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EuroWindoor AISBL

EuroWindoor

EuroWindoor, a international non-profit Association, was founded in order to represent the interests of the European window, door and facade (curtain walling) sector.

Lobbying Activity

Response to Classes for resistance to fire

15 Dec 2025

In the last revision of the delegated regulation for defining classes related to resistance to fire performance of construction products a yearlong gap related to fixed windows was closed by adding these to Table 4.1 which originally was for partitions. However, not all of the classes existing for partitions are relevant to windows. Windows, neither openable nor fixed will be intended to withstand impacts arising from the failure of other components or objects exposed to fire and therefore class EI-M will not be relevant for windows. EuroWindoor therefore suggests adding a note to Table 4.1 stating Class EI-M is not applicable for fixed windows. For more details see attrached document.
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Response to Circular Economy Act

6 Nov 2025

EuroWindoor supports the general objectives of improving resource efficiency, facilitating recycling and stimulating demand for circular products in the internal market. However, we would also like to point out that any recommendation or requirement must be chosen with care, taking into account the differing situation of each product group especially in the construction sector with very long-lasting products. For more details see the attached EuroWindoor position.
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Response to Revision of the Standardisation Regulation

15 Jul 2025

EuroWindoor supports maintaining Regulation 1025/2012 as a key component of the EU's New Legislative Framework. Harmonised standards play a crucial role in the EU single market for windows and doors and are essential for implementing the Construction Products Regulation and other EU laws. EuroWindoor emphasizes that harmonised standards, developed by European Standardisation Organisations (ESOs), should remain the primary means of translating legal requirements into technical language. This collaboration between public and private sectors enhances European competitiveness and regulatory efficiency. However, to make the system more agile and competitive, EuroWindoor calls for improvements in the standardisation process. This includes faster and more streamlined procedures, clearer roles and responsibilities, and closer cooperation among CEN, Member States, the industry, and the Commission. Finally, EuroWindoor stresses that sufficient time must be preserved for drafting and reviewing standards to ensure broad stakeholder involvement and high quality. For more details see attached document.
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

The activation of private investment in energy-efficient measures requires a balanced adjustment of the relevant political instruments, especially in the building sector. Plannable regulatory requirements must be dovetailed with a reliable and long-term framework for grants and financial incentives and backed up with market-based measures like the pricing of CO2 emissions. From our point of view, the necessary measures are: - Special tax write-offs for energy-efficient renovation for all groups of owners - Low-interest government renovation loans - Attractive subsidies for energy-efficient renovation - High subsidies for energy consultations and customised renovation roadmaps - Simple, user-friendly processing of the subsidy in a one-stop shop - Accompanying communication and information campaign on the energy and health benefits of energy-efficient buildings. For more details see attached document.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

EuroWindoor lends strong support to EU Regulation 1025/2012 on European standardisation and emphasizes the pivotal role of Harmonized Standards in the New Legislative Framework. EuroWindoor believes that there is a need for improvements and proposes to enhance the standardization process's efficiency and responsiveness, emphasizing the importance of promptly meeting market demands. If EU Regulation 1025/2012 undergoes revision, EuroWindoor recommends defining clear roles, responsibilities, timelines and templates for all stakeholders, ultimately strengthening Europe's fenestration industry's global competitiveness. For more details please see the attached document with the EuroWindoor feedback to Call for Evidence on evaluation of Regulation on European standardisation.
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Response to RoHS exemption for lead and cadmium in recovered polyvinyl chloride in electric doors and windows

24 Jul 2023

EuroWindoor highly supports the Delegated Directive as it aligns the requirements of RoHS with the Commission Regulation (EU) 2023/923 amending Annex XVII to REACH. But there is an important difference. While the expiry date in REACH is set to 28 May 2033 the derogation in RoHS will end on 28 May 2028. Therfore, the Delegated Directive shall state clearly that a renewal of the exemption needs to come into force in 2028 for keeping RoHS aligned with REACH until a new decision will follow the Commission review in 5 years. However, EuroWindoor still believes that it would be both proportionate and appropriate to limit the scope of RoHS to the electrical device of the window/door. EuroWindoor highly recommends to include only electrical devices of construction products like windows and doors in category 11 and not the complete product as such. If the scope of RoHS will be limited to electrical devices of construction products, the Delegated Directive with the exemption would no longer be needed. This should be clarified at least before the re-evaluation of the exemption in 2028 to increase legal certainty and avoid further exhaust of resources. For more details please see the attached document with the EuroWindoor feedback on the draft RoHS Exemption for PVC windows and doors.
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Response to Action plan on accelerating Heat Pump market and deployment

26 May 2023

EuroWindoor acknowledges that heat pumps are an important part of the energy transition in the building sector but they are not the solution for everything. Heat pumps are not an option for many existing buildings and the building sector needs a balanced approach between efficiency of building envelope and use of renewable energy. A specialized technology initiative for the heat pump is therefore not beneficial. What is needed is an action plan remaining open to technology und focusing on a balanced approach that generates low energy demand and use of renewables in equal measures to make decarbonisation a success. Please have a look to the attached document for more details.
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

EuroWindoor would like to underline the importance of having requirements on intermediary products such as aluminium, plastic, glass etc. to accelerate data availability throughout the value chains. Data availability and data quality is not sufficiently mature in many cases, why a push in this regard is needed to enable reliable and robust data on product level. For the complete EuroWindoor feedback see the attached document.
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Response to Review of the Construction Products Regulation

28 Jun 2022

EuroWindoor appreciates the opportunity to give feedback to the proposal from the European Commission for a new regulation replacing the CPR. EuroWindoor is a firm supporter of the concept of the single European market for construction products and sees the EU CPR as the main instrument to obtain a well-functioning internal market. General Comment: EuroWindoor welcomes the outspoken aim to strengthen a smooth functioning of the single market for construction products based - as the main route - on harmonised standards as the instrument for technical language and harmonised assessment methods. We also support the increased focus on a level playing field, expressed among others through increased focus on the functioning of the market surveillance and of the Notified Bodies. The inclusion of sustainability is furthermore appreciated by EuroWindoor. However, we also consider that many aspects of the draft CPR are too complicated and many areas are too open for interpretation. The complicated structure of the regulation and referencing between different articles make it difficult to read and understand, which may cause huge problems for implementation by manufacturers. This does to some extend make it difficult to give concrete input to all specific articles, as the consequence of them depends in a high degree on the practical implementation. Additionally there are numerous places where the Commission is empowered to develop delegated acts. EuroWindoor fully recognize that, if the Commission had this power under the current CPR, some of the identified problems could have been handled without starting a revision process. However, EuroWindoor believes this option to deliver delegated acts needs to be used with great care, as it does introduce a high degree of uncertainty and risk especially for the economic operators who will need to comply to an ever-changing ruleset. Please have a look to the attached document with the detailed EuroWindoor feedback in the following structure: 1 General comment 2 Broadening of the scope of regulation leads to over-regulation 3 New definitions “construction products” and “product types” (Article 3) 4 Essential characteristics of products (Article 4) 5 Modified DoP for used, remanufactured and surplus products (Article 12) 6 Obligations of all economic operators (Article 19) and Obligation of manufacturers (Article 21) 7 Additional environmental obligations of manufacturers (Article 22) 8 Declaration of environmental characteristics (Annex I Part A 2) 9 Product information requirements (Annex I Part D) 10 Committee on Construction Products (Article 88) 11 Assessment and verification system (Annex V) 12 Simplified Procedures (Chapter VII) 13 Transition to new CPR (Art. 93)
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Response to Sustainable Products Initiative

21 Jun 2022

EuroWindoor appreciates the opportunity to give feedback to the ESPR consultation und supports the aim of making sustainable products the norm while at the same time strengthening a level playing field with a fair and smooth functioning internal market. EuroWindoor would however like to stress the importance of ensuring a close coordination and alignment between the ESPR and those other legislative initiatives under development/revision all affecting the building sector (e.g. CPR, EED, EPBD, ...). Overlapping’s should be avoided, e.g. for information requirements related to the Digital Product Passport (DPP). To avoid unnecessary costs and burdens associated with requirements on products and their value chain EuroWindoor would like to underline the importance of involving all relevant actors – including industry and Member States in the development and implementation of such product specific regulations. It is fundamental that requirements will be based on scientific assessment methods through recognised European and International standards that are reliable and verifiable. For construction products this means specifically that it is essential to have continued focus on the assessment of the performance of construction products at building level from cradle to grave, as in EN 15804. For the same reason EuroWindoor does not support classes of performance labels (traffic light) on construction products as a product itself may be environmentally superior but at the same time it may in the operation and building context be inferior. Such a label could therefore easily be misleading which is the same with benchmarking on simple environmental aspects such as recycled content. For more details, please have a look to the attached document with the full EuroWindoor feedback.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

29 Mar 2022

EuroWindoor welcomes the opportunity to provide feedback on the proposed revision of the EPBD. We need an ambitious EPBD revision to enable the green transition of the European building stock and create more sustainable and healthier living conditions for all Europeans. This will require a close alignment with the Energy Efficiency First Principle and other relevant files from the Fit for 55 Package. The energy renovation of buildings is a key European flagship for national recovery plans with significant amounts being invested in buildings in the coming months and years, also as part of the Renovation Wave. We therefore support the broadened scope and strengthened exemplary role of public buildings. With the EPBD revision there is the opportunity to ensure that these investments will lead to energy efficient, decarbonised and healthy buildings, by setting the right legislative framework. To do this, there is a need to introduce a more holistic approach to buildings, moving beyond energy performance requirements to address all building parameters, i.e. energy, environment and health. EuroWindoor therefore very much welcomes the new provisions in the EPBD revision to better factor in health, comfort and indoor air quality (IAQ) as well as the proposal to expand the scope by including a CO2 emission reduction dimension. However, the revision of EPBD needs to be improved to deliver the full potential of the multiple benefits of energy efficiency and to comply with relevant technical progress. For the upcoming negotiations, it will be critical to focus on: I. Strengthening the new definition for zero-emission buildings II. Ensuring a Healthy Indoor Climate for all Europeans III. Factoring in the energy balance principle for window products IV. Further boost the renovation wave as part of national building renovation plans and taking Energy Efficiency First principle into account for MEPS Please have a look to the attached EuroWindoor feedback for more detailed information and explanation.
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Response to Review: Restriction of the use of hazardous substances in electronics

11 Mar 2022

EuroWindoor appreciates the opportunity to give feedback during the call for evidence supporting the review of Directive 2011/65/EU of RoHS. As mentioned in “the call for evidence” there is a range of issues with the practical operation of the Directive and the surrounding systems especially for construction products like windows, doors and facades with electrical devices in category 11 (“Other EEE not covered by any of the categories”). EuroWindoor proposes for a recast of RoHS that electrical devices attached to windows, doors and facades shall be regulated by RoHS, but not the construction product itself which is covered sufficiently by CPR (2011/305/EU) and REACH (2006/1907/EC). That would lessen the administrative burdens and bring the consistency within the EU regulations. Please find attached the EuroWindoor feedback with more detailed information.
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

EuroWindoor welcomes the adoption of the European Commission proposal to revise the Energy Efficiency Directive on 16 July 2021 and appreciates the opportunity to provide feedback to feed into the legislative debate. The EuroWindoor feedback is summarised as follows: In the upcoming negotiations, we call on the EU Institutions to: i. keep the strong legal basis for the EE1 Principle and the exemplary role of the public sector; ii. work for adoption of a binding Energy Efficiency target of 39%-41% reduction for primary energy consumption at EU level (compared to projections made in 2007 for energy use in 2030); iii. encourage member states to make national targets and specific strategic plans, prioritized to perform the most cost-effective actions at country level which may include sector-specific targets and measures; iv. ensure close alignment with the upcoming EPBD revision to ensure they are fully complimentary. For details of the EuroWindoor feedback, please look into the attached document. EuroWindoor would highly appreciate the Commission to consider our feedback and we remain available for further discussions.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

EuroWindoor appreciates the opportunity to provide feedback to the inception impact assessment on the revision of REACH Regulation. The small and medium sized companies of the European window, door and façade sector are downstream users at the end of a long supply chain and far away from the chemical industry. So, we would like to give some thoughts about the difficult situation of our sector which should be additionally considered for the revision of the REACH regulation. EuroWindoor believes REACH generally works well within the areas of substances and mixtures, but improvements could be needed, when it comes to communication in the supply chain on articles. The regulation is within our sector including entire supply chain perceived as technical difficult and complex, especially among the many SMEs within this sector. Please have a look to the attached document with EuroWindoor's input.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

18 Mar 2021

EuroWindoor welcomes the opportunity to comment on the Inception Impact Assessment on the Revision of the EPBD in the attached document. We believe that the upcoming revision is an opportunity to secure the introduction or the update of a coherent set of measures that will enable the green transition and benefit all Europeans. Key components of a strengthened EPBD are: • The phased introduction of mandatory Minimum Energy Performance Standards (MEPS) for all building types to secure that ambitious national renovation objectives are met. • An improved framework for Energy Performance Certificates, especially the inclusion of additional information, to ensure that key renovation triggers are harnessed, and that essential information on wider benefits of energy renovations, e.g. health and comfort is available for all Europeans. • The introduction of stricter requirements for all Public Buildings to secure that not only the quantity (as addressed by Article 5 of the EED for buildings owned and occupied by central governments), but also the quality of energy renovations is addressed. • A stronger focus on minimum requirements for Indoor Environmental Quality (IEQ) by addressing health and comfort (Daylight, Air Quality, Summer Comfort…) in NZEB definitions to secure the long-term resilience of the European Building stock and align design criteria with the needs of end-users. For more details see ther attached document.
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

EuroWindoor appreciates the opportunity to provide feedback to the consultation on the Sustainable finance – EU classification system for green investments. We would like to give feedback to the screening criteria for windows and doors in the draft delegated regulation on a classification system for sustainable economic activities (‘taxonomy’). In the attached document the following is explained in detail: - The U-value does not represent sufficiently the energy efficiency of glazed products - Products with very low U-values are not necessarily environmentally friendly - The screening criteria for windows and doors do exclude many regions from Taxonomy - Doors play a negligible role in the efficiency of the building - EuroWindoor suggestion to modify the technical screening criteria for windows and doors EuroWindoor would highly appreciate the Commission to consider our contribution and remain available to further discuss these screening criteria to secure the efficient implementation of climate mitigation policies.
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Response to Environmental claims based on environmental footprint methods

27 Aug 2020

EuroWindoor support to have one harmonized European method of making green claims. For construction products the CEN/TC350 suite of standards (EN 15804, EN 15978 etc.), aligned to PEF methodology, should be preferred with the arguments that: 1) the systems of EPDs for construction products and building evaluations are already somewhat well established 2) intermediate (construction) products and the final building as the end-user product is methodologically a special case not fitting perfectly into the PEF method
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Response to Review of the Construction Products Regulation

19 Aug 2020

EuroWindoor believes CPR in present format is overall well-functioning and therefore we are leaning towards Option A – Baseline scenario as defined as Option I in 2018. EuroWindoor is of the opinion that the insufficient quality of harmonized standards highlighted in the impact assessment is due to the fact that those standards being evaluated by the Commission now have been written before new guidance on requirements resulting from James-Elliott case have been provided. A revision of the CPR is not necessary to remedy this situation. This can be done by guidance and soft law. All EuroWindoor arguments are shown more detailed in the attached document
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Response to Establishment of a smart readiness indicator for buildings

6 Jul 2020

Although EuroWindoor supports the principle of SRIs and especially the possibility to promote the quality of a building’s design, we believe that the classes used for SRIs (defined in Tables 12 to 16 of the Second progress report) are missing some key performance evaluation. For example: - Regarding lighting, the only option to improve the score of SRIs is the use of control systems (presence detectors, diming according to light levels etc…) without considering the actual daylight conditions of the building which is the most important criteria to make smart control systems efficient. A smart control system in a poorly daylit building would indeed have a very limited impact, especially dimming systems. Furthermore daylight aspects should also cover the quality of light, like access to sunlight, view to the outside and control of glare. - Regarding Dynamic Envelop, passive cooling systems like e.g. ventilative cooling through windows are not promoted unless they are connected to heating and cooling systems. Therefore, the comfort to prevent from overheating provided by appropriate night cooling cannot be promoted unless an active cooling system is present in the building. As a general comment, we believe that the health and comfort aspects – which was clearly reflected in the different SRI categories – is not effectively reflected in the evaluation method and in the classes defined. We recommend to adjust the classes (“functionality levels”) in order to promote building designs that will enable the use of control system and optimize their efficiency. We also recommend to revise the default Impact Weightings in order to make the Comfort of building users better reflected in the final score. The Comfort Indicator today has an Impact Weighting of only 8% in all building configurations (regardless of their typology or their location), which is in contradiction with user demands towards more healthy and comfortable buildings.
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Response to Implementation modalities of the smart readiness indicator for buildings

6 Jul 2020

Although EuroWindoor supports the principle of SRIs and especially the possibility to promote the quality of a building’s design, we believe that the classes used for SRIs (defined in Tables 12 to 16 of the Second progress report) are missing some key performance evaluation. For example: - Regarding lighting, the only option to improve the score of SRIs is the use of control systems (presence detectors, diming according to light levels etc…) without considering the actual daylight conditions of the building which is the most important criteria to make smart control systems efficient. A smart control system in a poorly daylit building would indeed have a very limited impact, especially dimming systems. Furthermore daylight aspects should also cover the quality of light, like access to sunlight, view to the outside and control of glare. - Regarding Dynamic Envelop, passive cooling systems like e.g. ventilative cooling through windows are not promoted unless they are connected to heating and cooling systems. Therefore, the comfort to prevent from overheating provided by appropriate night cooling cannot be promoted unless an active cooling system is present in the building. As a general comment, we believe that the health and comfort aspects – which was clearly reflected in the different SRI categories – is not effectively reflected in the evaluation method and in the classes defined. We recommend to adjust the classes (“functionality levels”) in order to promote building designs that will enable the use of control system and optimize their efficiency. We also recommend to revise the default Impact Weightings in order to make the Comfort of building users better reflected in the final score. The Comfort Indicator today has an Impact Weighting of only 8% in all building configurations (regardless of their typology or their location), which is in contradiction with user demands towards more healthy and comfortable buildings.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

Modern trends in construction go towards ensuring three basic principles (i) health and comfort, (ii) energy efficiency and (iii) environment. It is important to keep on mind a holistic approach to building design which can help create healthier and more comfortable lives for occupants without negative impact on the climate – moving us towards a cleaner, healthier and safer living. This should be the case for renovations as well. We fully support the Initiative and its aim. But the Renovation Wave Initiative represents unique opportunity how to improve not only energy efficiency but also health and life quality of the occupants. And what we are missing in the strategy is the greater emphasis on the quality of the indoor environment and health. We believe that it will be a continuation of the trend set in EPBD III and thus, the European Commission should focus on the holistic approach and inspire the Member States accordingly. Focus on daylight, indoor climate aspects and a dynamic building envelope is important to ensure that European citizens live and work in healthier buildings. Increasing energy efficiency in buildings should and can go hand in hand with good daylight conditions and a healthy indoor environment, but only if proper attention is paid to this when setting requirements. So far Member States have implemented daylight and indoor climate comfort requirements very differently, and in most cases to a very little extent. Energy efficiency gains during summer and winter can be further achieved by e.g. optimizing the envelope of the building with dynamic products like smart windows and solar protection products – possibly automatized, which takes full account of the needs of the user in the specific heating and cooling context. Sensor driven systems can promote the energy efficiency. Additionally we like to address the importance of Building Automation and Control Systems (BACS), including products like Smart windows, Smart doors or Smart blinds & shutters. These products are integrated into the building management system in a wide variety of ways, some of which are also operated as stand-alone actuators. The function of our products is of key relevance to reduce building energy consumption by changing the performance of the building shell when needed, e.g. by controlling solar gains for reducing heating or cooling energy, by allowing natural ventilation and night cooling to reduce the potential need for air-conditioning etc.
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Response to Revision of the Machinery Directive

11 Feb 2019

Dear Sir or Madam, Thank you very much for the opportunity to give feedback to the inception impact assessment on revision of the Machinery Directive. EuroWindoor suggests option 2. Please find attached the detailed feedback of EuroWindoor AISBL. Best regards Frank Koos EuroWindoor AISBL General Secretariat Schuman Business Center 40, Rue Breydel 1040 Bruxelles / Belgium Phone: +32 (2) 502 3396 GS@eurowindoor.eu www.eurowindoor.eu Direct connexion: Walter-Kolb-Str. 1-7 60594 Frankfurt (Main) / Germany Phone +49 (69) 955054 - 36 Fax +49 (69) 955054 - 11 GS@eurowindoor.eu EU Transparency Register ID Number: 29749561729-18
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Response to Restriction of hazardous substances - evaluation

12 Oct 2018

EuroWindoor appreciates the opportunity to give feedback to the evaluation of restrictions included in the RoHS Directive 2011/65/EU. EuroWindoor represent the interest of the European window, door and façade sector and has in this role previously provided input for a study initiated by the European Commission to analyse the impact on the industry when windows and doors with electrical function becomes part of the scope of RoHS legislation from July 2019. In the study it is assumed that windows or doors become an electrical/electronic equipment, if an electrical device is included when placed on the marked. This point of view is based on the RoHS-FAQ from the European Commission only. EuroWindoor supports the approach of RoHS for electrical devices, but does not see a need to extend the scope to the complete construction product. Windows and doors are sometimes placed on the marked including an electrical device, but more often the electrical device is amended later to the construction product, probably by a different company. Therefore EuroWindoor can still not agree to the conclusion and recommendation of the report and our argumentation to support this is still the same (see attached EuroWindoor position paper “RoHS II Directive - Study for impacts from RoHS2 on windows and doors with electric functions” dated July 1st, 2015). EuroWindoor still believes that it would be both proportionate and appropriate to limit the scope to the electrical device of the window/door, something that could be done by clarifying the definition of large scale fixed installations. Windows and doors are normally assembled and installed by professionals and will stay in the building for 40+ years whereas an electrical device itself typically will be replaced 2 to 3 times during this period. This is partly due to shorter expected life time for these components but maybe more importantly due to high innovation rate in development of new and smarter solutions that can be an integrated part of smart buildings.
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