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Glass Fibre Europe

APFE

1.

Lobbying Activity

Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

Please find attached the relevant Glass Fibre Europe paper concerning the review of the EU ETS state aid guidelines for indirect carbon costs.
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Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and European Insulation Manufacturers Association and Glass for Europe

4 Sept 2025 · Trade policy, trade defence instruments

Response to Delegated act on primarily used components under the Net-Zero Industry Act

13 Feb 2025

Glass Fibre Europe, representing the continuous filament glass fibre (CFGF) manufacturing industry in Europe, welcomes the possibility to comment the European Commissions draft delegated and implementing acts before their adoption. Glass fibre products are essential components in both onshore and offshore wind renewable technologies. Without glass fibre rovings, mats and yarns, there would be no wind turbine blades, nacelles or hub covers - ultimately no wind energy industry. To continue bolstering the resilience of this supply chain, resulting in job creations and sustainable growth, and ensuring the technological advancements of the European wind industry, it is essential that these products, when used in wind renewable technologies, are recognised as main and specific components for the wind renewable technologies. Although the association understands that Annexes set out in a non-exhaustive manner the list of components, it believes the essential role of glass fibre rovings in wind renewable technologies should be acknowledged by including them in the list. These products meet the definition of processed material in the Regulation (article 3) and the criteria detailed in the Staff Working Document included in the consultation documents. This position is further detailed in the position in attachment.
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Response to List of net-zero technology final products and their main specific components

13 Feb 2025

Glass Fibre Europe, representing the continuous filament glass fibre (CFGF) manufacturing industry in Europe, welcomes the possibility to comment the European Commissions draft delegated and implementing acts before their adoption. Glass fibre products are essential components in both onshore and offshore wind renewable technologies. Without glass fibre rovings, mats and yarns, there would be no wind turbine blades, nacelles or hub covers - ultimately no wind energy industry. To continue bolstering the resilience of this supply chain, resulting in job creations and sustainable growth, and ensuring the technological advancements of the European wind industry, it is essential that these products, when used in wind renewable technologies, are recognised as main and specific components for the wind renewable technologies. Although the association understands that Annexes set out in a non-exhaustive manner the list of components, it believes the essential role of glass fibre rovings in wind renewable technologies should be acknowledged by including them in the list. These products meet the definition of processed material in the Regulation (article 3) and the criteria detailed in the Staff Working Document included in the consultation documents. This position is further detailed in the position in attachment.
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Meeting with Yvan Verougstraete (Member of the European Parliament)

20 Nov 2024 · Glass fibre

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Apr 2024 · Discussion on Glass Reinforcement challenges

Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

7 Mar 2024

Glass Fibre Europe (GFE) wants to bring the attention of the Commission the specific case of Continuous Filaments Glass Fibre (CFGF) products used as reinforcement of plastic in the manufacture of Glass Fibre Reinforced Plastic (GFRP) materials and articles. Such CFGF products are used in a large variety of end use GFRP applications, some of which are intended for food contact (e.g. food processing equipment) as well as for drinking water contact applications in the public water distribution networks (e.g. pipes, tanks, ladders in water towers, pumps). The current proposal will disproportionately impact food contact applications and prohibit de facto GFRP materials used currently in drinking water contact applications in compliance with Member States regulations. Detailed explanations are available in the document in attachment. Glass Fibre Europe solicits the attention of the Commission for considering the use of BPA as precursor of BADGE-based epoxy film formers used in the formulation of sizing applied to CFGF products used in reinforced plastic intended for food contact applications as eligible for a derogation to the prohibition of the use of BPA in FCM. Provided such a derogation is considered justified, to be effective, it would require to be covered in the proposed amendment of Regulation 1895/2005.
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Response to Revision of EU legislation on end-of-life vehicles

1 Dec 2023

Glass Fibre Europe, representing the continuous filament glass fibre manufacturing industry in Europe, welcomes the European Commission proposal to review the End-of-Life of Vehicles Directive. To our industry, it stands clear that glass fibre reinforced (GFR) composites must be sustainable to be part of our future. While the environmental benefits of GFR composites used in vehicles are incomparable, in particular their contribution to the reduction of vehicles weight and emissions, progresses must be done on their end-of-life treatment. In that respect, the European Commission proposal can be a game changer. While the European Commission proposal correctly addresses major hurdles to the reuse and recycling of end-of-life vehicles, we believe that the proposal can further promote these objectives for the GFR composites parts. Please find our proposals in attachment.
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

Comments related to EUPL Number 1351: glass fibres included in Annex I - EUROPEAN POSITIVE LIST OF STARTING SUBSTANCES FOR ORGANIC MATERIALS: The conditions of use associated with glass fibres are indicated as Glass according to Annex IV. Annex IV (Table 1): European positive lists of compositions of enamels, ceramics and other inorganic materials does include accepted composition for Borosilicate glass and Soda-lime glass as well as associated Relevant species to be analysed in the migration waters. Indeed, Borosilicate glass and Soda-lime glass are materials intended for direct contact with drinking water. Annex IV (Table 1) does not include an entry related to glass composition relevant for glass fibres. Glass fibres are not intended for direct contact with drinking water. For decades, glass fibres are used as reinforcement (additive) to organic materials (plastics) in glass fibre reinforced plastic (GRP) applications intended for contact with drinking water (examples are pipes, tanks, pumps, valves, etc.). Considering that (1) glass fibres are not final materials intended for direct contact with drinking water, (2) glass used to manufacture glass fibres is recognized as being an inert material, (3) glass composition for glass fibres does not contain intentionally added elements of concern like Cd, Pb, Hg, Cr, As, Sb and (4) glass fibres are authorized as additive in Annex I of Reg. EU/10/2011 without Restrictions and Specifications, we do not see the need of including accepted composition in Annex IV to achieve the desired end (i.e. consumer protection). However, the European Commission could consider treating glass fibres like some other Annex IV entries, namely with No specific composition requirements and a defined list of Relevant elements to be analysed in the migration waters. Glass Fibre Europe members could support this option by developing and proposing a testing plan for determining if there are relevant elements to be tested in migration waters. Comments related to ANNEX III - EUROPEAN POSITIVE LIST OF ORGANIC CONSTITUENTS OF CEMENTITIOUS MATERIALS: Glass fibres are used as reinforcement for concrete. More precisely, the function of AR-glass fibres (alkali-resistant) is to prevent the formation of cracks in concrete. Annex III Table 1 provides the list of generic constituents of cementitious materials, including the category inorganic additions, for which organic substances used for their preparation should comply with the European positive list for cementitious materials. In the case of glass fibres for concrete reinforcement, reference to the European positive list for organic materials should be added in positive lists requirements to cover glass fibre organic surface treatment (sizing).
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

Glass Fibre Europe welcomes the harmonization of the requirements applicable to materials intended for contact with drinking water. While reviewing the definitions available in the delegated acts, we have not found a definition of additive which is used in several delegated acts. Shall we understand that additive definition and concepts included in: - Regulation EU 10/2011 Art. 3 (7) (additive means a substance which is intentionally added to plastics to achieve a physical or chemical effect during processing of the plastic or in the final material or article; it is intended to be present in the final material or article;), and in - EFSA Scientific Opinion Approach for safety assessment of glass fibre-sizing agents in glass fibre-reinforced plastics for food contact https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2015.4168 are applicable in the frame of EU Drinking Water delegated acts?
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

14 Jun 2021 · International competition

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism