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European Parquet Federation

FEP

The European Parquet Federation (FEP) reunites European national parquet federations, parquet manufacturers and suppliers to the industry.

Lobbying Activity

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

30 Apr 2025

Regarding the following extract of the Annex of the draft Delegated Act: In the column, Relevant products, table note (1) is added after the entry Relevant Product: This Regulation does not apply to: a) Samples of products, which are of negligible value and quantity and can be consumed or used only to solicit orders for goods of the type they represent under the condition that the manner of presentation and quantity, for products of the same type or quality, rule out its consumption or use for any purpose other than that of seeking orders; b) Products which are to undergo examination, analysis or tests to determine their composition, quality or other technical characteristics for purposes of information or industrial or commercial research under the condition that the products to be analysed, examined or tested are completely used up or destroyed in the course of the examination, analysis or testing.", we very much welcome the fact that samples being used to seek orders or used for testing would be out of the EUDR scope. This is already reflected in the 4th version of the FAQs document under question 2.14 (p.31) although question 3.2 would, to our understanding, need to be revised accordingly.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

30 Mar 2023

FEP the European Parquet Federation is welcoming the European Commission proposal to revise the Packaging and Packaging Waste Directive, and the possibility to comment it. FEP is viewing this revision of the Packaging and Packaging Waste Directive as a unique opportunity to set common requirements on which information should be shared with consumers for sorting instructions and how this should be done in an harmonised way. Our comments concern especially Art 11.7, Art 13.7, Art 49.1.c & d, and Art 49.2 of the proposal issued on 30 November 2022 as well as the future implementing acts. In order to increase collection and recycling of packaging without hampering competitiveness, it is paramount: -To have a complete harmonisation of labels focusing on symbols and not languages or colours - To avoid accumulation of different (national some initiatives are already on-going) labels/labelling schemes. This will also allow to be space-conscious on-pack and avoid the obligation to increase packaging size.
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Response to Carbon Removal Certification

23 Mar 2023

FEP the European Parquet Federation is warmly welcoming the European Commission proposal for a Regulation establishing a Union certification framework for carbon removals, and the possibility to comment it. We also welcome the recognition of the carbon stored in long-life wood products such as parquet - although we would welcome more detailed delegated and implementing acts as well. Sustainable Forest Management (SFM) and the recyclability of our wood-based products are guaranteeing that our activity, besides storing carbon, is not endangering other dimensions of sustainable development and Green Deals objectives. Although we have to develop new business models for our products, allowing us to extend their monitoring period, we would appreciate that the expiry date of the certificate corresponds for the time being - to the theoretical life of the product and benefits more to products with a longer life. Methodologically, links should be made with ongoing work considering dynamic LCA (Life Cycle Analysis) and delayed emissions (for example, the revision of 16485 Round and sawn timber Environmental Product Declarations Product Category Rules for wood and wood-based products for use in construction). This possibility of accounting carbon storage should nevertheless not be a tool to offset carbon emissions only. There is a need for proactivity in reducing these emissions at their source. For instance, by substituting fossil-based products by wood-based products. Carbon emissions will be reduced and carbon removals increased, a win-win situation. Our sector will of course need enough raw material wood for supporting this solution and afforestation, reforestation, coherent policies (Forest and Biodiversity Strategies, LULUCF), etc. are primordial in this regard. Finally, administrative burdens should be limited, especially for SMEs.
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Response to Review of the Construction Products Regulation

11 Jul 2022

FEP – the European Federation of the Parquet industry – is welcoming the long-awaited European Commission (EC) proposal for a revised Construction Products Regulation (CPR), and the possibility to comment it. Please consult our comments in annex.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

FEP – the European Federation of the Parquet industry – is welcoming the Call for Evidence on the “Environmental impact of waste management – revision of EU waste framework” and the possibility to comment it. FEP is supporting the waste hierarchy as set by the EU waste framework, favouring waste prevention over re-use, recycling, other waste recovery options and disposal. The waste hierarchy should give the right place to long-life products, with possibilities of renovation, which are reducing waste per se, and this even before the circularity principle and the cascading use. Furthermore, long-life products can also store carbon when they are made of wood, including recycled wood. Re-use and recycling should be made easier for the operators and end-consumers through sound separation and collection systems. On the other, energy recovery should only take place at the very end of the cascading use of wood when no other solution remains. All the above-mentioned elements should be taken into account to get a waste framework in line with the Green Deal principles of sustainability, efficiency, circularity, decarbonisation, etc.
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Response to Restoring sustainable carbon cycles

4 Oct 2021

FEP – the European Federation of the Parquet industry – is welcoming the Roadmap “Restoring sustainable carbon cycles” and the possibility to comment it. Carbon removals are indeed an important factor to help the EU meeting its Green Deal main objective of carbon neutrality by 2050. Nevertheless, this should be done through a fair, competitive and green transition. And using forests as carbon sinks only, to compensate carbon emissions, could seriously hamper the possibilities of the EU Forest-Based Industries to play their key role in fulfilling the above-mentioned objective. The “European Bioeconomy Policy” has acknowledged that forests and the Forest-Based circular industries play an essential role in our economy and society especially with respect to climate change mitigation and adaptation. It is therefore important to unlock the full potential of forests for our future, especially for extending carbon storage in long-life Harvested Wood Products and for substituting other energy intensive, non-renewable and fossil-based materials for construction, renovation, flooring, and furniture. This is a.o. in line with one of the most important roles of wood products - already set out in the Renovation Wave Strategy and the new European Bauhaus initiative - which is to help turning the construction sector from a source of GHG emissions into a carbon sink. On the other hand, the new EU Forest Strategy imposes additional restrictions on forest use in relation to the Biodiversity Strategy. And the Land Use, Land Use Change & Forestry (LULUCF) part of the Fit for 55 Package is to set an overall target of carbon removals through natural carbon sinks. While the EC has made progress towards the tangible recognition of the positive role played by wood and wood products, its approach is not holistic and this positive development could be limited by artificially constrained wood availability. FEP is thus looking for the sustainable carbon cycles to also consider carbon storage in long-life Harvested Wood Products, as well as the fact that these long-life Harvested Wood Products are substituting energy intensive, non-renewable and fossil-based materials.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and

17 Sept 2021 · Upcoming Russian export ban on logs

Response to European Bioeconomy Policy: Stocktaking and future developments

4 Aug 2021

FEP – the European Federation of the Parquet industry – is welcoming the Roadmap on the “European Bioeconomy Policy: Stocktaking and future developments” and the possibility to comment it. Bioeconomy is indeed an important actor to help the EU meeting its Green Deal main objective of carbon neutrality by 2050 through a fair, competitive and green transition. The “European Bioeconomy Policy” acknowledges that forests and the Forest-Based circular industries play an essential role in our economy and society especially with respect to climate change mitigation and adaptation. It is therefore important to unlock the full potential of forests for our future, especially for extending carbon storage in long-life Harvested Wood Products and for substituting other energy intensive, non-renewable and fossil-based materials for construction, renovation, flooring, and furniture. This is a.o. in line with one of the most important roles of wood products - already set out in the Renovation Wave Strategy and the new European Bauhaus initiative - which is to help turning the construction sector from a source of GHG emissions into a carbon sink. On the other hand, the new EU Forest Strategy imposes additional restrictions on forest use in relation to the Biodiversity Strategy. And the Land Use, Land Use Change & Forestry (LULUCF) part of the Fit for 55 Package is to set an overall target of carbon removals through natural carbon sinks. This could seriously hamper the possibilities of the EU Bioeconomy to fulfil the above-mentioned objectives. In conclusion, the EC has made an additional step towards the tangible recognition of the positive role played by wood and wood products but its approach is not holistic and this positive development could be limited by artificially constrained wood availability. FEP is thus looking for the Bioeconomy Policy to provide with more coherency in this regard.
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Response to Standardisation Strategy

4 Aug 2021

FEP – the European Federation of the Parquet industry – is welcoming the Roadmap on the “Standardisation strategy”. At this occasion, FEP would like to, once again, highlight its expectations regarding the revision of the Construction Products Regulation (CPR). The review of the CPR is a unique moment to address its current weaknesses and ensure that is really supporting a truly functioning Single Market for construction products. While FEP agrees that the CPR and its implementation need to be improved, we consider that it should be done within the actual legal framework. Among the urgent issues to be solved, we would like to pinpoint the non-citation of harmonised standards (hENs) in the Official Journal of the European Union (OJEU) which is halting the work of committed experts from the industry who are dedicating time and resources to this task of utmost importance. It worth noting that the CPR is additionally an important tool to prevent the porosity of the EU market to penetration of products with unverifiable safety, health and environmental claims. The review of the CPR is also a unique opportunity to consider new elements such as sustainability and circularity characteristics, reflecting the EU Green Deal, New Circular Economy Action Plan, and even Renovation Wave initiatives. Integrating these elements into the CPR and the Standardisation strategy will ensure that the design of new and renovated buildings is in line with the needs of circular economy and leads to an increased use of sustainable and climate-friendly materials. This will enable both the building sector and the end-consumers to play further their key role in decarbonising the European economy and society by 2050.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

20 Mar 2021

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Revision of the Energy Performance of Buildings Directive (EPBD) 2010/31/EU” and the possibility to comment it. This initiative is clearly in line with the objectives enshrined in the EU Green Deal and to be applied by, among others, the Renovation Wave. Indeed, the construction sector’s environmental responsibility and sustainability should be at the heart of the implementation of the EU Green Deal and its derived new Circular Economy Action Plan. Additionally, this initiative could help supporting the economic recovery from the still ongoing Covid-19 pandemic. Energy efficiency of the existing building stock and the new buildings is of utmost importance to reach the set target of minus 55% GHG emissions, compared to 1990, by 2030. The revision of the EPBD is giving an opportunity to the building sector to play further its key role in decarbonising the European economy and society. In that context, FEP recommends that the European Commission is considering the following elements during the revision: - The coherency with the EU Green Deal, new Circular Economy Action Plan and derived Renovation Wave initiatives. - The assessment of the environmental and energy performance by categories of buildings, reflecting the results into a minimum Green Public Procurement threshold for sustainable products to boost the use of biogenic carbon storing materials and solutions for better resource and energy efficiency. - The development of an inventory of the existing barriers to the real functioning of the single market for construction products. This would help identifying areas of improvement to consider during the revision of the Construction Products Regulation (CPR) in order to ensure that the design of new and renovated buildings is in line with the needs of circular economy and leads to an increased use of sustainable and climate-friendly materials. - The definition of accurate accounting rules to measure and confirm the substitution effect of using biogenic products instead of carbon-intensive materials in order to extend carbon storage via greater use of natural products and increase the total harvested wood products’ carbon stock in the built environment. Such rules should consider the increased circularity of carbon through removals and storage in wood construction. - The design of new long-term financing mechanisms for renovation aiming at boosting a green Renovation Wave. The renovation of existing buildings using wood products can contribute significantly to a sustainable urban development. It can reduce the transmission heat losses and related heating energy demand of existing buildings significantly. When legally harvested and sourced from sustainable managed forests, wood is the only material that reduces the CO2 emissions, playing an important role to tackle climate change. Moreover, wood products need less energy in their manufacturing process, thus have an environmental impact lower than other materials in their life service cycle. Life cycle analysis of different building materials has demonstrated unequivocally the environmental advantages of wood construction. The small environmental footprint, coupled with wood's renewability, its ability to store sequestered carbon dioxide and its superior insulation properties, make wood the construction material of choice in renovation projects, and new constructions.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Please see the document attached.
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Response to EU Forest Strategy

2 Dec 2020

FEP – the European Federation of the Parquet industry – is welcoming the “EU Forest Strategy” Roadmap. Taking the kindly offered opportunity to comment this Roadmap, FEP would like to make the following remarks to be considered by the EC when drafting the new Strategy: - The new Forest Strategy should be fully coherent with the EU Green Deal, the new Circular Economy Action Plan and the recently derived Renovation Wave initiative. This means that all forest functions should be fairly balanced, allowing wood raw material to be sufficiently available to ensure the carbon storage and substitution role of wood products and their contribution to meeting the EU objective of carbon neutrality by 2050. When legally harvested and sourced from sustainable managed forests, wood is the only material that reduces the CO2 emissions, playing an important role to tackle climate change. Moreover, wood products need less energy in their manufacturing process, thus have an environmental impact lower than other materials in their life service cycle. - The carbon stored (saved) in wood products should be recognized, accounted adequately, and rewarded. - There is a need for a level-playing field for renewable sources, such as wood, whatever their use. - There is a need to develop a monitoring system for the European forests, providing timely information to forecast the impacts of climate change, meteorological accidents, fires, bark beetles, etc. on wood availability.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Amendment of the Land Use, Land Use Change and Forestry Regulation (EU) 2018/841”. Taking the offered opportunity to comment this Impact Assessment, FEP would like to make the following remarks: - The Regulation should be fully coherent with the EU Green Deal, the new Circular Economy Action Plan and the recently derived Renovation Wave initiative. This means that all forest functions should be fairly balanced, allowing wood raw material to be sufficiently available to ensure the carbon storage and substitution role of wood products and their contribution to meeting the EU objective of carbon neutrality by 2050. When legally harvested and sourced from sustainable managed forests, wood is the only material that reduces the CO2 emissions, playing an important role to tackle climate change. Moreover, wood products need less energy in their manufacturing process, thus have an environmental impact lower than other materials in their life service cycle. - There is a need for a level-playing field for renewable sources, such as wood, whatever their use. - The accounting of the carbon stored in wood products whose production is relatively more energy-efficient than other construction materials should be supported by defining accurate accounting rules to measure and confirm the substitution effect of using biogenic products instead of carbon-intensive materials in order to extend carbon storage via greater use of natural products and increase the total harvested wood products’ carbon stock in the built environment. Such rules should consider the increased circularity of carbon through removals and storage in wood construction. As proposed by the new Circular Economy Action Plan, their integration in a “regulatory framework for certification of carbon removals” should be explored.
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Response to Sustainable Products Initiative

13 Nov 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Sustainable Products Initiative”. While this initiative is not directly focused on the products we are representing, we guess that its overarching sustainability principles will concern all sectors at a later stage and thus we would like to express a few remarks on it: - We need harmonized rules and a really functioning Internal Market to ensure a level-playing field throughout the European Union (and beyond). The principles of the “Sustainable Products Initiative”, such as circularity, should be translated in (existing) standards and there is already a platform for doing it: the European Committee for Standardization, CEN (and the International Organization for Standardization (ISO) to go beyond EU borders). More specifically, regarding construction products, it is of utmost importance that the revision of the Construction Products Regulation – CPR – takes swiftly place to allow a smooth standardization procedure and give the possibility to introduce sustainability principles, defined by the present initiative, in existing and new standards. - While circularity is an essential principle to be considered, it should be combined and balanced with the longevity of products which are already designed for having a long-life and which can be renovated (and even revamped) on site several times before being removed and recycled. In view of the EU objective of carbon neutrality by 2050 and to be coherent with other European initiatives, carbon storage in products should also be considered in an adequate way. - Any multiplication of labels should be avoided. A uniformization is necessary to ensure the transparency of green claims. The administrative burden and costs of a potential product passport should also be minimized.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Review of the Directive 2012/27/EU on energy efficiency”. This initiative is clearly in line with the objectives enshrined in the EU Green Deal and to be applied by, among others, the Renovation Wave. Additionally, it could help supporting the economic recovery from the still ongoing Covid-19 pandemic. Energy efficiency of the existing building stock and the new buildings is of utmost importance to reach the recently set target of minus 55% GreenHouse Gases emissions, compared to 1990, by 2030. In that context, FEP recommends that the European Commission is considering the following elements during the review: - The coherency with the EU Green Deal, new Circular Economy Action Plan and derived Renovation Wave initiatives. - A level-playing field for renewable sources, such as wood, whatever their use. - A strong focus on and support to renovation, including through Green Public Procurement. - The accounting of the carbon stored in wood products whose production is relatively more energy-efficient than other construction materials.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Revision of EU Directive 2018/2001 on the promotion of the use of energy from renewable sources”. This initiative is of utmost importance to reach the recently set target of minus 55% GreenHouse Gases emissions, compared to 1990, by 2030 and other objectives enshrined in the EU Green Deal, while supporting the economic recovery from the still ongoing Covid-19 pandemic. In that context, FEP recommends that the European Commission is considering the following elements during the revision: - The coherency with ongoing and related initiatives such as the EU Green Deal, the new Circular Economy Action Plan and the derived Renovation Wave. - The necessity of a level-playing field for raw material wood, whatever its use. - The sustainability of the production of renewable energy, including the consideration of its GHG emissions. - This leads us to the recognition of the carbon stored in wood products whose production is relatively energy-efficient compared to other materials.
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Legislative proposal on substantiating green claims” initiative. This initiative is clearly supporting the recent EU Green Deal, the New Circular Economy Action Plan, and the Renovation Wave for which the European manufacturers of parquet are playing a key role by producing, with a relatively low carbon footprint, and selling products which are sustainable and durable, and store CO2 for a long time. In order to pursue and achieve the Green Deal’s and its derived initiatives’ goals, it is of utmost importance that all environmental claims reflect the reality and are not - and cannot be perceived as - “greenwashing”. In that context, FEP recommends that the European Commission develops a common and unique methodology for the whole European territory to assess the environmental performance of products and which is coherent with its other related initiatives (EcoLabels, taxonomy, etc.). Existing tools such as well-established Environmental Product Declaration (EPD) and Product Environmental Footprint (PEF) methodology are to be considered but need to be revised in order to include circularity principles. More specifically, their revisions should also be considered in the ongoing reviewing process of the Construction Products Regulation (PCR). Additionally, the selected tool(s) to ensure a fair competition and a level-playing field between all products in terms of environmental performance should be easily and fully understandable by the end-consumers, allowing them to chose the real environment-friendly solutions and to play their own role in reaching the Green Deal’s objectives, especially by decarbonising the European economy and society.
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Response to Review of the Construction Products Regulation

18 Aug 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Review of the Construction Products Regulation” (CPR). The review of the CPR will be a unique moment to address its current weaknesses and ensure that is really supporting a truly functioning Single Market for construction products. While FEP agrees that the CPR and its implementation need to be improved, we consider that it should be done within the actual legal framework. Proposed Option A ‘Baseline scenario’ or, to a lesser extent, Option B ‘Repairing the CPR’ should be privileged. On the other hand, Option E ‘Repealing the CPR’ is definitely not an option to be considered. Among the urgent issues to be solved, we would like to pinpoint the non-citation of harmonised standards (hENs) in the Official Journal of the European Union (OJEU) which is halting the work of committed experts from the industry who are dedicating time and resources to this task of utmost importance. It worth noting that the CPR is additionally an important tool to prevent the porosity of the EU market to penetration of products with unverifiable safety, health and environmental claims. The review of the CPR will be also a unique opportunity to consider new elements such as sustainability and circularity characteristics, reflecting the recent EU Green Deal, New Circular Economy Action Plan, and even Renovation Wave initiatives. Integrating these elements into the CPR will ensure that the design of new and renovated buildings is in line with the needs of circular economy and leads to an increased use of sustainable and climate-friendly materials. This will enable both the building sector and the end-consumers to play further their key role in decarbonising the European economy and society by 2050.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

7 Jun 2020

FEP answer to the EC Public Consultation on the Roadmap “A Renovation Wave initiative for public and private buildings” FEP – the European Federation of the Parquet industry – is enthusiastically welcoming the EC Renovation Wave initiative for public and private buildings. The construction sector’s environmental responsibility and sustainability should be at the heart of the implementation of the EU Green Deal and its derived new Circular Economy Action Plan. The Renovation Wave is giving an opportunity to the building sector to play further its key role in decarbonising the European economy and society. In this framework, FEP is calling for the following recommendations to be considered: - Assessing the impacts of renovation approaches, more specifically: o Assessing the environmental and energy performance by categories of buildings, reflecting the results into a minimum Green Public Procurement threshold for sustainable products to boost the use of biogenic carbon storing materials and solutions for better resource and energy efficiency; o Defining accurate accounting rules to measure and confirm the substitution effect of using biogenic products instead of carbon-intensive materials in order to extend carbon storage via greater use of natural products and increase the total harvested wood products’ carbon stock in the built environment. Such rules should consider the increased circularity of carbon through removals and storage in wood construction. As proposed by the new Circular Economy Action Plan, their integration in a “regulatory framework for certification of carbon removals” should be explored. - Developing an inventory of the existing barriers to the real functioning of the single market for construction products. This would help identifying areas of improvement to be considered during the revision of the Construction Products Regulation (CPR) in order to ensure that the design of new and renovated buildings is in line with the needs of circular economy and leads to an increased use of sustainable and climate-friendly materials. - Designing new long-term financing mechanisms for renovation aiming at boosting a green Renovation Wave. The renovation of existing buildings using wood products can contribute significantly to a sustainable urban development. It can reduce the transmission heat losses and related heating energy demand of existing buildings significantly. When legally harvested and sourced from sustainable managed forests, wood is the only material that reduces the CO2 emissions, playing an important role to tackle climate change. Moreover, wood products need less energy in their manufacturing process, thus have an environmental impact lower than other materials in their life service cycle. Life cycle analysis of different building materials has demonstrated unequivocally the environmental advantages of wood construction. The small environmental footprint, coupled with wood's renewability, its ability to store sequestered carbon dioxide and its superior insulation properties, make wood the construction material of choice in renovation projects, and new constructions. FEP is the European Federation of the Parquet Industry based in Brussels. It reunites 50 European Parquet Producers, 22 major Suppliers to the industry and 8 National associations and represents their interests at all relevant levels.
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Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

FEP - the European Federation of the Parquet industry - hopes that the CO2 savings through carbon storage into long-life products the European manufacturers of parquet offer, as well as the sustainable management of forests and the carbon sink they represent, will be fully and tangibly recognised by the EU in the implementation of the recently proposed measures by the EU Green Deal and new Circular Economy Action Plan, including the potential regulatory framework for certification of carbon removals and the EU taxonomy regulation.
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