FEhS - Institut für Baustoff-Forschung e.V.
Ziel ist die Forschung und Entwicklung von Eisenhüttenschlacken und deren Nutzungsmöglichkeiten als nachhaltige Baustoffe und Düngemittel.
ID: 982675322010-30
Lobbying Activity
Response to Review of the Construction Products Regulation
1 Jul 2022
One of the overarching goals of the draft of the CPR is, among other things, the resource-saving manufacture of construction products and the promotion of circular economy and sustainability in the construction industry. This goal is considered in the new draft of the CPR by imposing environmental obligations on the manufacturer in Art. 22 of the draft of the CPR. The European Commission's proposal also includes a new Article 84 on environmentally oriented public procurement. Art. 22 of the draft CPR overlooks the importance of by-products, while Art. 84 of the draft CPR is not very ambitious (see enclosure).
Moreover, in the current proposal the European Commission is empowered to adopt Delegated Acts in a broad range of situations. The criteria when to adopt Delegated Acts are not clear and transparent and considered by industry as a free ticket for the Commission to decide whether essential characteristics should be compulsory or voluntary for some family of products, to include threshold levels and classes of performance, to add further environmental obligations for manufacturers or to introduce labelling requirements including a ‘traffic-light-labelling’.
The current draft with its multiple possibilities for the Commission to adopt Delegated Acts, even where it may be disputed if some amendments are non-essential, is an open door to an ever-changing piece of legislation. Such empowerment would result in legal uncertainties and further difficulties for construction manufacturers to place their products on the market, adding confusion to the general process for all actors in the value chain which is considered complex and unclear enough.
So, we strongly recommend reducing the number of articles that may be amended by Delegated Acts, e.g., by further specifying the requirements in the legal text, and that the delegation of powers to the Commission should be used in exceptional circumstances to solve a specific issue not addressed in the legislation. It goes without saying that only a proper consultation of all stakeholders is key upstream and during the whole process.
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