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Federation of European Rigid Polyurethane Foam Associations

PU Europe

PU Europe represents the polyurethane (PUR/PIR) insulation industry in Europe.

Lobbying Activity

Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

19 Aug 2025

PU Europe represents the European polyurethane (PUR/PIR) insulation industry, covering factory-produced and in-situ formed PU foam. With over 110 manufacturing sites and more than 20,000 direct jobs including raw material suppliers, the sector contributes significantly to reducing building-related CO emissions and supporting the EU economy. The Commissions draft proposal on mass balance accounting, while focused on PET bottles, establishes the EUs first regulatory framework in this area and will influence other plastics, including thermosets. PU Europe welcomes key features, including clear application conditions when real proportions are unknown, a defined reporting period, and workable reallocation provisions (Article 7.5). Areas for improvement: - Broaden eligible feedstocks: Include both recycled and bio-based inputs to support full defossilisation. - Clarify polymer definition (Art. 7.5(c)): Ensure reallocation is possible for polymeric intermediates to avoid unintended barriers. - Safeguard chemical recycling: Legally recognise the Fuel Use Excluded (FUE) model. - Reduce administrative burdens: Apply mass balance at operator/site level with conversion factors covering all inputs and losses. - Ensure international consistency: Align definitions with ISO 22095 to allow replication across sectors. Although not directly in scope, PU Europe regards this proposal as a milestone for EU mass balance accounting and urges the Commission to secure practical, scalable, and internationally consistent rules. PU Europe stands ready to provide further expertise and engage constructively as the legislative process advances. -- A more detailed position is provided in the attached document --
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Response to Revision of the Standardisation Regulation

18 Jul 2025

PU Europe is the European voice of the polyurethane (PUR/PIR) insulation industry from construction products manufactured in factories to in-situ formed PU foam. The high performance products delivered by more than 110 manufacturing sites, and more than 20,000 direct jobs when accounting the raw material suppliers, are critical to tackle the carbon footprint of buildings which are responsible for around 36% of the CO2 emissions of the European Union, as well as for reducing the buildings operating costs and supporting our economy. For decades, our industry and the Association have invested resources and time to support the achievements of a European internal market. To date, our Association is active in a number of CEN Technical Committees (TC 88, 127, 350 & 351) working on harmonised standards cited by the European Commission and relied on by manufacturers for the placing on the market of their products (under the Construction Products framework). Our industry would like to share the following comments, as the EC services prepare for a review of the regulation: In the construction sector, hENs and EADs developed by CEN and EOTA are basically the sole route to the internal market. This is therefore of critical importance for the industry that the standardisation regulation fully takes into account industry concerns and priorities; In this context, it is essential that the European Commission provides stronger and more timely guidance to the industry when drafting harmonised standards in order to ensure swifter citation; In addition, the European Commission could also proactively offer guidance on how to apply and implement harmonized standards in practice for those hENs that require more clarity on how to apply them (and also because of technical or regulatory developments that would render the implementation of certain parts of the published hENs difficult); Due to a highly competitive market place in Europe, the number of experts in companies is decreasing and their availability for lengthy and time consuming standardisation activities is getting challenged. Today, the experts engaging in CEN work contribute to the common good of their entire sector without any form of acknowledgment nor reward. In addition, over the last decade, more and more industries have moved to relying on consultants, hired by their European trade association, to engage at CEN level; Concerning the direction of travel taken years ago to increase reliance on ISO standards over CEN ones whenever possible, it is critical to highlight that the drafting and validation processes are not under the EU control. As indicated earlier, the limited number of European experts are focusing on CEN activities and have therefore difficulties to follow and engage in ISO ones. It is important to recognize that certain large non-EU economies support their national experts in ISO in order to develop standards aligned with their political goals, which could include industrial policy support; With regards to the possibility of making accessible hENs to all stakeholders who need them, we would strongly recommend, as a first and fair step, to make freely accessible the standards to organisations which have provided the experts for their drafting; Furthermore, in addition to the three standardisation bodies listed in the 2012 Regulation, the European Commission and legislators should be able to confer specific power to other organisations, such as those listed as liaison bodies within CEN and registered under the lobbying registered, for drafting hENs/hTSs on well-defined products/issues. Best regards Arnaud Duvielguerbigny, Secretary General
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

PU Europe is the European voice of the polyurethane (PUR/PIR) insulation industry from construction products manufactured in factories to in-situ formed PU foam. The high performance products delivered by more than 110 manufacturing sites, and more than 20,000 direct jobs when accounting the raw material suppliers, are critical to tackle the carbon footprint of buildings which are responsible for around 36% of the CO2 emissions of the European Union, as well as for reducing the buildings operating costs and supporting our economy. While our Associations activities focus on the legislative framework and the enabling technical rules for PU construction products, our members are downstream users of chemicals and would therefore like to raise the following comments on the forthcoming IDA Act: First of all, we would like to remind EU decision-makers that the focus of this Act should not come at the expense of other environmental objectives such as water usage, NOx emissions, fine particulates or circular economy goals. While the fight against climate change is undisputed, other policy objectives should not be negatively impacted by a narrow focus on greenhouse gas (GHG) emissions. With regard to GHG emissions related to industries: o we would like to emphasise that this initiative focuses on GHG emissions, and it is important to distinguish between carbon contained in chemicals/products and carbon released to the atmosphere during production processes; o Life cycle assessments (LCAs) of finished products do inform on whether the emissions are related mainly to the upstream or the downstream part. In addition, while energy related GHG emissions can be cut by a move towards decarbonised energy sources (when available a competitive price), the case of carbon contained in the chemicals/products does require a more elaborated approach. o For polymeric materials such as PUR/PIR (low level of GHG during the product manufacturing process - lightweight compared to competing materials), the majority of the GHG emissions are linked to the upstream phase, i.e. the production of chemicals and the carbon contained in those substances. The latter remains stored throughout the long service life of the insulation materials (50 years+) and can be retained even longer through reuse or put back to use via recycling. o In addition to facilitating the transition to low carbon energy sources, it is necessary to support the chemical industry in transitioning away from an economy fully reliant on fossil monomers. Effective tools to encourage the use of alternative raw materials (recycled or biomass based) are necessary. To enable that transition in a gradual and cost effective way, European methodologies are needed that set up rules on chain of custody models , particularly mass balance, which enable the attribution of alternative feedstocks to selected output products. The European Commission should take an official stance on this matter in the forthcoming Act, notably on the use of mass balance methodologies in the calculations of LCAs for product environmental footprints (PEFs) and environmental product declarations (EPDs).
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Response to Update of format of F-gas labels

4 Jun 2024

Subject: Feedback from PU Europe on the update of format of F-gas labels (implementing act under the on the F Gases Regulation 2024/573) Dear Madam/Sir, Please find below our comments to the proposal on the F-gas labels: First of all we believe that due to the novelties introduced by the new F-Gas Regulation, the consultation forum as per its article 33 should be consulted for any draft implementing act having a significant impact. A new recital (8) in the draft legislation would simply be added to the draft law to allow that input; Since it would be an obvious distortion of treatment to only grant to metered dose inhalers equipment the possibility to indicate Contains fluorinated greenhouse gases with reduced impact on the climate on their label when a low GWP F-Gas is used, that wording in article 1 paragraph (11) shall also be allowed for foams and preblended polyols in a new paragraph 9 that would be created and also in the current paragraph 8 (notably when insulation foam is used). The F-Gas regulation is about fluorinated greenhouse gases, and the two substances used in polyurethane insulation foam in small amount (around 10%) have a GWP < 4 (i.e. far below the 150 threshold). The mandatory recovery of those very reduced impact on the climate F-gases trapped in the foam on the ground that it contributes to the fight against greenhouse gas emissions would not bring any GHG benefit. Thanks the identification of such foam/preblended polyols, demolition companies would be able to direct their effort at recovering foam with F Gases with a GWP>150; Even if our Association is not representing the one component foams (OCF) industry, we have doubt that paragraph (12)(b) is correctly written since entry (16) of annex IV of the regulation does not prohibit the use of F-Gas (only the use of gases with a GWP> 150) in OCF; In order to avoid misinterpretation at national level, the paragraph 4 of Article 1 shall clearly indicate that its provisions are only valid for Article 12 (3) of the F-Gas Reg and not foams and preblended polyol covered by Article 12(5). The words For relevant products and equipment,. could be added at the beginning of paragraph 4 of Article 1 to make this clear. Sincerely
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. Our members provide long lasting products and solutions (over 50 years for most of them) that are essential to cut energy use and therefore fight climate change. PU Europe welcomes the opportunity to provide feedback on the proposed regulations through this public consultation. However, our sector and many other industries in the construction ecosystem are finding it very difficult to stay abreast of the fairly recent European Commission activities on this topic, in part due to the lack of transparency to get access to the technical expert group work. Therefore our input should be seen as high-level and non-exhaustive. However, PU Europe would welcome the opportunity to contribute to the Platform on Sustainable Finance as an ad-hoc expert whenever construction issues are discussed in the context of the EU Taxonomy and sustainable finance more broadly. We would like to raise the below concerns regarding the draft proposal: 1. Our first concern is regarding sections 3.1.4 and 3.2.4 of the Annex II which address the construction of new buildings and renovations. Specifically, the operator of the activity is required to ensure that the three heaviest material categories used in construction/renovation comply with the maximum limits on the use of primary raw materials. While we support the goal of reducing the use of primary raw materials, we believe that setting such thresholds without conducting a proper impact assessment would have unintended consequences; 2. We agree that the principles of circular design and production should be the foundation for determining the conditions under which an economic activity contributes substantially to the transition to a circular economy. However, we suggest that the use of terms such as "re-use" and "recycling" be precisely defined and harmonized to avoid ambiguity and discrepancies, and also to allow the targets set in the sections 3.1.4 & 3.2.4 to be met. We also call for recycled construction materials from all recycling technologies to be eligible to sustainable finance. Stemming from this consideration, we would like to ask the role, and methodology, of the mass balance approach in the industry to be clearly recognized in the recycled content requirement for construction products. The mass balance methodology for chemical recycling, in complement to mechanical recycling and other processes, will enable a smooth and rapid transition to leverage recycled feedstocks in existing infrastructure. It is a well-known "chain of custody" model described in ISO22095 that can accurately calculate and verify the amount of recycled feedstocks allocated to products. PU Europe stands ready to continue contributing to the policies and regulations needed for a more sustainable European Economy and wishes to restate that the two key ingredients for drafting policies/legislations in this area should be material neutrality and technological openness.
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Response to Review of the Construction Products Regulation

12 Jul 2022

PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. We generally welcome the Construction Products Regulation (CPR) proposal as it builds on the existing single market legislation to cover environmental sustainability and circularity aspects. The text introduces a grandfathering principle for cited harmonized technical specifications until new standardisation requests are fulfilled. The fact that the CE marking is kept and that documentation can be transmitted via digital tool only are also welcomed. The link to the EN 15804 for declaring environmental sustainability is also something that the whole construction industry has been advocating for in order to convergence as soon as possible to sound and comparable data. With regards to chapters VI, VIII and IX, we value the efforts made at improving the existing framework for notified bodies and market surveillance authorities as it will ensure a better enforcement of the CPR. As regards international cooperation with non-EU countries, we hope that a bridge will be built in the future between the CPR and the UKCA legislations. Finally, we support the introduction of the trade-off principle in the legislation even though it will remain a rather grey zone during its implementation (numerous trade-offs are involved for manufacturers at the designing stage of a product : e.g. durability, resource use and recyclability, which have direct implications on the sustainability performance of the building). PU Europe comments on the CPR proposal, notably articles 22 and 30, can be found in the attachment. PU Europe sincerely hope that those comments will be taken into consideration in the next stages of the ordinary legislative procedure and would like to recall the support of its members to the EU long term carbon neutrality goal. Our products are critical in curbing energy consumption, and hence CO2 emissions, during the use phase of buildings, from commercial, industrial, public to dwellings. PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pu-europe.eu and lobbying transparency register ID number 27993486325-38).
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Response to Review of EU rules on fluorinated greenhouse gases

29 Jun 2022

PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. Our members provide long lasting products and solutions (over 50 years for most of them) that are essential to cut energy use and therefore fight climate change. PU Europe generally welcomes the proposal and would like to comment on its scope and the mandatory recovery and destruction of insulation waste containing F Gases, both topics being interlinked. The aim of this regulation being about preventing greenhouse gases emissions, we believe that a differentiated treatment shall apply to substances listed under section 1 “Unsaturated hydro(chloro)fluorocarbons” of annex II owning to their (very)low GWP. It is a fact that alternatives to those substances (flammable hydrocarbons included) might exhibit a higher GWP than the substances they substitute. This is particularly important in the context of the article 8 paragraphs 4 and 5 “recovery and destruction”. While the whole waste and construction sector has embarked on the immense task of developing a proper infrastructure is in place all over Europe to deal with construction and demolition waste (C&D W), this will take time and the developments are different depending on the countries/regions. If an obligation to recover foam containing a low GWP blowing agent was imposed bluntly in a geographic area where no proper infrastructure exist for C & D waste, the environmental benefit of such obligation would most probably be negative (assuming more intense human activities to segregate the waste and longer distances between the various stakeholders). We would therefore very much like to see a reversal of the proposal in the sense that an environmental cost benefit analysis shall prove that it is worth recovering those gases listed under annex II, section 1. With regards to the entry into force by January 2024 of this obligation, this seems overambitious when looking at the number changes which will need to be made to national frameworks and for informing all the stakeholders. PU Europe members are committed to help the European Union reach its medium to long-term objectives of a climate neutral, resilient and fair Europe. We believe than our durable products are critical in curbing energy consumption, and hence CO2 emissions, during the use phase of buildings, from commercial, industrial, public to dwellings. It is also worth highlighting that for the fraction of our sector relying on F Gases, those substances have almost completely being replaced by H(C)FO-1336mzz, -1234ze& -1233zd listed under annex II section 1, well in advance of the 2023 deadline set by the existing F Gas Regulation. Those former substances have 99% lower Global Warming Potential (GWP) vs. their predecessors and also exhibit a better thermal conductivity.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

7 Feb 2022

PU Europe, representing the European polyurethane insulation industry, welcomes the proposed recast of the EPBD issued on the 15th of December. This proposal contains numerous clarifications and new provisions, notably the introduction of Minimum Energy Performance Standards and the setting of national building renovation plans, together with a significant effort to bring more consistency in European energy & climate laws. Altogether, the proposal has potential for fostering a more energy efficient and climate friendly building stock, however the willingness of member states to implement it and boost actions on the ground remains a key question mark. Our feedback on the proposed recast EPBD is as follows: • The introduction of whole life-cycle GHG emissions reporting obligations for new buildings needs to rely on standards developed by CEN TC/350 (in particular EN 15978 & EN15804 Furthermore, the European Commission shall endeavor to fix the the current differences in how EPDs are created and differing raw material databases still need to be harmonized to ensure accurate and comparable whole life carbon data. This will enable necessary investments in making construction products like PUR/PIR insulation products ever more climate friendly; • The Energy Efficiency 1st principle should be given a higher role throughout the EPBD and not solely referred to in a recital. For instance, there shall be a final energy consumption metrics in the deep renovation definition and on the Energy Performance Certificate (this is part of Annex III but missing in Article 16); • The definition of ZEB (zero-emission building) should be altered to reflect science to secure decarbonisation of buildings. With the stated approach on ZEB, the objective of the legislator is to address direct greenhouse gas emissions from the running of the building due its energy consumption. However, such definition is not coordinated with the WLC GHG emissions approach (ZEB shall be one sub-metric of WLC GHG emissions) and the oversimplified way it is communicated risks undermining the need for actions on the other life cycle stages of buildings. Furthermore, such definition disregards others “emissions” (emissions of SOx, NOx, PMs…) whether at local level or remotely (emissions emitted at the point of generation for energy distributed via networks). And this without even mentioning possible land use change and water scarcity impacts. In certain countries and cities, health and environmental issues could increase due to this overwhelming term that does not capture the other emissions. Therefore the ZEB definition should have a clear focus on Zero operating GHG emissions building or could maybe go back to the a Zero operating energy building scope. Consumers should not be misled on the true environmental performance of buildings via oversimplification. In addition, the NZEB standards and the primary energy use figures indicated for ZEB in Annex III are not ambitious enough compared to existing NZEB over the EU countries. This should be revisited. Furthermore, PU Europe, as a member of the Renovate Europe Campaign, supports the points raised by this organization on: - More ambition on the Minimum energy performance standards (MEPS) to be achieved by buildings; - Clear intermediary milestones to be added in the National Building Renovation Plans (with a view to have member states develop meaningful MEPS and associated trigger). The central role of buildings in an energy efficient and fully decarbonised economy by 2050 is clear, and the European polyurethane thermal insulation industry is committed to a climate neutral and resource efficient Europe by mid-century. PU Europe will work with European decision-makers in 2022 to help finalise the recast of the EPBD, and more broadly for achieving the goal of renovating 35 million building units by 2030.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

PU Europe, the European Federation of PUR/PIR rigid polyurethane insulation manufacturers, appreciates the opportunity to contribute to the inception impact assessment for the revision of the REACH Regulation. Our industry acknowledges the non-disputable role that REACH Regulation has played over the last decades and stands ready to help achieving a higher level of protection of citizens and the environment against hazardous chemicals. PU Europe therefore supports the headline objectives of the Chemicals Strategy for Sustainability (CSS). However it is necessary to highlight that the European Green Deal in not only flanked by a Chemicals Strategy for Sustainability for a toxic-free environment, but also by the Renovation Wave Strategy. As part of the ambitious objectives on many fronts which have been set by the European Commission, the Climate Neutrality one by 2050 is for sure the most critical one. A number of products, like the ones manufactured by our members, are urgently needed to curb GHG emissions from the building sector even if certain of those products rely on substances exhibiting hazardous characters. The mere presence of chemicals labelled as hazardous does not translate into risks for workers and/or end-users of those articles. A risk management approach is central to protecting health & environment while meeting other societal challenges. PU Europe would like to recall its full support to article 68(1) of the REACH Regulation, which clearly states that the objective of REACH is to apply restrictions when there is an “unacceptable risk to human health or the environment (…) which needs to be addressed on a community-wide basis”. Furthermore, before a targeted review of REACH is launched, PU Europe and its members find it necessary to restate their support to sound science for underpinning any decision under REACH. In that regards, in order to implement the CSS action plan, speed (or sticking to tight deadlines) shall not be privileged at the expense of quality and proper impact assessments shall be performed. While our sector agrees that there are areas requiring further improvement, we would like to comment on some of the initiatives listed in the REACH IIA: • Mixture assessment factor (MAF) *COMMENTARIES IN THE ATTACHED DOCUMENT* • Restriction process *COMMENTARIES IN THE ATTACHED DOCUMENT* • Authorisation process *COMMENTARIES IN THE ATTACHED DOCUMENT* • Registration of polymers and Polymer of Concern (PoC) *COMMENTARIES IN THE ATTACHED DOCUMENT* Polyurethane thermal insulation products are made out of a cellular polymer material in which chemical substances are therefore fully reacted (with the exception of gas trapped into the rigid matrix). Our products are urgently needed to curb GHG emissions from the European building sector, from dwellings to industrial facilities, and reach Climate Neutrality by 2050. About us: PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pu-europe.eu and lobbying transparency register ID number 27993486325-38).
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

PU Europe, the European Federation of PUR/PIR rigid polyurethane insulation manufacturers, appreciates the opportunity to contribute to the inception impact assessment for the revision of the CLP Regulation. PU Europe supports the objectives of the Chemicals Strategy for Sustainability (CSS) aiming at achieving a higher level of protection of citizens and the environment against hazardous chemicals and encouraging innovation for the development of safe and sustainable alternatives. Our industry fully supports a clear and effective CLP legislation and would like to comment on some of the proposals listed in the IIA: • Global alignment must be kept: in already complex regulatory frameworks for raw material suppliers and supply chains, aiming for bringing improvements/changes to the UN GHS regulatory shall be pursued first rather than amending the CLP and creating a de facto diverging system; • Introducing some new hazard classes and corresponding criteria via CLP: our industry stand the view that the REACH framework already allows for such approach (like annex XIII for PBT’s) and we thus do not recommend following that policy option; • Relationship between the CLP and REACH regulations: we urge decision-makers to properly assess the impact that a change of hazard classification and criteria in the CLP will have on value chain/downstream users. Because of the “automatic” ban in REACH, and even more so if REACH is amended to introduced more “generic restrictions”, that derives from certain CLP classifications, users of substances/mixtures will be confronted with a wave of new legal restrictions whose benefits will not have been assessed and might not materialise. The implementation of any new hazard identification and criteria in REACH shall be done in a relevant way for the downstream sectors (risk management ensures safe use for workers/consumers and the environment); • Moving to a hazard based system solely: PU Europe members believes that the removal of hazardous chemicals merely based on their hazards and not on the risk they pose to society could harm some key objectives of the European Green Deal. A risk management approach is central to protecting health and the environment while meeting other societal challenges; • Timeline consideration for the CLP review: due to the sheer structure of the European economy, any change to the CLP regulation will have consequences for raw material suppliers but also for all their customers (including formulators). Therefore realistic transition periods (and cascading them in the supply chain)) shall be agreed with industry (also to carry out proper impact assessments). Polyurethane thermal insulation products are made out of a cellular polymer material in which chemical substances are therefore fully reacted (with the exception of gas trapped into the rigid matrix). Our products are urgently needed to curb GHG emissions from the European building sector, from dwellings to industrial facilities, and reach Climate Neutrality by 2050. About us: PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pu-europe.eu and lobbying transparency register ID number 27993486325-38).
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

PU Europe, representing the European polyurethane insulation industry welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment (IAS) on the review of the Energy Performance of Buildings Directive, and take the opportunity of this input to restate its commitment to a climate neutral and resource efficient Europe by mid-century. As properly described in the IAS, the EPBD review shall indeed be seen in the broader context of our fight against climate change which cannot be won in the absence of a strong focus on cutting energy consumption in the building sector. That is why in order to fulfill our 2030 & 2050 objectives, a review of the EPBD is needed even if the actual legislation, amended in 2018, is not yet fully and properly implemented. Out of the options presented in the IAS, PU Europe strongly supports a review of the EPDB flanked by non regulatory measures, therefore the options 3 and 2 together. Review of the EPBD: • Mutually reinforcing EED and EPBD legislations for cutting more effectively energy consumptions: --> see attached position paper • Improving the quality and consistency of Energy Performance Certificates (EPC)--> see attached position paper • Building logbook featuring information on energy renovation (BRP)--> see attached position paper • Phased/staged introduction of Minimum Energy Performance Standards (MEPS) for existing buildings--> see attached position paper • Setting up deep energy renovation standard(s)--> see attached position paper Non-regulatory measures: The EPBD needs to be supported by other instruments to truly deliver on its promises: • Support measures like technical assistance, project development assistance and financing are essential to help authorities in designing, developing and triggering renovation plans and LTRS (also for the implementation of MEPS, notably for the most vulnerable groups). • Accompanying the skills and the knowledge of the building and construction sector workforce will be key to make sure quality renovations are delivered and that no bottleneck stands in our way to a decarbonized and climate resilient building stock. At a time when renovating our dwellings, public buildings but also our commercial and industrial premises makes a lot of sense from a climate but also an economic perspective we believe that the review of the EPBD together with the implementation of the national Recovery and Resilience Plan represent a unique opportunity for Europe to grasp the multiple benefits linked to energy renovation: improved health and comfort, reduced energy poverty and the creation of jobs and economic growth. About PU Europe: PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pueurope.eu and lobbying transparency register ID number 27993486325-38).
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

PU Europe welcomes the opportunity to comment the draft Commission delegated regulation and its two annexes which would supplement the existing EU Taxonomy Regulation. The European Union drive in setting standards on sustainable financing is welcomed by our organisation. Due to the societal challenges that the world faces, the huge task of bringing European buildings to an energy efficient level has been singled out as a key priority of the current European Commission. However, the EU Taxonomy technical screening criteria shall be carefully crafted so as to support our path to the 2030 and 2050 GHG emissions objectives. With this input, we would like to raise our concerns that the way the proposed annexes are drafted: • Could lead to a loss of confidence from the sustainable finance community to thermal insulation products, including rigid polyurethane products, and • Would leave untapped a significant, and difficult to reach latter on, energy saving potential during thermal energy renovation activities. The long and exhaustive preparatory exercise undertaken by the Technical Expert Group (TEG) came up its the final report with thermal insulation products being listed under its section 3.1 “Manufacture of Low carbon technologies” (paragraph 3 on page 163). Based on this, the Commission drafted the proposed annex I & II featuring each a chapter 3.4. called “Manufacture of energy efficiency equipment for buildings”. While most products listed originally under 3.1 have been migrated to the new chapter 3.4, an obvious omission is the absence of thermal insulation products. Our products would then fall de facto under the chapter 3.5 “Manufacture of other low carbon technologies” with much less visibility at a time when the improvement of the building envelope shall primarily be done thanks to those insulation products. This move could create instability in the market and surely represents an unfair treatment of one product over the others listed in the TEG final report. Furthermore, the current text seems to be inconsistent in its approach since roofing or cladding systems listed under chapter 3.4 do need insulation products and that under chapter 7.3 “Installation, maintenance and repair of energy efficiency equipment”, insulation is the first operation to be mentioned. Why to leave this product out of chapter 3.4 if they substantially contribute to fighting climate change. We therefore call on the Commission to re-introduce previous wording into its proposal and, if NACE codes are needed for such purpose, to make reference to polyurethane thermal insulation products code C22.21.41.50. Regarding the chapter 7.2 “Renovation of existing buildings “ of Annex I containing the 30% primary energy savings threshold, we fully support the submissions filed by Renovate Europe & EuroAce which warned that applying such requirement could lock improvements of the building stock via too weak energy renovations. A 60% threshold would be more appropriate for reaching our climate objectives, and would in fact be in line with the definition of deep renovation as set in the European Commission Renovation Wave Strategy. PU Europe sincerely hope that the above comments will be taken into consideration and would like to recall the support of its members to the EU long term carbon neutrality goal. Our products are critical in curbing energy consumption, and hence CO2 emissions, during the use phase of buildings, from commercial, industrial, public to dwellings. The energy required to manufacture our products (including the raw material acquisition and transformation) is usually offset by the energy savings achieved after the first trimester. PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union.
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Response to Sustainable Products Initiative

16 Nov 2020

PU Europe welcomes the opportunity to comment the roadmap on the “Sustainable Products” initiative and firmly believes that PU insulation products have a key role to play in a greener and more sustainable future. The views expressed below reuse and complement our submission to the “substantiating green claims” public consultation over the summer. In short, we stand the view that a sustainable product Directive must not cover intermediary products like construction products. Best regards Arnaud Duvielguerbigny Secretary General PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pu-europe.eu and lobbying transparency register ID number 27993486325-38).
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

PU Europe, representing the European polyurethane insulation industry welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment on the evaluation and the review of the Energy Efficiency Directive. Please find attached our input on this critical piece of legislation which must be made more effective and contribute more to the success of the European Green Deal, via a stronger focus on reducing energy consumption in buildings.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

PU Europe, representing the European polyurethane insulation industry, has been following the debate on the Single Market for Green Products for many years and welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment on a legislative proposal on substantiating green claims. The PU industry supports providing fair, scientifically sound and harmonized information to the market, notably in the field of so-called green claims, and is committed to the success of a climate neutral and resource efficient Europe. Please find attached our contribution to this crucial debate.
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Response to Review of the Construction Products Regulation

19 Aug 2020

PU Europe, representing the European polyurethane insulation industry, welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment for the future of the Construction Product Regulation (CPR) and would like to contribute with the following points in the attachment.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

PU Europe welcomes the opportunity to comment the roadmap on the “Renovation Wave initiative for public and private buildings”. Energy efficiency in buildings, from dwellings to industrial and commercial premises, must be significantly improved over the next three decades in order to reach carbon neutrality by 2050. The Roadmap describes very well the context and the problem lying in our way to more energy efficient and decarbonized buildings. However, we believe that the objectives should be to triple rather than to double the current average renovation rate and to achieve a greater amount of saved energy during each renovation (heading towards more deep renovations). In order to realise the energy -and thus carbon- savings potential in the building sector, the Renovation Wave shall make renovation of buildings, from apartments to large industrial/commercial premises, a priority at national level. Only with high level political backing can decision-makers, the construction sector and owners of buildings make the right forward looking choices. This would be best achieved by setting up a legislative instrument focusing on cutting energy consumption of buildings, meaning not only existing ones but also new built, and setting up high level indicative energy consumption targets for 2030, 2040 and 2050. Those targets would need to be evaluated at the European Union level against the path compatible with the Paris Agreement objective, notably via a cross-check of the Nationally Determined Contributions, and the Energy Efficiency Directive, the Energy Performance of Buildings Directive (via the national Long-Term Renovation Strategies) and the National Energy and Climate Plans due under the governance of the energy union and climate action regulation. In addition, a fitness check and evaluation of national and European legislations for buildings shall consider introducing mandatory minimum energy performance requirements when a significant change in the building life, like its ownership, occurs so that thermal renovation works can be mandated. This would significantly increase the depth and rate of renovation for buildings under the scope of such an approach. Furthermore, the renovation part of this building specific legislative instrument should be supported by a dedicated financial arm in the forthcoming “next generation EU” recovery plan, thus providing the means to the objectives of a more energy efficiency building stock. The above-mentioned proposals would not only help the EU to achieve carbon neutrality by 2050 but also get companies and economies on a recovery path after the coronavirus pandemic. The multiple benefits of thermal renovation for companies, householders and tenants are well known to span from economic growth, job creation and productivity enhancement, to comfort and indoor air quality improvements to name but a few. PU Europe believes that this forthcoming Renovation Wave initiative should become a central part of the European Green Deal. We stand ready to further contribute to the European Union work in this field and are committed to the success of a climate neutral and resource efficient Europe. Best regards Arnaud Duvielguerbigny Secretary General PU Europe is the European voice of the polyurethane (PUR / PIR) insulation industry. The 110 manufacturing sites and more than 20,000 direct jobs in the PU rigid foam sector contribute to tackling the carbon footprint of the buildings stock responsible for around 36% of the CO2 emissions of the European Union (more information about us via www.pu-europe.eu and lobbying transparency register ID number 27993486325-38).
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Response to A new Circular Economy Action Plan

20 Jan 2020

Dear Madam, Sir, Please find attached PU Europe input to the roadmap on the forthcoming Circular Economy Action Plan. Lobbying transparency register ID number: 27993486325-38. Best regards
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