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European PVC Window Profiles and related Building Products Association

EPPA

EPPA is the trade association of European PVC-U window system companies, related national associations and component manufacturers.

Lobbying Activity

Response to Evaluation of EU Rules of Origin

2 Dec 2025

EPPA AISBL, representing the European PVC profiles and related building products sector, welcomes the European Commissions ongoing evaluation of the EU rules of origin.
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Response to Circular Economy Act

24 Oct 2025

To whom it may concern, Attached please find EPPAs feedback on the Circular Economy Act. Should you require any clarifications on the matter, please feel free to get in touch. Best regards, Elena Vyboldina on behalf of the European PVC Window Profile and Related Building Products Association (EPPA)
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Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

22 Sept 2025 · Housing, energy performance of buildings.

Response to European strategy for housing construction

16 Sept 2025

EPPA, representing Europes PVC window profile industry, highlights the role of PVC windows in delivering affordable, energy-efficient and circular housing solutions. The sector employs 25,000 people, generates 4 billion turnover, and has a mature recycling system. EPPA proposes six measures: a 2 billion EIB Windows First facility, renovation earmarks in the Affordable Housing Plan, simplified and standardised State-aid rules, mandatory closed-loop collection of old windows, and a Green Skills Pact to train installers and recyclers. These actions target key barriers such as financing, skills shortages, and secondary material flows. They will lower costs for tenants, improve building efficiency, and strengthen the EUs recycling value chain. EPPA offers technical expertise and support for pilot projects to ensure successful implementation of the European Strategy for Housing Construction.
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Response to Measures to reduce microplastic pollution

29 Dec 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment, and public affairs. EPPA welcomes the opportunity to comment in the on-going public consultation and would like to share the enclosed comments and information.
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Response to RoHS exemption for lead and cadmium in recovered polyvinyl chloride in electric doors and windows

24 Jul 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment, and public affairs. EPPA welcomes the opportunity to comment on the draft RoHS exemption for lead and cadmium in recovered PVC in electric doors and windows. As co-applicants for this exemption in 2015, we appreciate the proposal and would like to share the enclosed comments with regard to process and content.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

20 Jul 2023 · Energy efficiency potential and related regulatory initiatives

Response to Action plan on accelerating Heat Pump market and deployment

26 May 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment, and public affairs. EPPA welcomes the opportunity to comment on the call for evidence on the heat pump action plan. We observe that this initiative is not based on a thorough impact assessment and consider this lack of assessment as one cause for the ill-suited prioritization of heat pumps in Europe, although science and legislation1 clearly demand the prioritization of energy-efficient refurbishment. In this regard, we invite you to consider the enclosed feedback and proposals.
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Response to Initiative on EU taxonomy - environmental objective

28 Apr 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. We welcome the opportunity to provide feedback in the course of the revision of the Energy Performance of Buildings Directive, which we consider a key pillar of the work towards climate neutrality by 2050. EPPA welcomes the opportunity to comment on the draft delegated act concerning EU Taxonomy criteria for economic activities making a substantial contribution to one or more of the following environmental objectives: sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control and protection and restoration of biodiversity and ecosystem. Please find our feedack in the enclosed document.
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Response to Ecodesign for Sustainable Products - Product priorities

28 Apr 2023

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of 4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. EPPA welcomes the opportunity to comment on the new product priorities for Ecodesign for Sustainable Products. Please find our feedback enclosed.
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Response to Review of the Construction Products Regulation

12 Jul 2022

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. We welcome the opportunity to provide feedback in the course of the profound revision of the Construction Products Regulation. Please see our feedback enclosed.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1,4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. We welcome the opportunity to provide feedback in the course of the revision of the Energy Performance of Buildings Directive, which we consider a key pillar of the work towards climate neutrality by 2050. Please see our feedback enclosed.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1, 4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. Plastics Recyclers Europe (PRE) is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high-quality material destined for the production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy. Plastics recycling in Europe is a rapidly growing sector representing €3bn in turnover. We welcome the opportunity to provide evidence in the RoHS revision process throughout the upcoming months. The complex value chain is currently confronted with a mismatching legislative framework, which leads to a distortion of the European market. With a pending exemption request since 2015 and an in-parallel REACH restriction process on the same substance (Pb), the undersigned associations strongly believe that RoHS should be revised to prevent legislative overlap and contradiction between the above and other legislative instruments (such as the Construction Products Regulation) covering the same content relating to PVC window systems. With regard to the ongoing call for evidence and the therein-presented options, we would like to provide the enclosed comments. The undersigned associations would like to offer a more in-depth dialogue on the technical and socio-economic dimension of PVC window systems in the European market and are looking forward to a more targeted consultation.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1, 4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products. Based in Brussels, EPPA provides a common platform for bundling national activities in the fields of PVC window technology, recycling, environment and public affairs. Please see enclosed our feedback.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

26 Jan 2021 · Chemicals

Response to Review of the Construction Products Regulation

14 Aug 2020

The CPR plays a vital role in the window industry, considering the fact that window profiles are construc-tion products with a long-lifecycle that are manufactured by European companies, acting across national borders on the European market. Therefore, EPPA is committed to a Europe-wide harmonization of tech-nical and environmental requirements for construction products.For the windows industry CPR is a core document, however current European harmonized standards are considered to be outdated, therefore it is essential to develop new standards on the European level. EPPA recognizes the key role of the industry experts in the standardization process, who should be fully involved in the development of standardization requests for each product family, to ensure requirements are devel-oped with a high degree of expert knowledge and full commitment of the industry. In addition to CPR, window profile manufacturers must also comply with the requirements of REACH, the Classification and Labelling of Products Directive (CLP), RoHS and others. EPPA members believe that all legal requirements relevant to their products should ideally be contained in a single piece of legislation to reduce administra-tive burden and increase legal certainty. The Construction Products Regulation with its Basic Work Re-quirements is in a position to cover all these legislative requirements currently scattered across multiple other legal instruments, partially overlapping and contradicting each other. The construction products sector plays a key role in the environmental performance of buildings and infra-structure throughout their lifecycle. Including sustainability considerations in the objectives and mecha-nisms of the CPR, as announced in the European Green Deal and the new Circular Economy Action Plan, would facilitate the transition to a more innovative and sustainable European construction sector. To this end a comprehensive environmental impact assessment system has to be recognized as a basis for increas-ing sustainability of construction products and contribute to the sustainability of construction works. This system needs to be aligned with horizontal policies, whilst covering the sector specific needs at the level of the environmental assessment of buildings and other construction works. Today, EPDs based on EN 15804 fulfill all the pre-requisites to become the legally established assessment system across Europe. EPPA as a member of Circular Plastics Alliance it is committed to increase recycling of plastics, to use its own recyclates in the new window profiles and to contribute to the overall 10 million tones objective set by the Commission for the plastic industry. EPPA calls for smart and safe management of secondary raw materials that contain legacy substances. It is vital that any new or modified EU legislation does not intro-duce barriers to the recycling of plastics material, which has been shown to be safe to recycle. A solution needs to be found, which ensures that exposure to hazardous substances is managed within recognized limits of safety and enables existing recyclers operators to continue to operate. To sum up, regarding the proposed policy options, we are not in favor of major changes in the CPR and definitely reject the option of repealing this Regulation. EPPA supports the intention to “materialize the commitments of the European Green Deal and the Circular Economy Action Plan”. EPPA also believes that CEN and the European Commission should improve their communication to facilitate the standard devel-opment and reinforce CEN’s position.
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Response to RoHS exemption for cadmium and lead in electrical and electronic windows and doors containing recovered PVC

30 Sept 2019

The restriction and its derogation We do not agree with the fact that RoHS II is applicable to windows . As construction products win-dows are already covered by the Construction Products Regulation (CPR) and furthermore by REACH and CLP. In line with the CPR the release of dangerous substances is regulated under basic work re-quirement number 3. REACH and CLP cover all content-related matters with regard to substances in articles. Additional legislation under RoHS II is therefore doubling legislative actions, potentially leading to legal uncertainty. In this context we also underline that windows were not meant to be in scope of this Di-rective according to the impact assessment of the Commission preparing the revision of the instru-ment. It was at a later stage of the legislative process that the scope was widened by introducing the catch all category 11 “other EEE not covered by any of the categories above” into Annex I. We therefore stress the fact that RoHS II should not be applicable to windows since its objectives are already covered by existing legislation. This should be corrected in the upcoming revision by explicitly excluding windows (or construction products in general) from the scope of the Directive. The values The proposed values of 0,1 % for Cadmium and 2% for lead are accepted by our industry. They are in line with the in force (cd) and proposed (pb) values under REACH. They will enable the profile industry to continuously recycle and use old PVC windows in the future. Thereby, this derogation is key if EPPA wants to live up to its commitment as a VinylPlus member and as a signatory of the European Circular Plastics Alliance. In this context, the PVC industry is committed to recycle and use 900.000 tons of PVC by 2025 and 1 mio. tons by 2030. EPPA’s members account for 45 % of this goal and they can only achieve it if pb as present in old windows remains permitted (at least at levels below 2%). Lower thresholds would effectively prohibit the industry from using recyclate from post-consumer waste. The labelling requirement PVC profile producers already mark their products as containing recycled PVC. According to EN12608-1 they mark profiles as “contains RMa”. RMa stands for “recycled material category a” which refers to used rigid PVC products of a quality suitable for use in windows. This obligation does therefore not constitute an additional burden. The validity of the exemption The Delegated Directive as proposed is valid for only 2 years. The reason provided by the Commission is that this should ensure a swift alignment to legislation under REACH. EPPA, EuroWindoor, VinylPlus and EuPC are not in favour of such a short validity period for two rea-sons. First, it does not provide any planning security. Profile producers invest in the necessary machines and tools allowing them to work with recyclate. The so called co-extrusion process where recyclate is ex-truded into the core of a virgin layer requires special equipment that also needs to be maintained. If producers cannot be sure that they can still use these tools and the material in two years from now, they are indeed incentivized to phase out these machines now and to be ready to only use virgin ma-terial afterwards. Second, the justification provided does not apply. The exemption proposed is in line with the deroga-tion to the lead restriction proposed under REACH legislation. The latter has a proposed length of 15 years. By then it can be expected that peak levels of lead in recyclate are reached as the largest share of old windows containing lead will have been dismantled. As of then lower thresholds may be suffi-cient. We therefore ask the Commission to revise the draft and to increase the validity period to 15 years. European PVC Window Profile and Related Building Products Association│ EPPA ivzw EuroWindoor AISBL European Plastics Converters | EuPC VinylPlus
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Response to Restriction of hazardous substances - evaluation

9 Oct 2018

We understand and support the need of the RoHS Directive aiming to restrict hazardous substances in EEE, in particular to avoid adverse effects when it comes to dismantle such products for EoL reasons. PVC windows may be subject to RoHS, when they are equipped with electric devices such as cables, drives etc. In the context of “smart home” technologies this is increasingly the case and can produce problems if PVC profiles contain recycled PVC. Recycled PVC may contain parts of lead and cadmium stabilizers deriving from the past. In particular the content of lead stabilizers can exceed RoHS thresholds of 0.1 % w/w, whereas the waste framework directive WFD defines a threshold of 0.3%. Regarding REACH, there is a proposal to restrict the content to 0,1% with a derogation for rigid PVC in certain applications (such as window profiles) allowing for a content of up to 2%. Given the fact that PVC windows are recycled in a controlled loop since 25 years and can be seen as a reference for both a circular economy and the EU plastics strategy (increasing the use of recycled plastics and hence recycling), the not existing coherence of above regulatory frameworks needs to be aligned in order to strongly promote plastics recycling under controlled loop conditions. It is a matter of common knowledge that lead and/or cadmium stabilizers are embedded in the polymer matrix and hence not bio-available. In addition to that in most cases electric devices can be easily removed and seperated from used PVC window frames.
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