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Finnish Association of Construction Product Industries

RTT

Finnish Association of Construction Product Industries (RTT) is part of the Confederation of Finnish Construction Industries RT (CFCI) being the joint interest organisation of building contractors, special contractors and the construction product industry.

Lobbying Activity

Response to European strategy for housing construction

18 Sept 2025

The CPR Acquis work to revise harmonized product standards is ongoing. The work is in fact behind schedule. Because of that if would be essential to grant Construction Unit relevant resources in order to complete the work in time. It is not advisable to keep going for decades. There are approximately 400 cited hENs and 200 mandates to be revised. We have high hopes for the upcoming Circular Economy Act. Member States have already possibility to give decrees which indicate that certain construction products remain products instead of becoming waste when detached form the construction work. It is important to speed up the process of delivering those national decrees. However, increasing circular economy is not a rapid way out of the difficult situation many European countries suffer from. Circular economy shall, unfortunately, not increase the number of flats in the short run. EU guarantee models, like sustainable guarantees, can play a pivotal role in bolstering the construction sector by providing financial assurances that mitigate risks for investors and developers. These models offer guarantees that can enhance access to credit, ensuring that developers can secure the necessary funding for their projects. By reducing the perceived risk for lenders, guarantee models can lower borrowing costs and make financing more accessible. This increased access to capital can stimulate new construction projects, addressing housing shortages and contributing to economic growth. Furthermore, EU guarantee models can support small and medium-sized construction firms by improving their financial stability and enabling them to compete more effectively in the market. Any change in the State Aid rules must be carried out in a way that does not skewer the competition or hamper private investment. Furthermore, the EU must respect national conditions in order not to offset markets. While public funding is constrained by the rules of the Stability and Growth Pact, private financing needs to be channelled towards housing projects. For this purpose, the current prudential rules from Basel III and the regulatory guidance from the European Banking Authority (EBA), which requires banks to make high provisions for investment in new construction projects (i.e. housing development and acquisition), should be eased to avoid that construction companies face a credit crunch. Indeed, investing in housing projects should not be considered as riskier or less attractive than investing in other activities. In Finland a new Construction Act came into force in the beginning of this year. New building permits must be applied using building information model or otherwise in a machine-readable format in the beginning of next year. Finland could be used as best practices and our system could be copied elsewhere. We support this initiative as long as it does not require those Member States that already have a functioning system to change it. Functioning of the internal market is very important and by increasing movability of construction services is supportable. In general we support the idea of having European strategy for housing construction, but it is imperative to ensure that it does not introduce any additional unnecessary regulations. Growing regulatory requirements increase the regulatory compliance cost. The EU must address general housing affordability, rather than limit the scope to social or affordable housing. All measures must be designed to enable investment in the places where the housing shortage is greatest and for the people who are in most need of societal support. Everyone needs a place to live, a place to work and be able to travel to and fro. As you go through different phases of life, living requirements change. It is not always true that the next home is accessible. Young people stay in their parents home for longer, move to a family stage later in life and nativity is sinking. The development is very troubling.More feedback in attachment
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Response to European climate resilience and risk management law

4 Sept 2025

Confederation of Finnish Construction Industries (CFCI) is focused on meeting the needs to fight the climate change, but the economic situation is a challenge because in Finland we are building very little compared to times before the war in Ukraine and therefor there is not enough market for all kinds of construction products. The Construction Products Regulation and CPR Aqcuis work are already making certain that manufacturers must declare EPD as soon as harmonized product standard is revised. This is making construction products to be more climate resilient as wished in the part C of the initiative. The Circular Economy Act may hopefully promote possibilities to reuse of material and help making market for products manufactured with circulated material. The hope is that this initiative shall not end up creating more regulations and we should avoid creating extra administrative burden. The purpose of the initiative is very good, but we need to be careful to avoid excess requirements for the industry.
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Response to Revision of the Standardisation Regulation

15 Jul 2025

Finnish Association of Construction Product Industries RTT welcomes the opportunity to provide its perspective on the initiatives of the European Commission concerning the revision of the standardisation regulation. RTT represents the key building product manufacturers and acts as a standards writing body in Finland. We would like to highlight the importance of the following topics: 1. Maintain the New Legislative Framework and industry-led standardization model and focus on improving the implementation phases including the phases prior to the actual standardisation. 2. We propose the European Commission to put in place the necessary mechanisms to ensure coordination in its regulatory initiatives and standardisation tasks. 3. The regulation should address the work related to standardisation (AUWP, SReq, citations, etc.) carried out by the Commission, which is strongly affecting the overall duration of the process. 4. The distinction between regulation-based and fully voluntary standards should be clear in the regulation, and strong binding regulatory requirements should only apply to regulation-based standards. 5. The Annual Union Work Programme for European standardisation (AUWP) should include funding information on each SReq, and necessary funds should be made available already at the AUWP stage. 6. The European Commission should ensure that the funding model for standardisation requests linked to legislation is clear, transparent, equitable, fair, and has continuity. 7. Unlike harmonised standards, which are based on transparency, multidisciplinary participation, and broad involvement of Member States, the Common Specification procedure does not offer the same level of transparency. For strong European Single Market and competitiveness, the wide participation of all stakeholders, including SMEs, must be safeguarded. Therefore, the usage of CS procedures should be restricted to an absolute minimum and be temporary. 8. Member States should ensure that authorities have sufficient resources to participate in standardisation. The regulation should include a provision that Member States must safeguard the maintenance and operation of the national standardisation system. 9. European standardisation must not diverge from global standardisation, as it is essential for competitiveness and business solutions. 10. The utilisation and encouragement of new technologies should be enabled. For ex. online meeting opportunities would support the participation of all relevant stakeholders.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

RT/RTT appreciates the opportunity to give send feedback to the Commission on the long-awaited draft Environmental Delegated Act. RT/RTT believes that the EU taxonomy is a unique sustainable finance framework that must support the construction sector and its companies in their transition to more sustainable and climate-friendly business models. RT/RTT considers the EU taxonomy an opportunity that cant be missed and is committed to contribute developing the act and its criteria. RT/RTT and its members have noted that many thresholds proposed for the various construction-related activities would be achievable from a technical point of view. As such, the draft Environmental Delegated Act is more balanced than the March 2022 recommendations of the Platform on Sustainable Finances Technical Working Group (TWG). However, it is questionable whether all thresholds and maximum/minimum values would be achievable in the short/medium term in every Member State (local availability of secondary raw materials, final CO2 emission reduction potential jeopardized by long transport distances, incompatibility with national building codes, etc.). Currently, there is already insufficient supply of some secondary materials, which some companies must ship in from outside of Europe. RT/RTT recognises that this Delegated Act should help increase this supply; however, the increased wider demand for secondary materials will make this difficult to achieve in the timescales required. RT/RTT would propose to introduce a step-by-step approach in this Delegated Act; start with less strict requirements which can be tightened as secondary raw materials are more developed. Some criteria still seem to have been chosen arbitrarily without proper justification and lack transparency (e.g. maximum values for primary raw material used for certain material categories and construction products) while some activities do not necessarily correspond to what could/should be covered by the description of the activity (e.g. the maintenance of bridges and tunnels, which is not included under Maintenance of roads and motorways). Especially for the activity Maintenance of roads and motorways, it will be very difficult for road construction companies to comply with the criteria as many responsibilities lie with designers. Taxonomy technical screening and Do-No-Significant-Harm criteria should be easily understandable for businesses and be achievable across the EU, in every Member State. Some of the technical criteria would still raise practical problems and make reporting under the EU taxonomy difficult. RT/RTT also consider it of fundamental importance that regular checks of all taxonomy-related documents and management reports are carried out to prevent any attempt of greenwashing or circumvention of the technical criteria. More detailed feedback is given in the attached file.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Feedback in attached file.
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Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

15 Jan 2015 · European Fund for Strategic Investments

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen) and Miltton Networks Oy

14 Jan 2015 · Construction industry