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Glass for Europe

Glass for Europe is the trade association representing the European flat glass sector.

Lobbying Activity

Glass for Europe urges support for advanced glazing technologies

13 Jan 2026
Topic — The EU is consulting on measures to strengthen industrial capacities for advanced materials.
Message — They request that the Act includes glazing technologies to boost competitiveness and support high-performance production. The group proposes de-risking manufacturing investments and establishing closed-loop recycling systems.123
Why — This would protect EU producers from imports and lower financial risks for furnace upgrades.45
Impact — Non-EU glass importers and waste management firms relying on landfilling would face market barriers.67
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Meeting with Denis Redonnet (Deputy Director-General Trade)

12 Jan 2026 · State of automotive glass industry

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and European Insulation Manufacturers Association and

9 Dec 2025 · Implementation of the Construction Products Regulation (CPR)

Glass for Europe calls for relaxed window energy efficiency criteria

5 Dec 2025
Topic — A review of the EU taxonomy rules to update technical screening criteria.
Message — The association proposes raising the maximum window heat loss threshold to 1.4 W/m²K. They also suggest using solar heat gain as an alternative measure of energy performance.12
Why — Raising the threshold allows more glass products to receive sustainable finance classification.3
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Glass for Europe urges closed-loop flat glass recycling mandates

6 Nov 2025
Topic — The consultation seeks feedback on the proposed Circular Economy Act for sustainable production.
Message — Glass for Europe advocates for a 'flat glass to flat glass' closed-loop system. They propose mandatory pre-demolition audits and a ban on landfilling recyclable glass. They also seek recognition of pre-consumer glass as a by-product.123
Why — Access to more recycled content lowers energy costs and manufacturing emissions.45
Impact — Building owners face higher costs due to mandatory sorting and audit requirements.6
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Glass for Europe calls for unified building carbon limits

31 Oct 2025
Topic — The Commission is establishing a framework for calculating the life-cycle carbon footprint of buildings.
Message — The organization requests a consistent framework for setting carbon limit values across the EU. They propose updating reporting tables to show the total carbon impact from all construction stages.12
Why — Standardized rules would reduce the complexity of selling glass products across different European markets.3
Impact — National governments lose the flexibility to set climate priorities based on their local construction methods.4
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Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

23 Oct 2025 · Exchange the Industrial Decarbonisation Accelerator Act (IDAA). Flat glass sector's input on IDAA

Response to New European Bauhaus

17 Oct 2025

Flat glass is an irreplaceable construction material which brings essential natural daylight and thermal comfort to buildings in both winter and summer. It is an enabler of energy consumption reduction and even allows on-site renewable energy generation. These characteristics mean that flat glass plays a central role in meeting the New European Bauhauss objectives: supporting decarbonisation in the built environment, accelerating the move towards clean and cheaper energy, and promoting circular design and resilient models. High performance glass and glazing solutions offer proven, scalable means to improve building energy performance, enhance occupant well-being, and address the growing challenge of overheating in a warming climate. Glass for Europe supports the NEBs ambition to mainstream sustainability and resilience principles at neighbourhood and building level and calls for the recognition of flat glass as a key enabler of climate adaptation within the initiatives next phase. The complete contribution of Glass for Europe is available to download.
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Glass for Europe demands financial support for industrial electrification

9 Oct 2025
Topic — The Electrification Action Plan aims to accelerate the transition from fossil fuels.
Message — The group requests inclusion in the indirect emissions compensation list and tax exemptions. They also want incentives for advanced glazing to improve building efficiency.123
Why — These measures would lower high operational costs and mitigate carbon leakage risks.45
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Glass for Europe pushes glazing-first approach for heating

9 Oct 2025
Topic — The initiative explores policy measures to accelerate the decarbonisation of heating and cooling.
Message — The association requests prioritizing energy reduction through high-performance windows. They recommend including glazing as a cornerstone of building transition strategies.12
Why — Focusing on building envelopes would drive market demand for high-performance glass products.3
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Glass for Europe urges EU to bolster construction supply chains

18 Sept 2025
Topic — The consultation seeks to improve the EU housing supply through construction sector productivity.
Message — The association requests financial support for energy-intensive production and harmonized recycling rules. They also seek an extension of the recovery fund deadline and strict building efficiency standards.123
Why — This would lower operational costs while securing long-term demand for high-performance glass.45
Impact — Taxpayers may bear costs if affordable housing projects are exempted from competition rules.6
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Meeting with Dan Jørgensen (Commissioner) and

18 Sept 2025 · Competitiveness

Glass for Europe urges state aid for flat glass sector

5 Sept 2025
Topic — Updating rules for compensating indirect carbon costs under the Emissions Trading Scheme.
Message — The association requests state aid eligibility for flat glass manufacturing and processing. High electricity prices and global competition increase the risk of industrial relocation.12
Why — This would reduce production costs and facilitate the transition to electric furnaces.34
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Glass for Europe promotes glazing solutions for climate resilience laws

4 Sept 2025
Topic — The EU is establishing a framework to manage accelerating climate change risks.
Message — The organization calls for high-performance glass to be included in building codes and renovation plans. They argue that advanced glazing protects public health by preventing indoor overheating during extreme heatwaves.12
Why — Official recognition would drive market demand for specialized high-performance glass products.3
Impact — Air-conditioning manufacturers face market pressure as buildings shift toward passive cooling designs.4
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Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and European Insulation Manufacturers Association and Glass Fibre Europe

4 Sept 2025 · Trade policy, trade defence instruments

Glass for Europe urges CBAM coverage for downstream products

26 Aug 2025
Topic — Expanding the carbon border adjustment mechanism to downstream products to prevent leakage.
Message — The sector demands that CBAM covers both raw glass manufacturing and downstream processing to prevent tax evasion. They argue that excluding processed goods would shift imports toward high-value finished products.12
Why — Including downstream products would protect European manufacturers from unfair competition and rising energy costs.34
Impact — Importers of processed glass from countries with lower climate standards would face higher costs.5
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Response to Revision of the Standardisation Regulation

21 Jul 2025

Glass for Europe, the trade association of the EU flat glass sector, has long been involved in the standardisation of building glass products and welcomes the opportunity to give feedback on the planned revision of Regulation (EU) 1025/2012, based on our experience in CEN and ISO. The attached contribution outlines four key recommendations to improve the current functioning of the EU standardisation framework.
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Glass industry warns against administrative burdens in decarbonisation act

7 Jul 2025
Topic — An EU initiative to speed up industrial decarbonisation and create low-carbon product markets.
Message — The sector urges the Commission to avoid new labels and burdensome reporting. They suggest using existing data and defining products by where glass is melted.123
Why — This would prevent unnecessary compliance costs and protect local manufacturers from non-EU competition.45
Impact — Non-European manufacturers and processors of imported glass would be excluded from green incentives.6
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Glass for Europe urges urgent post-2030 EU ETS framework

4 Jul 2025
Topic — Review of EU Emissions Trading System elements for stationary installations, aviation and maritime.
Message — The organization requests urgent design of a new EU ETS framework post-2030, continued free allocation protection against carbon leakage, and support targeted to sectors lacking decarbonization technologies. They argue Phase IV mechanisms imply the end of free allocation and rapid market depletion, deterring investment decisions for furnaces running 16-20 years.123
Why — This would reduce compliance costs and enable investments in manufacturing facilities.45
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Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur)

5 Jun 2025 · Housing Crisis in the EU

Response to European Affordable Housing Plan

4 Jun 2025

Please find attached Glass for Europe's contribution to the Call for Evidence on the European Affordable Housing Plan.
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Meeting with Alicia Homs Ginel (Member of the European Parliament) and Eurogypsum

20 May 2025 · Sustainable construction in the European Affordable Housing Plan

Glass for Europe backs realistic lifespans for energy calculations

7 May 2025
Topic — Revision of the methodology for calculating cost-optimal energy performance in buildings.
Message — Member States should consider insulation and solar gains when assessing glazing. The role of operable windows in maintaining healthy indoor environments must be recognized. The regulation should explicitly link cost calculations to future global warming assessments.123
Why — Broader performance metrics and longer calculation periods would boost demand for high-performance glass.4
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Meeting with Heiko Kunst (Head of Unit Climate Action), Mette Koefoed Quinn (Head of Unit Climate Action) and

15 Apr 2025 · Exchange of views on the revision of the EU Emission Trading System and challenges faced by ceramic, glass and pulp and paper sectors.

Meeting with Benedetta Scuderi (Member of the European Parliament)

10 Apr 2025 · Resolution on Energy Intensive Industries

Meeting with Benedetta Scuderi (Member of the European Parliament)

10 Apr 2025 · Ells

Meeting with Bruno Tobback (Member of the European Parliament)

24 Mar 2025 · Werkbezoek Glass

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

12 Mar 2025 · Circular Economy and construction

Glass for Europe urges shift from price to sustainability criteria

6 Mar 2025
Topic — Evaluation of EU rules governing public procurement contracts for goods and services.
Message — Glass for Europe recommends moving beyond cost as the primary decisive factor. They suggest introducing mandatory non-price criteria to prioritize sustainability and innovation. These criteria should rely on officially declared performance data for fair competition.123
Why — This would prioritize the high-performance, European-made, and low-carbon glass of its members.45
Impact — Cheap suppliers would lose their dominant market advantage in price-only public tenders.67
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Meeting with Markus Ferber (Member of the European Parliament)

5 Mar 2025 · Work of HOUS Committee

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

20 Feb 2025

The comprehensive supply chain approach of the Net-Zero Industry Act is essential to boost domestic capacities and strengthen the resilience of EU strategic value chains. In this regard, Glass for Europe welcomes the inclusion of several flat glass products in the list of primarily used and main specific components of Net-Zero technologies namely: Solar glass Anti-reflective coatings and high transparency of solar glass are essential for optimal light transmission and thus maximised energy conversion of solar PV. In line with the European Commission's methodology for drafting secondary legislation, solar glass is specific, commercially available and essential for the manufacture of photovoltaic (PV) and solar thermal technologies. For these reasons, the inclusion of solar glass in the list of components is a request of the entire solar PV industry, as stated in the European Solar PV Industry Alliance (May 2024). o Glass for Europe supports the inclusion of solar glass and encourages the European Commission to keep it as such. Solar mirrors These are mirrors used solely to concentrate the sun's rays onto a central receiver in Concentrating Solar Power (CSP). They are made of extra-clear, low-iron glass coated with a reflective layer to reflect solar energy. Due to their intrinsic properties, solar mirrors cannot be used in other applications such as appliances or automobiles. It appears that solar mirrors are included in the list of primarily used and main specific components under 'CSP reflectors' for solar thermal electric technologies. o In order to dispel any doubts about the inclusion of solar mirrors under 'CSP reflectors', the implementing and delegated acts could mention them more explicitly. Additional glass products meet the criteria and could be added to the list of components. It is notably the case for: Building-integrated photovoltaics (BIPV) Photovoltaic materials which are an integral component of the building envelope used to replace conventional building materials such as the roof, skylights, facades, canopies and spandrel glass. BIPV simultaneously converts solar energy into electricity and provides building envelope functions. Glass for Europe therefore recommends its addition to the list of components of photovoltaic technologies. Further justifications on the inclusion of building-integrated photovoltaics can be found in the table attached. The table also contains Glass for Europe's feedback on transformative industrial technologies for decarbonisation
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

The comprehensive supply chain approach of the Net-Zero Industry Act is essential to boost domestic capacities and strengthen the resilience of EU strategic value chains. In this regard, Glass for Europe welcomes the inclusion of several flat glass products in the list of primarily used and main specific components of Net-Zero technologies namely: Solar glass Anti-reflective coatings and high transparency of solar glass are essential for optimal light transmission and thus maximised energy conversion of solar PV. In line with the European Commission's methodology for drafting secondary legislation, solar glass is specific, commercially available and essential for the manufacture of photovoltaic (PV) and solar thermal technologies. For these reasons, the inclusion of solar glass in the list of components is a request of the entire solar PV industry, as stated in the European Solar PV Industry Alliance (May 2024). o Glass for Europe supports the inclusion of solar glass and encourages the European Commission to keep it as such. Solar mirrors These are mirrors used solely to concentrate the sun's rays onto a central receiver in Concentrating Solar Power (CSP). They are made of extra-clear, low-iron glass coated with a reflective layer to reflect solar energy. Due to their intrinsic properties, solar mirrors cannot be used in other applications such as appliances or automobiles. It appears that solar mirrors are included in the list of primarily used and main specific components under 'CSP reflectors' for solar thermal electric technologies. o In order to dispel any doubts about the inclusion of solar mirrors under 'CSP reflectors', the implementing and delegated acts could mention them more explicitly. Additional glass products meet the criteria and could be added to the list of components. It is notably the case for: Building-integrated photovoltaics (BIPV) Photovoltaic materials which are an integral component of the building envelope used to replace conventional building materials such as the roof, skylights, facades, canopies and spandrel glass. BIPV simultaneously converts solar energy into electricity and provides building envelope functions. Glass for Europe therefore recommends its addition to the list of components of photovoltaic technologies. Further justifications on the inclusion of building-integrated photovoltaics can be found in the table attached. The table also contains Glass for Europe's feedback on transformative industrial technologies for decarbonisation
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Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

3 Feb 2025 · Circularity requirements for vehicle design and management of end-of-life vehicles

Meeting with Ivars Ijabs (Member of the European Parliament, Shadow rapporteur)

29 Jan 2025 · End-of-life vehicles Regulation

Meeting with Marina Mesure (Member of the European Parliament) and AGC Glass Europe

21 Jan 2025 · Visite de l'usine Soltech

Meeting with Marina Mesure (Member of the European Parliament)

18 Sept 2024 · Politique énergétique européenne et impact sur l'industrie

Meeting with Maroš Šefčovič (Executive Vice-President) and

2 Feb 2024 · Roundtable with associations of industrial users

Glass for Europe calls for flexibility in EU emissions trading climate plans

2 Jan 2024
Topic — EU ETS free allocation rules update for 55% emissions reduction by 2030.
Message — The association requests more time for operators to prepare climate neutrality plans due in May 2024, better alignment with Energy Efficiency Directive requirements, and greater visibility on future free allocation calculations. They emphasize sticking to industrial reality for efficient policy.123
Why — This would give producers more time to comply with new climate planning requirements.4
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Glass for Europe advocates for closed-loop automotive glass recycling

4 Dec 2023
Topic — This consultation revises EU rules on recycling and reusing end-of-life vehicle components.
Message — They want a clear definition of dismantling to ensure high purity and non-contamination standards. The group proposes prioritizing closed-loop recycling that returns automotive glass specifically to the flat glass sector. They also advise against listing specific sub-sectors allowed to recycle automotive glass.123
Why — These changes ensure the industry receives the pure materials required for manufacturing.45
Impact — Other recycling sectors might lose access to high-quality glass waste streams.6
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Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur) and UIRR, International Union for Road-Rail Combined Transport

9 Nov 2023 · Weights and dimensions directive

Response to Evaluation and revision of the Weights and Dimensions Directive

26 Sept 2023

Glass for Europe welcomes the European Commissions (EC) proposal for a revision of Directive 96/53/EC (COM(2023) 445/2) but considers that additional improvements are needed to increase logistic efficiency and reduce transports CO2 emissions in the EU. European flat glass manufacturers organize thousands of transports every year to deliver products to their customers. The value chain, which includes multinationals and thousands of SMEs, relies on well-harmonized rules and on local schemes allowing trucks with 5 or 6 axles to be heavier than 40 tonnes. Given this reality, Glass for Europe calls on policymakers to implement two main improvements. First improvement: Annex 2.2 should be modified to set the maximum weight of vehicle combinations with 5 and 6 axles to 44 tonnes to reduce flat glass transports CO2 emissions. Flat glass producers evaluated that this measure could allow a cut of 7 to 10% of the CO2 emissions related to flat glass transportation. Beyond flat glass, case studies have shown that the overall impact of increasing the maximum weight of heavy-duty vehicles is environmentally beneficial. While increasing the use of intermodal transports and switching to zero-emission vehicles will take time (need for technological innovation and adequate infrastructure), using heavier vehicles for flat glass transportation would allow immediate results since no change of equipment would be needed. Alternatively, Annex 2.2.2 could be complemented with a section allowing vehicle combinations to weigh 44 tonnes when they include a flat glass inloader semi-trailer, i.e., a combination of a 2 or 3 axles vehicle with a 3 non-transverse axles (bespoke) semi-trailer. Float glass must be transported in large panes of indivisible mass. Although the glass inloaders design is optimized to increase transport efficiency, the 40 tonnes limit leads manufacturers to ship glass in underloaded glass inloaders, only because adding panes would exceed regulatory limits in weights. If an increase in weight would be allowed for this specific situation, the increase of 5 or 6 axles trucks weighing 44 tonnes on EU roads would remain minor it is evaluated that max. 5000 glass inloaders are used in the EU today - but the emissions cut from flat glass transportation would be significant. Besides, glass inloaders have a recognizable design and shape which would permit easy monitoring by authorities. Second improvement: Ensure long-term harmonised rules and enable CO2 emissions cuts by ensuring that the maximum weight to enter or leave a Member State is always identical to the one allowed on the Member States territory. Article 4b (1) goes in the right direction by ensuring that when a Member State allows for higher weights in national transportation, it shall also allow these weights for international transportation. Yet, the EC proposal still leaves possibilities for Member States to disregard this rule for vehicles heavier than 44 tonnes, or for all vehicles heavier than the directives limit after 2034. The future directive should eliminate this kind of unjustified double standard by suppressing Article 4b (2) & (3). If a Member State possesses adequate infrastructure and rules to allow heavier vehicles in national transportation, they can welcome international transportation with the same vehicles, including from non-EU countries.
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Glass for Europe wants glazing recognized as eco-innovation

19 Sept 2023
Topic — The EU is revising procedures to approve innovative CO2-reducing technologies for vehicles.
Message — The association requests that advanced glazing be included in air conditioning efficiency assessments. They argue for a less restrictive market penetration threshold for innovative technologies. Additionally, they call for the eco-innovation scheme to include electric vehicles.123
Why — Official certification would incentivize car manufacturers to purchase more high-performance glass products.45
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Glass for Europe demands flexibility for long investment cycles

1 Sept 2023
Topic — This consultation establishes content requirements for climate-neutrality plans within the EU carbon market.
Message — The industry requests that five-year targets be adjusted to reflect their twenty-year furnace investment cycles. They also seek recognition for past decarbonization progress and protection for energy-intensive, high-value products.123
Why — Greater flexibility would protect their free carbon allowances and reduce administrative burdens.45
Impact — European building efficiency goals are threatened if glass manufacturing faces increased carbon leakage.6
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Glass for Europe urges tailor-made taxonomy for glass recycling

3 May 2023
Topic — The initiative defines sustainable economic activities for investment purposes across several EU environmental objectives.
Message — The organization calls for criteria specific to glazing realities and simple enough for operators to use. They recommend separating glass from mineral wool to ensure recycling thresholds are appropriate for each product type.12
Why — Simpler rules would prevent glass manufacturers from being discouraged by complex accounting requirements.3
Impact — Competing material manufacturers might gain unfair advantages from inconsistent definitions of raw materials.4
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Iskra Mihaylova (Member of the European Parliament, Shadow rapporteur)

14 Nov 2022 · discussion on the new Construction Products Regulation (CPR)

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Response to Prodcom list - topic industrial production statistics

27 Jul 2022

Glass for Europe, the trade association of Europe’s flat glass sector, would like to call on European authorities to amend some 6-digit level CPA codes and 8-digit level PRODCOM codes under the NACE codes C23.11 ‘Manufacture of flat glass’ and C23.12 ‘Shaping and processing of flat glass’. The proposed modifications are meant to better reflect technological developments in flat glass, in particular the advance of coated glass technologies. The shift of some existing PRODCOM codes from NACE code 23.11 to NACE code 23.12 would correspond to the production structure in the industry. Most activities of flat glass coating are done by undertakings classified under NACE 23.12 since the coating of glass is a processing activity and not a glass melting activity. The modification of PRODCOM codes would thus provide more consistency with the NACE classification of activities and its explanatory notes. The proposed change would also improve the reliability of statistics and avoid double counting. Today, a sheet of float glass once manufactured is reported under a 23.11 code but it is also counted a second time under another 23.11 code after that same sheet of glass has been coated by another company. This leads to a lot of double counting in manufactured flat glass sheets under NACE 23.11. The proposal would solve this problem since the glass sheet would rightly appear once as manufactured (23.11) and once as processed (23.12). PROPOSAL: 1. Rename CPA 23.11.12: Float glass and surface ground or polished glass, in sheets, having or not any layer but not otherwise worked This change is to clarify that any type of manufactured float glass shall be reported under one of the corresponding codes, i.e. ‘having or not any layer’. 2. Remove PRODCOM codes 23.11.12.12 , 23.11.12.14 and 23.11.12.17 These codes correspond to coated glass that we propose moving to NACE code 23.12. 3. Create a new CPA 23.12.14 Coated glass under NACE code 23.12 ‘Shaping and processing of flat glass’ 4. Create three new PRODCOM codes: 23.12.14.12 (with the same description as current 23.11.12.12), 23.12.14.14 (with the same description as current 23.11.12.14) and 23.12.14.17 (with the same description as current 23.11.12.17) The proposed changes would not necessitate new codes under the combined nomenclature used for external trade classification. They would only require some minor adjustments to the correspondence tables to ensure perfect alignment.
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Response to Review of the Construction Products Regulation

5 Jul 2022

As the EU trade association representing building glass manufacturers and fabricators in Europe, Glass for Europe welcomes the new CPR proposal since it reinforces the single market principles for construction products and supports the construction industry’s move towards greater sustainability. Based on the experience of building glass manufacturers and SMEs in the building glass value chain, Glass for Europe would like to offer the following suggestions to make the CPR more adapted to the realities of the construction sector: 1. Some simplified procedures need to be reintroduced to cut red tape for SMEs The simplified procedure that currently allows the recognition of test results obtained by another manufacturer should be re-introduced (see Article 36(1)(b) Regulation 305/2011). The numerous possible glazing configurations and the fact that identical components are used by several manufacturers make this procedure widely used by the glass sector since 2005 (see Guidance Paper M) without resulting in any issues. SMEs are the first beneficiaries since the duration and costs of certain tests can be substantial, while repeating tests brings no added value. The possibility to replace type calculation with technical documentation when specified in the harmonised technical specifications should also be re-introduced to reduce unnecessary red tape and costs, most particularly for SMEs. 2. The EU database and system must support the construction industry’s digitalisation and avoid over-prescriptive and outdated requirements. The concept of an EU database or system is welcomed if, instead of a classic centralised database, it is a smart system that can handle fully digitised and automated interactions for sharing and retrieving information from decentralised manufacturers’ systems. Indeed, all together, the glass sector represents several millions of active Declarations of Performance, and uploading data manually would increase the risk of mistakes and necessitate prohibitive human, financial, and technical resources for SMEs and flat glass manufacturers. 3. Utilise the CPR as a driver of sustainability in the construction sector Requesting manufacturers to give preference to recyclable materials is welcomed; it shall enhance the collection of end-of-life flat glass and allow glass production with less raw materials, energy, and CO2 emissions. Besides, If minimum recycled contents are introduced, they should be determined in collaboration with manufacturers to consider industrial, local, and recycling infrastructure realities. Regarding the traffic-light labelling scheme (Article 22 (6)(j)), giving a unique colour or indicator per glass product would mislead users since glass impacts depend on external factors like building design or climate. Only products whose sustainability characteristics do not depend on the application shall therefore be included in the scheme. Finally, certain conditions must be set regarding the request for manufacturers to regain ownership of surplus products (Article 22 (2)(j)). Returned glass products will most likely need to be destroyed and recycled since building glass panes are highly personalised bespoke products. Products that cannot be resold without unreasonable environmental and financial costs, should not be reimbursed by manufacturers when returned. 4. Strengthen CPR’s single market principles and maintain the structuring role of the European Committee for Standardisation (CEN) The continuous linkage of the CPR to the single market principles is a positive aspect of the new CPR. Articles 7 and 8 will reduce the risks of local interferences while the demand for Member States to establish a national information system (Article 77) should guarantee all actors’ comprehension of the CPR rules. Article 34 will also ensure that the complexity of the numerous glass products marketed in the EU is dealt with adequately by maintaining the major role of CEN in developing harmonised standards.
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

Achieving the target on CO2 emission reduction of at least 55% by 2030 as proposed by the European Commission , will require drastic cuts in buildings’ energy consumption and related emissions. The flat glass sector will play a key role in reaching a zero-emission building stock: up to 37% of the total buildings’ energy consumption can be saved in 2050 thanks to high-performance glazing products . The Energy Performance of Buildings Directive (EPBD) needs a thorough and coherent revision to support the EU’s climate-neutrality objective and realize the full potential of glazing in buildings. The proposal for a recast of the EPBD presented by the European Commission has the merits of translating the Renovation Wave pledges in operation policy measures and objectives. While the proposal is future-proof and in line with carbon reduction targets when it comes to the provisions for new buildings, more substance and provisions are needed in the renovation segment. To massively scale-up renovation, the EPBD should demand Member States to build capacity on the ground. The risk is otherwise high that buildings renovation rate remains too low and that, when renovations take place, sub-optimal energy-performance levels are delivered. Policy recommendations High-level of ambition in building renovation requires actions on the ground. The EPBD should include measures for - building capacity of local administrators, - supporting jobs creation and upskilling of workers in the construction sector, - facilitating the access to building permits. National building renovation plans should include mandatory minimum annual renovation rate of at least 3% per year and include plans for the phasing-out of inefficient building components such as single glazing and early uncoated double glazing. Minimum energy performance standards should be aligned to higher performance standards and anchored to the Energy Efficiency First principle. They should encourage deep renovation to ensure long-lasting CO2 and energy savings and prevent works carried with minimal energy-efficiency considerations.
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Response to Evaluation and revision of the Weights and Dimensions Directive

17 Feb 2022

Glass for Europe, the trade association for Europe’s flat glass sector, would like to thank the commission for this opportunity to provide feedback. While the harmonization aimed at by Directive 96/53/EC is welcomed to realize the internal market in practice, the minimum harmonization approach gives rise to limitations that prevent optimization of transport flows of flat glass products. This generates more trucks on the road and more GHG emissions. Against this background, we suggest reviewing Directive 96/53/EC as follow: 1. Make the maximum weight to enter a Member State identical to the maximum weight allowed on its national territory. Glass for Europe considers that transiting trucks that are heavier than the standard maximum weight but within the weight limit accepted by the bordering Member States, should be able to cross the border in the same way vehicles with the standard maximum weight would do. If two neighboring Member States similarly rose the maximum weight on their national territory, it can be considered that they both possess adequate infrastructure for heavier trucks and that they both consider the safety/environmental impacts of such vehicles acceptable. As long as this rule is absent from the directive, legal uncertainties will remain for operators crossing a border between countries in the abovementioned situation. Currently, a Member State can raise the maximum weight of trucks on its national territory but still refuses to let trucks of such weight pass its border. Alongside organizational burdens, such discrepancies increase the transport costs and contribute to higher GHG emissions from glass transportation. 2. Allow a maximum weight of vehicles of at least 44 tonnes for the transportation of flat glass. Alternative transport modes are used by the flat glass industry whenever relevant. Yet, road transport is likely to stay the main mode of transport for glass within Europe. A difference of 4 tonnes in trucks weight is non-negligible for the industry, considering that glass has a high volumetric mass density. As an example, the addition of 4 standard glass plates of 19 mm thickness each represents a weight of about 3.7 tonnes and amounts to adding only 7.6 cm of thickness over the entire length and height of the trailer. Increasing the maximum weight of trucks would permit a decrease in the CO2 emissions per tonne of transported goods and it could be done without changing the properties and configurations of the vehicles currently used. Glass for Europe thus suggests amending the Directive 96/53/EC to increase the maximum weight of all 5 axles (and more) vehicles to at least 44 tonnes. For an overview of the environmental and economic benefits of using heavier vehicles, see: https://doi.org/10.1080/01441647.2014.891161 https://doi.org/10.1016/j.sbspro.2012.06.992 https://doi.org/10.1016/j.trd.2004.09.006
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Meeting with Michael Bloss (Member of the European Parliament) and EUROMETAUX and

8 Feb 2022 · ETS

Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

The European flat glass sector takes it as its role to produce the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon-avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the EU’s climate neutrality objective, including by developing novel ways to lower its industrial emissions. It is Glass for Europe’s conviction that to achieve the ambitious target on CO2 emission reduction of at least 55% by 2030, drastic cuts in buildings’ energy consumption and related emissions are needed in Europe. High-tech glazing play a crucial role to make buildings more energy efficient, but flat glass technologies are also essential to the clean mobility transition and to renewable solar energy production. While the European Commission’s proposals for a recast of the Energy Efficiency Directive goes in the right direction, Glass for Europe believes that some improvements are needed: Article 4 - Energy efficiency targets - Upgrading the ambition of the energy efficiency target and making it binding at EU level will be instrumental to reach the 55% emissions cut by 2030. Nevertheless, to provide predictability to the industry and ensure accountability of Member States, national energy efficiency targets as well should be made mandatory. The European Commission should look in updating the Governance regulation on this point. Article 6 - Exemplary role of public bodies’ buildings - Glass for Europe supports the increased focus on building renovation in the EED recast. In particular, it welcomes the proposal to extend the 3% renovation requirements to all buildings owned by public bodies and the link to the EPBD Art 9. As proposed, Member States shall not be allowed to apply alternative measures. Article 5 - Exemplary role of public sector - Glass for Europe welcome the proposal to increase the level of ambition for energy savings obligations for public bodies, which can be leveraged to increase rates of building renovation. To concretely deliver on the Renovation Wave objectives, massive investment of the public sector in the renovation of public buildings are needed at the highest performance standards: school, social housing, and hospital should be prioritized. -Encouraging Member States to consider life cycle carbon emissions of their public bodies’ investment can positively support in decarbonizing the EU building stock. Nevertheless, any consideration should be supported and preceded by the introduction of a harmonized EU methodology to assess the whole life-cycle carbon emissions of new buildings. The revision of the EPBD will be instrumental on this aspect. Article 9 - Energy efficiency obligation schemes - Glass for Europe believes that Member States shall require obligated parties to support energy renovation among people affected by energy poverty. On the same topic though a different legislation, Glass for Europe is concerned that the extension of ETS to buildings may run counterproductive to the fight against energy poverty and may impact most the most vulnerable in society. - New and innovative financial mechanisms are needed to ensure that incentives to building renovation reach out small property owners to allow them to invest in the replacement of inefficient building components with a large impact on energy performance. For instance, incentives to window retrofitting should be generalised in all Member States. Article 26 - Availability of qualification, accreditation and certification schemes - The EED shall support both the level of competencies and employment of installers of building elements. A better skilled workforce will be able to respond to the increase in demand in construction sector and will facilitate the deployment of most advanced glazing solutions, including solar glass, switchable glazing, digital glass, etc.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Glass for Europe, the trade association of Europe’s flat glass sector, welcomes the opportunity to comment on the European Commission’s proposal for a Carbon Border Adjustment Mechanism. The European flat glass sector views its role as the producer of materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon-avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the EU’s climate neutrality objective, including by developing novel ways to lower its industrial emissions. With increased objectives in terms of CO2 emission reduction and a European industry faced with both high energy and EUAs costs, levels of investments to deliver the 2030 CO2 emissions objectives are largely increased while the industry’s investment capacity is impacted. Glass for Europe therefore welcomes all measures that could reduce carbon emissions globally, while preserving the competitive price of EU-made products. Although the flat glass industry is not one of the energy-intensive sectors considered for a pilot phase, we take this opportunity to point out critical factors for the development of a CBAM, which would benefit from being apprehended in light of our industry’s reality. The effectiveness of a CBAM will ultimately be conditioned by the versatility of the system and international trade partners’ buy-in. The WTO compatibility question is evident and will not be commented. The CBAM needs to preserve complex EU-based value-chains. If the costs generated by the new mechanism apply to primary materials only, there is a serious risk of provoking a shift in imports from the primary materials to (semi-)finished and higher value-added products, as a way to escape the new CBAM. This unintended consequence would be detrimental to both the upstream production and the downstream transformation activities and would cause a major threat to entire European value-chains. Therefore, any CBAM needs to be sufficiently versatile for an adequate coverage of the different value-chains and avoid loopholes. The CBAM proposal is complex. As it stands, it is open to loopholes. The definition of circumvention is currently too narrow and limited to slight product modifications. The proposal should better define and address circumvention risks (incl. resource shuffling, transhipment strategies or costs absorption). Beyond that, a future CBAM needs to indistinctively apply to all imported products regardless of their country of origin. More generally, any country exemption risks jeopardizing the mechanism and triggering opportunistic trade flows. Under the EU ETS, EU operators must comply with annual monitoring, reporting and verification requirements with data verified by an EU accredited verifier. Under the CBAM, the same level of control needs to apply to non-EU operators importing products to the EU. Emissions should be calculated and reported at installation level. Both direct and indirect emissions should be covered. Regarding benchmarks, they should be product-specific and based on reliable data, thus mirroring the EU ETS. Where proxy data has to be used for imports, the penalty should represent a sufficient incentive for third country producers to significantly reduce CO2 emissions. Following this logic, should a Cross Sectoral Correction Factor (CSCF) be applied in the EU, it would need to be reflected in the penalty. The new system must allow for a smooth transition for the European energy-intensive industry. In this regard, the co-existence of free allowances and CBAM needs to be preserved for a period of transition to alleviate any competitiveness shock on EU industries and their value chains. If the CBAM is tied with a reduction of free allocation to those covered sectors, a reallocation of allowances could be envisaged to avoid the application of a CSCF under the EU ETS.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The European flat glass sector takes it as its role to produce the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon-avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the EU’s climate neutrality objective, including by developing novel ways to lower its industrial emissions. The ‘Fit for 55’ package, aimed at delivering on the targets of EU’s climate ambitions, has introduced a revision of the Energy Taxation Directive. The revision proposal contains a deletion of the exemption for mineralogical processes (Article 3.1(b)). This raises a number of major concerns for the flat glass industry, which is part of the energy-intensive sectors with mineralogical processes. As the industry moves towards decarbonisation, increased electrification is one of the routes identified to decrease CO2 emissions from glass manufacturing. The flat glass industry should therefore be incentivised to use more electricity but the EU policy framework runs counterproductive to this objective: the flat glass industry is not entitled for compensation for its indirect costs under the EU ETS, which is very problematic, and it is now proposed in the Energy Taxation Directive to withdraw the exemption which covers this sector. The impact would be especially strong since the EU industry has been faced with soaring energy prices, which have not only exponentially grown but have increased at a higher rate in Europe compared to other parts of the world. The flat glass industry is characterised by a significant share of its production costs attributable to energy costs, primarily from natural gas but also from electricity. It has been shown by the studies on energy prices and costs conducted for DG ENER and DG GROW that energy costs represent more than 30% of production costs and, in certain years, this proportion has gone up to 39%, as documented in those studies. The current energy price increase is likely to adversely impact the EBIDTA and therefore the sector’s global competitiveness. Higher electricity costs are also susceptible of reining in the deployment of electrification. In this context, an additional increase of energy costs should be avoided. The criteria and methodology based on which the mineralogical processes have been excluded from the exemption list are missing from both the revision proposal as well as from the Impact Assessment accompanying it. There is no clarity regarding the reasoning behind this exclusion, nor is there an evaluation of the effects of lifting the exemption. The flat glass industry considers that the proposal to lift the exemption will have a significant negative impact on its global competitiveness and its ability to invest in new technologies to reduce its CO2 emissions. Mineralogical processes are currently exempted from the scope of the EU Energy Taxation Directive alongside the chemical, electrolytic and metallurgical processes. It is our belief that the same treatment must continue to be applied to all processes under the exemption regime in order to maintain the level playing field among EU industries on the EU internal market. The flat glass sector, together with other mineralogical industries therefore calls for the exclusion of mineralogical processes from the scope of the Energy Taxation Directive by keeping the current exemption in Article 3.1(b). A common request is attached.
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Glass for Europe calls for Market Stability Reserve reform to prevent free allocation cuts

3 Nov 2021
Topic — Reform of Market Stability Reserve rules for EU Emissions Trading System industrial allowances.
Message — The organization requests that allowances from one-off rebasing be diverted to free allocation when needed to prevent Cross-Sectoral Correction Factor application. They argue CSCF breaks the link between allocation and industrial realities as reflected by product benchmarks.123
Why — This would protect their free emission allowances and reduce compliance costs during decarbonization transition.45
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Glass for Europe urges protection from carbon leakage risk

3 Nov 2021
Topic — EU Emissions Trading System revision to achieve 55% emission reduction by 2030.
Message — The association requests avoiding cross-sectoral correction factor, maintaining free allocation protections, and ensuring ETS reflects industrial realities. They support lifting maximum reduction rates for product benchmarks and welcome Innovation Fund support for research into emission-reducing technologies.123
Why — This would protect their production base from international competition and reduce compliance costs.45
Impact — Environmental groups lose stronger carbon pricing if free allocations continue without stricter conditions.6
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

17 Mar 2021

The Energy Performance of Buildings Directive (EPBD) is the backbone of the European Union policy for energy efficiency in buildings. Glass for Europe, the trade association of Europe’s flat glass sector, believes that the EPBD should be amended (option 3) to translate into legislation the Renovation Wave and tackle the inefficiencies which have been overlooked during the 2018’s review. EU buildings remain the largest energy consuming sector in Europe, where strong efforts are needed for a revised 2030 energy efficiency objective. To Glass for Europe, this is because the current EU legislative framework has proven effective for new constructions but has missed to trigger energy-efficient renovations of buildings. Renovation is not happening at sufficient speed and when it does take place, sub-optimal products are often used due to a lack of legal or financial incentive and/or information to consumers. Glass for Europe believes the Energy Performance of Buildings Directive (EPBD) needs to be reviewed to trigger upgrades in national building codes and ensure long-lasting CO2 emission reductions: - Milestones included in the National long-term renovation strategies should be aligned to the sector-specific objective for building to be set in the EED. - Mandatory minimum energy performance standards (MEPS) attached to trigger points in the lifetime of buildings, should be included in the EPBD. They need to be linked to high-performance standards to avoid that renovations are carried with minimal energy-efficiency considerations. - National methodologies setting minimum energy performance standards for building components should go beyond the “cost-optimality” criterion to ensure compatibility with the climate neutrality objective and thus avoid CO2 lock-in effect in the building sector. - Building passports must be introduced next to Energy Performance Certificates. The EPBD should ensure a proper evaluation of all energy-related aspects impacting the performance of building elements such as windows and glazing: - Stricter guidance should be given to Member States for the purpose of determining the performance levels according to the climate neutrality criterion. - Member States should be asked to improve the methodology defining the minimum performance requirements of transparent components of the building envelope. These must be assessed by way of the energy balance. - The calculation of the energy performance of a building should be based strictly on its energy needs. Therefore, the possibility given to Member States to consider both on-site and off-site renewables in the calculation of the primary energy factors for the purpose of calculating the energy performance of buildings should be removed. In 2019, Glass for Europe commissioned a study on energy savings and CO2 emission avoidance of high-performing glazing to the independent research institute TNO Built Environment and Geoscience (TNO). This study identifies energy and CO2 savings that can be realised thanks to high-performance glazing across the 28 EU Member States in both horizons 2030 and 2050. In addition to full potentials, whereby all windows are equipped with high-performance glazing across all EU buildings, it also simulates the impacts of several window replacement rates, all compared to a baseline scenario. The full study is attached to this answer.
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

The European flat glass sector takes it as its role to produce the materials essential for conducting energy-efficient renovations of buildings, for supporting clean mobility with lighter and thermally efficient automotive glazing and for increasing the share of renewable solar energy in Europe. Considering that these above usages represent over 99% of flat glass production, Glass for Europe considers that its manufacturing activities should be covered under the taxonomy with adequate technical screening criteria. In this respect, Glass for Europe would like to comment on three items of annexes 1 and 2 of the draft delegated act. 1. NACE code C23.12 to be added under sections 3.4 In both Annexes, section 3.4 ‘Manufacture of energy efficiency equipment for buildings’ rightly identifies the manufacturing of high-performance windows and their key components. All NACE codes covering the production of such windows and their key components are listed but one. NACE code C23.12 ‘Shaping and processing and flat glass’ is missing and should be added to the list. This code is essential since it covers the fabrication of insulating glass units (IGU), i.e. the required ‘double or triple glazing’. The IGU (Prodcom code 23.12.13.30) represents between 70 and 80% of the surface of a window and is a key component affecting efficiency, see the recent TNO study on CO2 savings from glazing (visit www.glassforeurope.com. Both NACE codes C23.11 and C23.12 should be covered: flat glass production and application of high-performance coatings (C23.11) and cutting and fabrication of high-performance IGUs (C23.12). 2. 0.7 W/m2K U value for windows needs to be amended In the section 3.4 of both annexes, the technical screening criteria on contribution to climate change mitigation / adaptation is defined as ‘windows with U-value lower or equal to 0,7 W/m2K’. Glass for Europe wishes to state that it is impossible to define a unique set of energy performance specifications for windows in all buildings across Europe and that the U-value of a window is only one of several parameters that affect the energy performance of products. However, Glass for Europe recognises that a simple indicator needs to be used for the purpose of the Taxonomy. Glass for Europe wishes to stress that while windows of a U-value lower or equal to 0,7 can be technically delivered, these are adapted to Europe’s most northern and coldest climates only. They are unnecessary to reach nearly zero energy standards across most of Europe therefore they are likely to remain expensive niche products. Setting such a U value for window manufacturing in the Taxonomy could run counter-productive to the EU Renovation Wave’s ambition to increase energy efficient renovations of buildings and could hinder affordability of window replacement. Based on the above and after discussion with window manufacturers, Glass for Europe suggests that the technical criteria is rephrased accordingly: ‘U-value lower or equal to 1,0 W/m2K’. Such a performance level is more challenging that minimum performance requirements set by most Member States according to the EPBD (study enclosed) and requires the use of highly-thermally insulating glazing units that massively contribute to decarbonising EU buildings. Such an ambitious performance level would already send a strong signal to investors and support the industry’s efforts in developing ever-better performing products adapted all European climates. 3. Manufacture of low carbon technologies for transport Glass for Europe regrets that both flat glass NACE codes, i.e. C23.11 and C23.12, are not listed under the heading 3.3 ‘manufacture of low carbon technologies for transport’ considering that the glazing specification can have a sizable impact on the efficiency and CO2 emissions from transport vehicles. Glass for Europe would like to engage in defining technical screening criteria for these components of low carbon transport in a future work on taxonomy.
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Glass for Europe demands better consultation on carbon leakage risk

24 Nov 2020
Topic — A review of the EU Emissions Trading System to align with 2030 climate goals.
Message — The sector calls for a proper consultation to correct methodological errors in assessing carbon leakage risks. They specifically request data extraction at a more granular level and more realistic growth projections.123
Why — More accurate data would likely show higher trade intensity, securing better protection against carbon costs.4
Impact — Non-ETS glass processors currently skewing sector data would no longer be included in the specific risk assessment.5
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Sept 2020

Glass for Europe, the trade association of Europe’s flat glass sector, believes that an upwards revision of the 2030 Energy Efficiency target is necessary to align energy efficiency measures to the increased climate ambition. In addition, to ensure immediate and long-lasting energy savings, binding sectoral objectives should be included to ensure that Member States concentrate their efforts towards the sectors with the highest energy savings potentials, namely building and transport. The last EED review (2018) was not designed to achieve at least a 50% climate ambition by 2030 and has become quickly obsolete. To address the gap and allow energy efficiency policies to reach their full decarbonisation potential, the EU should timely equip itself with ambitious energy efficiency objectives. In particular, the energy efficiency target of 32.5% for 2030 should be amended for a binding reduction of at least 40%. Far from being an ancillary initiative, energy efficiency must be considered as Europe's largest domestic energy source and come first in all political decision. The achievement of higher energy savings will happen if the EU can rely on a holistic plan: European Green Deal initiatives must be mutually reinforcing and work coherently as pieces of the same puzzle. This increase in ambition shall be followed by urgent initiatives at all levels of governance. The EU will most likely fail to achieve its 2020 energy efficiency goal, notwithstanding the reduction in energy consumption due to COVID19. This is primarily resulting from the lack of ambition and actions targeting the building sector in the EU. Europe’s building stock is not fit for carbon neutrality and, more worryingly, current trends in terms of building renovation clearly indicate that it will not be fit in 2050 nor in one hundred years if Europe does not review the policy it has pursued for the last decade and does not scale up financial resources (building energy renovation rate is stagnating below 1% per year). The state of the EU building stock and current renovation levels are a clear signal that the first deep renovation Europe needs is legislative. The European Union cannot limit itself to a mere communication, limited and complex financial mechanisms and the continuation of legislations that have demonstrated to be inefficient for most of the building stock. Glass for Europe agrees that the initiatives announced in the Green Deal have the potential to generate substantial energy and CO2 savings. In particular, the flat glass sector wishes to highlight the importance of the building sector and circular economy in industry. The flat glass sector has contributed to a recent TNO study highlighting a potential for massive energy consumption and emissions in buildings thanks to high-performance glazing (up to 29% in 2030[1]). These savings are conditioned by an increase in the annual building renovation rate and use of high-performance glazing. Two concrete measures the European Union can do by way of a mandatory minimum annual renovation rate of 3% and the upgrading of minimum energy performance requirements for windows. Regarding the modelling of buildings for the calculation of savings scenario, Glass for Europe calls on the European Commission services to consider realistic consumer behaviour scenarios for properly informing the decisions to be taken. Variables such as the insulation performance of buildings and building products or the efficiency of heating and cooling systems should have precedence over potential changes in consumer behaviour (e.g. reducing indoor air temperature). Links Flat glass in climate-neutral Europe - https://glassforeurope.com/wp-content/uploads/2020/01/flat-glass-climate-neutral-europe.pdf Glazing savings and CO2 emission reduction - https://glassforeurope.com/wp-content/uploads/2019/05/Glazing_potential_brochure_2019.pdf [1] Potential impact of high-performance glazing on energy and CO2 savings in Europe, TNO, 2019.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Glass for Europe welcomes the European Commission’s initiative on Environmental product performances’ claims and supports the objective to limit the number of methods to evaluate the environmental impacts of the products. The roadmap highlights the central role of the Product Environmental Footprint (PEF) methods to reach this objective. While the PEF method can be defined as such with its methodology directly applicable for many generic products, it is necessary to recognise the EN 15804 + A2 standard as the adequate method for the environmental assessment of construction products. This standard, edited by the European Committee for Standardization (CEN) TC 350 over a decade to assess the construction products, has been reviewed in 2019 to be aligned with the PEF main methodology. Following this logic, the Product Category Rules (PCR) developed in conformity with EN 15 804, such as the EN 17074:2019 for flat glass products, should be recognised as equivalent to PEFCRs. With these recognitions taken into account, Glass for Europe supports a voluntary EU legal framework enabling companies to make green claims on construction products based on EN 15804 +A2 standard, that is considered equivalent to the PEF method.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The European flat glass industry welcomes the European Union’s desire to engage in a Renovation Wave of public and private buildings, as announced in the European Green Deal, and is ready to deliver the high-performance glazing EU buildings need to become carbon-neutral by 2050. Europe’s building stock is not fit for carbon neutrality and, more worryingly, current trends in terms of building renovation clearly indicate that it will not be fit in 2050 nor in one hundred years if Europe does not review the policy it has pursued for the last decade and does not scale up financial resources. Europe’s buildings are aged and high energy consuming, despite a broad range of products available to cut their energy demand. For example, high-performance glazing could save around 37% of energy consumed in buildings in 2050 with a total contribution potentially higher when innovative products such as switchable/electrochromic glazing, hyper-insulating glazing or glazing-integrated photovoltaics become mainstream. In the recent years, progress has been made to increase the energy and CO2 performance of new buildings thanks to EU legislation , yet this is merely the tree that hides the forest. 97% of today’s building will have to be renovated by 2050 to achieve climate neutrality, while less than 1% of buildings are renovated in Europe every year . Renovation is not happening in sufficient quantity and when it does take place, sub-optimal products are often used due to a lack of legal or financial incentive and/or information to consumers. The state of the EU building stock and current renovation levels are a clear signal that the first deep renovation Europe needs is legislative. The European Union cannot limit itself to a mere communication, limited and complex financial mechanisms and the continuation of legislations that have demonstrated to be inefficient for most of the building stock. This paper proposes several concrete actions to give substance to the renovation wave to cut emissions and relaunch the economy.
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Response to 2030 Climate Target Plan

15 Apr 2020

Glass for Europe, the trade association of Europe’s flat glass sector, supports the EU objective to achieve climate neutrality by 2050. For the flat glass sector, it stands clear that reaching climate-neutrality by 2050 will require an unprecedented transformation of the European economy and that the European Union needs intermediary targets and milestones. Glass for Europe agrees with the European Commission that mitigation potentials differ strongly among economic sectors and the right balance between the different contributing sectors will have to be found to achieve a higher mitigation responsibly. In January 2020, the flat glass industry has released a publication, ‘2050 Flat glass in Climate-neutral Europe’, to contribute to the analysis on the emission reduction potential in the EU economy. The contribution includes figures on the reduction of emissions possible by using available flat glass products, such as insulating glass units in the building sector, and on the theoretical maximum reduction potential for flat glass manufacturing. The document can be downloaded on Glass for Europe’ website: https://glassforeurope.com/wp-content/uploads/2020/01/flat-glass-climate-neutral-europe.pdf Based on this expert work, Glass for Europe would like to stress some key elements to be considered by the European Commission when assessing the proposal for an increase in its GHG emission reductions target for 2030 and policy updates to be tabled in 2021: 1°) Regarding the potential for emission reduction in the industry: it is primarily conditioned by the availability of technologies to reduce emissions, the uptake of best available technologies in the sector, the availability of infrastructures (e.g. CCS or CCU, recycling facilities), and the availability of carbon-neutral energy. It must be accounted that flat glass manufacturing is limited in its 2030 reduction potential by these conditions. An additional factor will play an important part in the variation of total emissions: demand for its products, which cannot be substituted and are necessary to decarbonise buildings and transport. Finally, the investment capacity of the industry for the research and development of disruptive manufacturing technologies is an emerging concern in view of the heavy economic impact of COVID19 on the sector’s finance. 2°) Regarding the potential for emission reduction in the building sector (energy demand): this potential depends on two main variables: the renovation rate of the building stock and the performance of the products installed. One cannot disregard the second considering that some building products are to stay for over thirty years and create lock in if sub-optimal products are installed. Therefore, when assessing the potential in the building sector and more importantly the practical measures to be implemented to activate this potential by 2030, the European Commission should consider both increasing the renovation rate and reviewing the minimum performance requirements for building components (and additional mechanisms to incentivise the uptake of most efficient products). One last element to consider for modelling the building sector is the introduction of realistic consumer behaviour scenarios. In the Clean Planet for All - Impact Assessment, a number of variables have been modified including the indoor temperature for the activation of heating systems, which artificially lowers energy needs. Such unrealistic changes are misleading and prevent from identifying the need to adapt the legislative framework to effectively reduce emissions and achieve targets. It should be avoided for properly informing decisions to be taken.
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Response to Carbon Border Adjustment Mechanism

25 Mar 2020

Glass for Europe, the trade association of Europe’s flat glass sector, takes note that the European Commission is considering tabling a legislative proposal to introduce a carbon border adjustment mechanism in EU law. Flat glass manufacturing is an energy intensive activity covered under the EU ETS and the flat glass sector is considered at high risk of carbon leakage. The flat glass sector has embraced the climate neutrality direction provided by the European Green Deal and issued in January 2020 its 2050 vision to maximize its contributions to this societal objective. In particular, the European flat glass sector takes it as its role to produce at a competitive price the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon-avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the carbon neutral transition, including by developing novel ways to lower its industrial emissions. The European flat glass sector agrees that all measures that could potentially reduce industrial emissions globally, while preserving a competitive advantage for EU-made low-carbon industrial goods which are needed to the EU transition towards climate-neutrality, should be carefully analysed before a legislative proposal is tabled. To contribute to the in-depth analysis of the border adjustment mechanism, the flat glass sector wishes to present the following elements for consideration: The inception mentions in its analysis of the social impacts of inaction that the scenario to be compared to a BAM is “i.e. increasing the EU climate ambition without any new measures addressing carbon leakage.” To Glass for Europe’s views, the decision-makers would benefit from a comparison of a broader range of scenarios to ensure the proportionality of the new measure (both in EU and WTO legislations). The scenarios could include: - Scenario 0: no carbon leakage protection to industry; - Scenario 1: continuation of the carbon leakage protection to industry exposed to risk of carbon leakage with free allocations at the level of the benchmark; - Scenario 2: introduction of a border adjustment mechanism replacing the free allocations to industry exposed to risk of carbon leakage; - Scenario 3: introduction of a border adjustment mechanism with continuation of carbon leakage protection measures under the format of possibly-reformed systems of free allocations The three scenarios plus the scenario 0 (no carbon leakage protection to industry) would benefit from additional variables to be considered, such as: - Industrial sectors included in the border adjustment mechanism - Date of entry into force of the border adjustment mechanism - Revision of the 2030 target and different levels of contribution for the EU ETS sectors In addition to the scenarios, some further elements would be worth considering in the future impact assessment: - In the analysis of the effects on the price of consumer products, to pay attention to mechanism such as offer and demand effects in the segments were the demand for industrial goods is expected to increase. This is particularly relevant for the construction sector with the renovation wave announced by the Green Deal; - In the analysis of the social and economic impact of the products, to pay attention to the impact on the value-chains (in particular for complex value-chains). If the BAM was to be applied to primary material, a risk assessment of an increase in imports of transformed products should be considered to provide a full picture on its social and economic impact. - Regarding the analysis on the administrative burden, it is necessary to include control measures in third countries since fraudulent declarations are already observed from certain countries.
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Response to Climate Law

25 Mar 2020

Glass for Europe, the trade association of Europe’s flat glass sector, welcomes the proposal from the European Commission to enshrine in law the objective for the EU to achieve climate-neutrality by 2050. The flat glass sector has embraced the climate neutrality direction provided by the European Green Deal and issued in January 2020 its 2050 vision to maximize its contributions to this societal objective. In particular, the European flat glass sector takes it as its role to produce at a competitive price the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the carbon neutral transition, including by developing novel ways to lower its industrial emissions. In this context, Glass for Europe would like to highlight 4 points concerning the proposed climate law (see position paper enclosed)
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Response to Climate Law

4 Feb 2020

Climate Law The first step towards carbon neutrality Europe’s flat glass sector is working in the climate neutrality direction provided by the European Green Deal published on 11 December 2019. The European flat glass sector takes it as its role to produce at a competitive price the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe. While already providing net carbon-avoidance products, the flat glass sector is looking into ways to massively scale up its contributions to the carbon neutral transition, including by developing novel ways to lower its industrial emissions. The European Green Deal announces an unprecedented transformation of the European economy which requires certainty and predictability to bring all EU actors on board. Therefore, setting the climate neutrality objective by 2050 in law is a logical initial step to set the long-term direction and steer all relevant policies. Ultimately, it is the measures to attain the objectives to be set in the climate law which will matter the most. While the climate law roadmap published by the European Commission considers that setting intermediary targets could “facilitate” the achievement of the 2050 climate-neutrality, Glass for Europe believes that intermediary targets are most important at sectoral level to define the expected contribution of each sector of the economy to the overall reduction objective. The European Union, its’ Member States, economic actors and citizens need to have a clear understanding of where efforts need to be focused on the short, medium and long term. Attention should also be paid to the credibility of the intermediary objectives which is directly linked to the availability of technologies and infrastructures, magnitude of the changes required (e.g. legislative, business model, consumer behaviour), and time to proceed to adaptations.In the event that the reduction objective for 2030 was to be reviewed, the new overall target and sectoral objectives shall be defined in a socially-fair and cost-efficient manner taking into account the limited time left to proceed to adaptations. The sequencing of the transition measures will also be crucial. For instance, the availability of low-carbon energy sources needs to be guaranteed for an industrial actor to rely solely on this energy source for its operations. Infrastructures need to be available to provide certainty and secure investments in the transition. A second element calling for a well-designed sequencing of the actions is that the carbon budget left is limited. In the sectors where solutions to decrease emissions are already available and offer a high reduction potential, such as the building sector, actions should be undertaken without undue delay. The objective of doubling the renovation rate should be made legally binding and the minimum performance requirements of building components upgraded to avoid carbon lock-in. In the sectors where solutions are not yet available, measures are urgently needed to unlock new CO2 savings reduction potentials; such as the support to research and the development of infrastructures.
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Glass for Europe urges dynamic free allocation in ETS rules

9 Jul 2019
Topic — The consultation concerns updating rules for determining free carbon emission allocations to industrial installations.
Message — Glass for Europe requests a dynamic system where carbon allowances adjust proportionally to actual production changes. They want 2019 and 2020 data included in the 2021 collection to ensure immediate adjustments. They also argue against removing allowances for single years of zero production.123
Why — These measures would help the glass industry avoid the sudden loss of free carbon allowances.45
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Response to Draft Commission Regulation establishing the “PRODCOM List” of industrial products

7 Jun 2019

Glass for Europe is the trade association for Europe’s flat glass sector. Flat glass is the material that goes into a variety of end products, primarily in windows and facades for buildings, windscreens and windows for automotive and transport as well as solar energy equipment, furniture and appliances. Glass for Europe would like to highlight issues concerning the current PRODCOM codes under the NACE code 23.11. The main problems are the following: - An improper classification of installations under the NACE code 2311 - The current classification of coated products into NACE 2311 is misleading and conduct to a wrong assessment of the quantity produced, turnover and trade indicators of the sector - Product classification is no longer adequate to reflect the range and different types of products effectively produced and traded. More information are available in the document attached.
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Response to Carbon Leakage List 2021 - 2030

2 Nov 2017

Glass for Europe, the association representing the European flat glass sector, welcomes the European Commission’s consultation on the Inception Impact Assessment. Some directions on the methodological approach will be determined at this stage with direct consequences on the evaluation of the sectors covered by the EU ETS and in particular their level of exposure to risk of carbon leakage. As stated in the Inception report, the EU ETS framework for the fourth trading period and analysis of the risk of carbon leakage, requires several types of assessments to be conducted based on new data and methodological choices. Glass for Europe agrees that methodological choices will require the following parameters to be assessed and considered before the carbon leakage list is established: emission factor for electricity, assessment of other countries' climate policies, and the framework for additional assessments, and in particular the disaggregated assessments. On this matter that is highly important for the flat glass sector, Glass for Europe welcomes the European Commission's commitment to ensure comparable level of robustness to ensure transparency and equal treatment among sectors. In light of the new parameters to be considered in the future impact assessment, Glass for Europe recommends to include in the data sources the cumulative cost assessments (CCA) of the industrial sectors carried on under the umbrella of the European Commission services. To achieve its objective of assessing the costs generated by EU legislation on the flat glass sector, including climate policy, the CCA report (published in July 2017 by the European Commission, enclosed) provides an unprecedent statistical analysis of the sector’s activities in Europe and a comparison with competing border countries. It therefore provides valuable data on carbon direct and indirect costs, production cost comparison with Russian sites and methodological inputs on the statistical data to be used to ensure consistency in the assessment of the sector. To ensure homogeneity in products and manufacturing activities analysed, the CCA is based on an assessment at a disaggregated level (Prodcom-8 level) for the flat glass sector. By contrast with NACE-4 assessment, disaggregation to Prodcom 8 level is necessary to distinguish flat glass processing and transformation activities, which are not covered by the EU ETS, from the glass melting sites covered by EU ETS. To conclude, the CCA provides, based on a highly representative sample, a detailed and robust set of data highly relevant to EU ETS’ carbon leakage assessment and its impact assessment. Glass for Europe therefore proposes that the CCA study on the glass sectors to be added as a data source to conduct the Impact Assessment.
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