmental regulation 2020. Eurima has actively participated and supported the harmonization between EN15804 and PEF as a result the new “PEF for buildings” method, EN15804+A2. We continue to support the alignment of standards and schemes towards the new EN method in accordance to the efforts of the European Commission at all levels. EN15804+A2 provides a structure to ensure that all EPDs are derived, verified and presented in a common and appropriate way to be used for the building assessment. This has been achieved thanks to the participation of all construction products representatives and Member states which ensured horizontality, but also to the fact that the EN15804 was developed in accordance to the EN15978 related to the environmental performance of buildings. In addition, Eurima together with the other insulation manufacturers have committed to update their Product Category Rules (PCRs) according to the new method. --> Please read the attachment for our full contribution.
Read full response

Response to Review of the Construction Products Regulation

18 Aug 2020

Eurima welcomes and supports the continuous efforts of the European Commission to safeguard and improve the European internal market for construction products. We strongly believe that a well-functioning and transparent internal market is the basis for continued sustainable growth and a major enabler for a sustainable built environment. Regarding the Inception Impact Assessment on the CPR, we would like to share with you some general remarks and the outcome of our internal assessment of the different expected impacts as described by the European Commission in Section C of the Inception Impact Assessment report. In general, we think it should be recognized that all options besides option A will create additional administrative burden in the adaptation process to new legislative requirements. Regarding market surveillance, we welcome the different measures proposed in options B, C and D by the European Commission. Providing guidance and support to national authorities will however also harmonize and improve market surveillance under option A. Furthermore, we believe that none of the options as proposed by the European Commission will avoid emerging national taxonomies. This is due to the fact that these national schemes, apart from being related to the placement of products on the market are also an important reference for insurances required by the local/national market, tax reductions, etc. With regards to Option A, we believe that, in terms of economic impacts, for all the manufacturers who have not been issuing Environmental Product Declarations (EPD) on a voluntary basis in the past, indeed additional costs will occur. However, we do think that making it mandatory for all manufacturers would facilitate the transition to a more innovative and sustainable construction sector. With regards to Option B, unlike the European Commission assessment, we think that this option will not lead to a reduction of implementation costs. It will at best stabilize them as, in practice, industry will have to reinvest in new Declarations of Perfomance (DoPs), updating databases, issuing more EPDs, participating in new Technical Committees to update the harmonized technical specifications, etc. In terms of legal certainty, we think this specific option can lead to improvement if Member States would be more involved in the initial stages of the standardisation process (issuing of mandates/standardization requests). Clear guidance remains necessary from the European Union. It is important to note that most of the CPR-related issues recognized by the European Commission can be handled within the current framework by providing sufficient guidance to the different stakeholders and member states. With regards to Option C, we think this option will induce substantial additional costs both for member states and manufacturers. Member states will have to develop national schemes and manufacturers will have to service and comply with all these schemes in addition to the EU-scheme. We would recommend the European Commission to disregard this option. It would effectively reduce to zero all the efforts made in recent years to create a single and harmonized European market for construction products. Losing the technical language would make the DoP difficult from country-to-country and create confusion for end-users. Manufacturers would have to handle different languages and deal with the mutual recognition between member states. With regards to Option D, in general we agree that this option, if implemented correctly, may improve the protection of workers/occupants and promote the environmental goals as set out in the European Green Deal and the Circular Economy Action Plan. However, we do think that this option will reinforce national requirements and hereby increase implementation costs. Product requirements would lead to adjustment costs for operators which may differ from one country to another in handling different national targets.
Read full response

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

Eurima (European Mineral Wool Insulation Manufacturers) supports the efforts of the European Commission on the revision of the requirements for packaging and packaging waste. Our industry is committed to constantly improve the packaging of our products by reducing the use of “fossil based/virgin plastic” and increase the recycle content when it is technically feasible and economically viable. From our point of view, it is important to take into account the expected and necessary technical performance of certain packaging when considering the recycled content of such packaging (tensile strength, resistance to UV radiation, etc.). For example, in our specific case, MW products are highly compressed with the help of plastic film wrap that ensures a good size for transportation and storage. This is particularly important as it contributes to better loads of the vehicles, more efficient transportation and less space when it comes to storage of our products. This is feasible by the technical performance of the packaging that is used for our products. It also contributes to the reduced environmental footprint of our products. Our industry is committed to phase out unnecessary packaging and we are constantly trying to improve in this respect. In addition, we believe in order to succeed in better reuse/recycling of the packaging, well-structured and economically feasible recovery systems shall be put in place. We remain at the disposal of the European Commission and other policymakers & stakeholders for further discussion.
Read full response

Response to Chemicals strategy for sustainability

19 Jun 2020

Eurima welcomes the Commission’s intention to protect the citizens and the environment and combine better health and environmental protection by simplifying and strengthening the legal framework. We also see the value that this Strategy could bring to the other EU priorities under the European Green Deal, such as circular economy ambition, which European Insulation Manufacturers Association (Eurima) is strongly committed to. The Chemical Strategy can indeed help progress on issues linked to the Interface between chemicals, product and waste, identify the overlaps and gaps and take action. Eurima has identified some work streams and actions that should be taken into account for the Chemicals Strategy for Sustainability, which some of them already highlighted in the 2018 consultation of the interface between Chemicals, Products and Waste that would improve circularity in the context of construction sector and the interlinks with the Chemical Products Regulations: • Improve exchange between REACH, Product Standards and Eco-design once a change in a classification of a substance is implemented, in order to ensure the correct, up to date and alignment of information per substance. Today, the manufacturers are responsible for the cross-check between the legislations while this could be solved with a common platform exchange between the relevant product legislations and REACH. • Avoid having discrepancy of methods between REACH and CPR for mineral wool products on their chemical emissions. Today, the REACH regulation restriction proposes a test method for the assessment of formaldehyde emission that is not in line with the current CPR regulation that defines another test method for the VOC emission. The gap between the two methodologies required creates additional administrative effort and high costs to the manufacturers in order to assess the emissions of their products. In order to fill this gap, a better alignment of scope and requirements between the two pieces of legislation is essential for construction products to avoid double work but to ensure the best possible protection of consumers and the environment in Europe. • The imported goods should follow the same rules as the products produced in Europe. If information is missing for those products, it will continue to hamper the recycling. The management of the goods introduced in the EU market must follow the same rules as the substances and mixtures imported into the EEA according to REACH Regulation e.g.: Article 5 of REACH Regulation: No data, no market: “Substances on their own, in mixture or in articles shall not be manufactures in the Community or placed on the market unless they have been registered in accordance with the relevant and provisions of this Title where this is required “ [...] Please see the attachment for our full opinion on the Chemicals Strategy for Sustainability roadmap.
Read full response

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The European Insulation Manufacturers Association welcomes the Commission’s intention to at least double renovation rates. Without addressing the EU’s biggest CO2 emitters (buildings), the 2050 climate neutrality objective will be unachievable. Spurring a Renovation Wave is also of key importance to the EU’s economic recovery, as it has the potential to immediately boost local employment and support the many SMEs in the construction sector. Eurima broadly agrees with the aspects that the Renovation Wave initiative will address and underlines that a greater focus should be placed on comprehensive solutions that solve multiple barriers and enable deep renovations. However, Eurima has identified 3 further priorities, currently missing from the roadmap, which must be included in the upcoming Renovation Wave initiative for it to succeed: (i) the establishment of ring-fenced funding for renovations, (ii) the introduction of minimum energy performance standards and (iii) a greater focus on renovation depth and quality. Firstly, dedicated funding (both loans and grants) needs to be ring-fenced for the renovation wave. Scaling up deep renovation projects require organizational and financial competences. This has so far not been successful when addressed by multi-faceted financial instruments that allow the choice of ‘easier’ large infrastructure projects. Only a dedicated team, managing a tailored financing facility and providing technical assistance, will deliver deep renovations at a scale needed to achieve the Green Deal objectives. Technical assistance is essential to support project promoters in developing and bundling projects and to grow financial institutions’ interest in financing renovation projects. This upfront support should be at the core of the Renovation Wave. Over 125 organisations have called for the establishment of a dedicated Renovation Fund. As a first action of such a renovation facility, the deep energy renovation of public buildings should be incentivized to help with the EU’s recovery. Secondly, the Renovation Wave must include a commitment to upgrade the worst performing buildings in order to guarantee quality homes to people, thus improving living conditions and tackling energy poverty. This can be achieved by setting minimum energy performance standards (MEPS) for existing buildings that are progressively tightened over time in line with the EU’s 2050 climate neutrality objective. MEPS will be crucial to give visibility and security to the market regarding the future direction of the existing building stock. If done right with sufficient lead times, MEPS allow the market to mobilise itself and properly plan for the transformation. Investors would be incentivised to shift their real estate portfolios to climate neutral compliant ones, encouraging their clients to value energy efficiency and providing financial incentives or more advantageous financial products for energy renovations. An EU-level scheme for MEPS for existing buildings should hence be a central element of the regulatory leg of the Renovation Wave. Thirdly, the Renovation Wave should help ensure greater depth and quality of renovation works. To this end, Energy Performance Certificates (EPCs) should become a more reliable tool in assessing energy performance and improvements post-renovation, notably by enhancing the required qualifications to deliver EPCs. Building Renovation Passports (BRPs) and real performance metrics should complement the EPC to ensure adequate project planning, coordination of the renovation steps and proper design of measures. BRPs, energy advisory services and one stop shops are essential to boost the renovation market and to reach the needed 75% energy savings on average, next to lifting the burden of work planning for owners. Progressively, real performance metrics should complement calculated performance, which would also facilitate the financing of energy renovation linked to guaranteed savings.
Read full response

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and

4 May 2020 · Renovation wave and recovery

Meeting with Kadri Simson (Commissioner) and

23 Apr 2020 · How building renovation can contribute to post covid-19 recovery, how to get renovation projects off the ground, how to remove regulatory obstacles and improve advice.

Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s work to create a classification system for sustainable economic activities (‘taxonomy’). Eurima believes that the taxonomy is of vital importance to mobilise sustainable investments that help Europe reach net-zero greenhouse gas emissions by 2050 at the latest. The screening criteria should hence be regularly updated to make sure they evolve in line with policy developments and the pathway to climate-neutrality by 2050. The process to update these criteria should be done in a transparent way and in close collaboration with relevant stakeholders, including market actors, to ensure that they do not lag behind (but rather spur) market developments. The same applies to the relevant do-no-significant harm criteria that should be defined in a transparent and an inclusive manner. Clarity regarding the method and modalities of assessing these criteria will be important to guarantee harmonized implementation across the market. In relation to the climate mitigation criteria for the activity ‘Construction and real estate activities’, Eurima would like to make the following two recommendations based on the final report of the Technical Export Group on Sustainable Finance (TEG): Firstly, in relation to ‘Building renovation’, the taxonomy will be important to both accelerate the rate of renovation as well as improve the depth of renovation. There could be a significant risk of carbon lock-in with the TEG’s proposed criterion of attaining at least 30% energy savings. A renovation achieving 30% energy savings in a building, especially a building in a very low energy class (e.g. EPC rating of F or G), can be characterized as a ‘shallow’ renovation. Shallow renovations could make more comprehensive measures in the future more costly and hence can put the achievement of a highly energy efficient and decarbonised building stock by 2050 at risk. Additional safeguards will be needed, as 2050 is only 1 renovation cycle away. These additional safeguards can include a future evolution to absolute thresholds, subjecting the % improvement to achieving a certain energy class (i.e. linking it to a minimum energy performance standard) or encouraging investors to incentivize deeper renovations beyond these thresholds e.g. by setting better funding conditions if you go beyond the minimum renovation requirements. Secondly, in relation to the future evolution to carbon metrics of the activity ‘Construction of new buildings’, it would be appropriate to assess whole life carbon and thereby ensure that embodied carbon is not considered in isolation. It also remains important to complement any carbon metrics with energy efficiency thresholds, as reducing the energy demand of buildings is a prerequisite for a rapid and cost-effective expansion of renewables in buildings (and beyond). This is because the renewable energy potential is inadequate to meet the heating demand of a poorly renovated building stock. Increased efficiency in existing buildings moreover allows heating system flow temperatures to be reduced, which increases condensation boiler efficiency and permits the use of heat pumps for heating. Eurima looks forward to work with the European Commission and other stakeholders on the development and implementation of the taxonomy.
Read full response

Response to EU rules on industrial emissions - revision

17 Apr 2020

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to improve the design and implementation of the Industrial Emissions Directive (IED) in order to prevent, reduce and eliminate as far as possible pollution arising from industrial activities. Eurima supports the IED and believes it has positively contributed to environmental sustainability, benefiting citizens and the society as a whole. The following observations and areas for improvement should be kept in mind for the IED’s revision: First, regarding the IED’s contribution to the reduction of energy use, we suggest to strengthen the already existing horizontal BREF for energy efficiency and to make it mandatory. According to an Ecofys (2012) study for the European Industrial Insulation Foundation, there is still significant energy efficiency potential of industrial insulation representing 620 PJ annual cost-effective energy savings (equal to the annual energy consumption of 10 million households), or 50 Mt annual cost-effective CO2 savings. For industry, the savings potential for low-temperature surfaces is about equal to the potentials for middle and high-temperature surfaces together. The horizontal energy efficiency BREF should tap into this potential to maximize the IED’s contribution to energy efficiency and climate neutrality. Secondly, the BREF is very focused on air emissions, and at the moment does not sufficiently take into account other aspects such as waste, water consumption and the reduction of natural resources. The Commission should analyse the interaction of the IED with other policy instruments in these areas to best achieve the objectives. Thirdly, the duration of the process for developing and reviewing BREFs is too long. In our case, the process took almost six years and the intention to revise BREF notes every 8 years has not happened. The long BREF process creates unnecessary administrative burdens and costs. A more efficient BREF process would allow the IED to achieve its benefits more cost-effectively. Fourthly, the BAT conclusions are not clear enough regarding monitoring requirements and can be subject to diverse interpretations. Reporting requirements are based on local regulations and even the common reporting scheme ‘PRTR’ is used differently in different countries. This means that reporting and monitoring requirements are not harmonized between Member States. This is hence an area for improvement in the IED revision. Finally, we believe that the IED remains a relevant and an effective tool for the transitioning to a climate-neutral economy. We cannot imagine such a transition without a comprehensive approach to addressing pollution and environmental impacts to air, land and water. Eurima looks forward to exchange with the European Commission and other policymakers & stakeholders on the revision of the Industrial Emissions Directive to achieve a high level of protection of the environment.
Read full response

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s work to enshrine the long-term objective of climate neutrality by 2050 in legislation and increase the EU’s climate ambition by 2030. Additional market economy measures are necessary to enable decarbonisation of the industry, while avoiding carbon leakage. An assessment and a revision of current and new policy instruments are therefore needed to achieve the Green Deal’s objective of a decarbonized and competitive EU. In order to incentivize industry decarbonisation, a sufficiently high carbon price will be required while avoiding carbon leakage and maintaining industrial production within the EU. Investments in low-carbon technologies should be rewarded by putting an adequate price on greenhouse gas emissions ($50-100/tCO2 by 2030 to achieve the Paris Agreement goals according to the High-Level Commission on Carbon Prices). We therefore need a well-functioning EU ETS, while making sure that a high carbon price does not encourage a shift in emissions to other jurisdictions with no, or lower, carbon prices. Eurima believes that a carbon border adjustment mechanism may be one possible option to create a level playing field for low-carbon products. Before preparing any legislative proposal, the feasibility of such a mechanism needs to be robustly analyzed through an in-depth impact assessment. This assessment should encompass a careful analysis of the mechanism’s functioning in relation to the existing climate and energy policy instruments. The following four principles should be kept in mind in the design of such a mechanism: Firstly, the overall objective of the mechanism, to help sustain and increase domestic climate ambition while also incentivizing other countries to take comparable action, needs to inform decisions on how a border measure is introduced. Retaliatory measures by third countries need to be avoided, for example by involving third countries in the process to determine whether these countries have taken comparable action. The first global stock-taking foreseen during COP26 could represent a first occasion to assess global climate policy developments. Secondly, we also encourage the Commission to analyse other types of instruments and policy options to help decarbonize industry and sustain production, demand and uptake of low-carbon products in the medium- and long-term. This can include targeted incentives for energy efficiency investments or instruments such as public procurement. Thirdly, administrative complexity should be avoided as much as possible. In the reflection on the methodological approach to evaluating the carbon content of products, we recommend the European Commission to base its analysis on well-consolidated market practices, following EU and International Standards. For construction products, such an assessment needs to be based on Environmental Products Declarations (EN 15804 standard and its V2), which represents a worldwide reference with more than 7,300 construction products covered. Fourthly, the carbon border adjustment should avoid competitive distortions, within and outside the EU. A fair and solid assessment of this matter is needed. Eurima looks forward to exchange with the European Commission and other policymakers & stakeholders on the design of a carbon border adjustment mechanism in Europe and other relevant instruments.
Read full response

Response to Climate Law

6 Feb 2020

The European Insulation Manufacturers Association (EURIMA) welcomes the Commission’s intention to propose a Climate Law to put the 2050 climate neutrality objective into legislation. EURIMA is strongly committed to, and supports, the transition to a climate-neutral economy by 2050 at the latest. The Climate Law needs to help accelerate the transition, by providing certainty as to the trajectories to be taken at EU and national level, and by enabling all sectors to play their part, building on citizens’ engagement. Action in the building sector is urgently needed to make this transition a success. No other sector in the EU uses more energy or emits more carbon dioxide. And no other sector offers such a huge opportunity to make a positive difference to people’s lives. EURIMA has identified 4 priorities to be addressed by the Climate Law. Firstly, the Climate Law should clearly put the Energy Efficiency First (EE1) principle at its core and ensure its application across all infrastructure, policy and investment decisions. EE1 requires considering the value of investing in energy efficiency in all decisions about energy system development. Applying this principle will increase Europe’s ability to create a less costly, jobs-rich and climate-neutral economy. It also means that any new modelling exercise should build on this principle. As such, the Climate Law should ensure that energy efficiency plays its enabling role to decarbonize the economy at large in the most cost-efficient manner, and buildings in particular. The Climate Law’s identified pathway to climate-neutrality by 2050 should therefore set out intermediary targets including for energy efficiency and specify that a share of energy savings will come from the building sector. Secondly, to realise a climate-neutral Europe by 2050 all sectors will need to play their part. The Climate Law should include a long-term vision for the buildings sector, by re-affirming the objective of a highly energy-efficient and decarbonized building stock by 2050 and by embracing the transition to net-zero whole life carbon buildings. The Climate Law should also establish a reporting and review process to make sure that Europe and Member States are on track to meeting the climate-neutrality objective (Ecologic (2020); Climate laws in Europe). An ambition trigger mechanism should enable the Commission to put forward new EU legislation, to accelerate the phase-out of the worst energy performing buildings through increasingly higher energy performance standards. This will help to eradicate energy poverty and to bring social, economic and environmental benefits to the society at large. Further inaction in the building sector otherwise risks the EU missing its climate objectives by up to 400 million tonnes of CO2 (Climact (2018); The key role of energy renovation in the net-zero GHG emission challenge). Thirdly, the energy efficiency potential in industry should be unlocked. There is still significant energy efficiency potential of industrial insulation representing around 37 Mt annual cost-effective CO2 savings, or around 4% of industry’s total annual CO2 emissions (EiiF, 2020). The Climate Law should pave the way for clear EU level requirements for industrial energy efficiency. Finally, the Climate Law must be accompanied with targeted support to further develop innovative technologies to lower industrial emissions. Mission-oriented R&D programmes for low-carbon technologies in energy-intensive industries like mineral wool are a must. This means providing sufficient support for designing and building demonstration plants at scale, as well as for their roll-out across the market. The Innovation Fund should support industry low-CO2 innovation, while green public procurement and contracts-for-difference can help ensure market uptake. EURIMA looks forward to work with the European Commission and other policymakers & stakeholders on the development and implementation of the Climate Law.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

EURIMA welcomes the Commission’s intention to adopt a new Circular Economy Action Plan in which actions in high-impact sectors, such as construction, will be identified. The European Insulation Manufacturers Association (EURIMA) is strongly committed to, and supports, the transition to a circular economy. This is still a challenge for the construction sector, which uses about half of the resources extracted around the world. Overcoming the barriers to circularity in the construction and building sector is particularly important in light of the upcoming ‘renovation wave’ which will lead to an increase in renovation activities in the coming years. EURIMA has identified 5 actions to be tackled by the New Circular Economy Action Plan so that building and renovating is done in a resource efficient way: Firstly, the re-use/renovation of existing buildings needs to be prioritized. If this is not possible, buildings need to be dismantled, rather than demolished, to avoid that construction waste is mixed and valuable construction materials end up in landfills. The sorting of construction waste from deconstruction/demolition sites will need to become mandatory and (non-weight) targets for the recycling of construction products should be set. Secondly, reuse and recycling must become more (financially) attractive than landfilling. Currently, construction materials still end up in landfills, as landfilling is often cheaper than recycling these materials. A ban on landfilling for all products that can be recycled, and/or a tax on landfilling can help overcome this. Requirements for durability, recycled content and recyclability, combined with clear and consistent terminology (reuse, recycling, recyclability) through standardisation, can also help promote circularity. Thirdly, EU waste legislation needs to facilitate, instead of hamper, the reuse and recycling of construction products. We expect an increase in renovation activity and therefore more non-performing construction systems being replaced by systems with better energy performance. When these ‘old’ systems become waste, some components are sometimes by default classified as hazardous under the Waste Framework Directive and subject to strict provisions. These provisions hamper the recycling of this waste as a secondary raw material to produce materials that no longer contain any substances of concern. A dedicated legal framework should be created to foster recycling of hazardous waste streams into non-hazardous products. Fourth, in order to facilitate circularity in the building and construction sector in the long-term, a harmonised way to provide transparency on the content of buildings and construction products and their end-of-life routes (guidelines for correct disassembly, re-use possibilities etc.) will be required. An EU-wide standard for information on the content of construction products can encourage the use of non-toxic and recyclable materials. The information should be included in building passports and still be accessible when the building and/or products reach their end-of-life (after around 50 years for construction products), through developments in digitalisation (e.g. BIM), in order to facilitate dismantling, reuse and recycling at that time. EURIMA is working on a voluntary content declaration for the industry as a first step towards a harmonised approach. Finally, a proper regulatory framework needs to be accompanied with (EU and national) investments prioritizing circularity in the construction sector inter alia by supporting research and development of new recycling technologies. EURIMA looks forward to work with the European Commission and other policymakers & stakeholders on the development of the New Circular Economy Action Plan.
Read full response

Meeting with Daniel Calleja Crespo (Director-General Environment)

4 Feb 2019 · Circular Economy and sustainable production and consumption

Response to Carbon Leakage List 2021 - 2030

10 Nov 2017

Eurima welcomes the opportunity to comment on the Inception Roadmap concerning the carbon leakage list 2021-2030. Prior to drafting the list, as part of the methodological choices for the parameters of the assessment it is essential to have a fair and transparent framework which takes into account industry specificities, for assessments at disaggregated and qualitative levels, thereby ensuring (intra and inter industry) the equal treatment and non-discrimination of sectors and subsectors. Our contribution focuses on this aspect. The unique case of the Mineral Wool Sector: a level-playing field in the Carbon leakage assessment Eurima represents the interests of all major mineral wool producers throughout Europe. Our members manufacture a wide range of mineral wool products (glass wool and stone wool) for the thermal, acoustic insulation and fire protection of domestic and commercial buildings and industrial facilities. The different types of products (glass and stone wool) that compose the mineral wool insulation sector share the same range of properties combining high thermal resistance with long-term stability. They are very similar products destined for the same use in the same market. Additionally, the production processes are largely the same: melting of mineral raw materials, fiberizing, curing of the binder, products mainly made in the form of rolls or boards. The only difference between glass and stone wool can be found in the sourcing of the raw material. The mineral wool insulation sector is treated as “one single sector”. Our sector is recognised as one by an array of actors and institutions, including the European Commission, in a wide range of regulatory instruments including: Best available techniques Reference document (BREF), European standardisation, the Industrial Emissions Directive (IED), and not least the EU ETS itself, where we have one benchmark for the mineral wool sector . Ensuring the competitiveness of our industry requires a holistic assessment. Glass and stone wool despite, belonging to the same mineral wool sector are today categorised under different NACE4 codes which are heterogeneous. Due to the very nature of this statistical grouping, unless treated at Prodcom level our products are at risk of not being evaluated on equal terms when it comes to the risk of carbon leakage, with possible generation of competition distortions and damaging the level playing field across the sector. Hence, the need to preserve the possibility for evaluation at disaggregated level (Prodcom level) by having an explicit legal reference in the EU-ETS proposal Art 10b4. Doing so is the only way to enable the equal treatment of all mineral wool insulation actors in a given market on equal terms, as one single sector, and preventing unintended consequences.
Read full response

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

10 Nov 2016 · energy efficiency

Meeting with Miguel Arias Cañete (Commissioner) and ROCKWOOL A/S and

27 Sept 2016 · Energy efficiency in buildings

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

20 Sept 2016 · post 2020 construction strategy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

2 Sept 2016 · Energy efficiency in buildings

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

1 Jun 2016 · on insulation and energy efficiency

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and ROCKWOOL A/S and

30 May 2016 · energy efficiency in buildings

Meeting with Dominique Ristori (Director-General Energy)

30 May 2016 · Energy Efficiency

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

2 Mar 2016 · Investment in Energy Performance in Buildings

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

16 Feb 2016 · Energy and Climate Policy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

29 Jan 2016 · Review of the EPBD

Meeting with Riccardo Maggi (Cabinet of First Vice-President Frans Timmermans)

5 Nov 2015 · Better regulation

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

2 Oct 2015 · Cohesion Policy and energy efficiency

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

10 Sept 2015 · Energy Efficiency

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete), Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

9 Sept 2015 · Energy Union

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

8 Sept 2015 · Energy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

11 Mar 2015 · Circular Economy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

11 Mar 2015 · Circular Economy and Resource Efficiency in the Construction Sector

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

11 Mar 2015 · Circular Economy

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

11 Dec 2014 · Energy Efficiency in buildings, Energy Security, Energy Union