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ROCKWOOL A/S

ROCKWOOL Group

ROCKWOOL is a global leader in insulation products for residential and non-residential buildings, contributing to energy efficiency, fire safety, and comfortable indoor climates.

Lobbying Activity

Response to Classes for resistance to fire

17 Dec 2025

ROCKWOOL supports the migration of existing reaction-to-fire and resistance-to-fire performance classes into the new CPR framework. These classes are a key tool for Member States when defining pre-accepted and material-based fire-safe design solutions in their regulations. They allow cost-efficient construction while maintaining a high level of fire safety. It is essential that the well-established classes under CPR-2011 can continue to be applied seamlessly under CPR-2024. Please see attached document for further feedback.
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Response to Classes for reaction to fire

17 Dec 2025

ROCKWOOL supports the migration of existing reaction-to-fire and resistance-to-fire performance classes into the new CPR framework. These classes are a key tool for Member States when defining pre-accepted and material-based fire-safe design solutions in their regulations. They allow cost-efficient construction while maintaining a high level of fire safety. It is essential that the well-established classes under CPR-2011 can continue to be applied seamlessly under CPR-2024. Please see attached document for further feedback.
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Rockwool seeks EU-wide harmonisation to scale construction waste recycling

6 Nov 2025
Topic — The Circular Economy Act aims to improve EU sustainability and material security.
Message — Rockwool proposes mandatory EU-wide producer responsibility and landfill bans for recyclable products. They want material-specific targets that account for volume rather than just mass.12
Why — Harmonised regulations would make the company's recycling programme commercially viable across Europe.3
Impact — Producers of non-recyclable materials would face higher taxes and fees.4
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Meeting with Niels Fuglsang (Member of the European Parliament) and The Coalition for Energy Savings

6 Nov 2025 · Energy

Rockwool urges EU to harmonize building carbon emission standards

31 Oct 2025
Topic — EU consultation on establishing a framework for calculating life-cycle global warming potential of buildings.
Message — Use the latest standards and all life-cycle stages for uniform implementation across the EU. Prioritize verified product-specific data over inconsistent generic information or average values. Reward durability by reflecting strategies that extend building lifespans and reduce material turnover.12
Why — Consistent rules would prevent high-durability products from being unfairly penalized by short-term assessment models.3
Impact — Producers of short-lived materials lose out when the framework rewards long-term durability and circularity.45
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Meeting with Pierre Schellekens (Director Energy)

17 Oct 2025 · Industry perspective on efficiency and buildings performance

Meeting with Jessika Roswall (Commissioner) and

15 Oct 2025 · To discuss REACH revision

Insulation Giant ROCKWOOL Calls for Industrial Electrification Subsidies

9 Oct 2025
Topic — A European Commission initiative to accelerate the transition from fossil fuels to electricity.
Message — The company calls for direct funding and operating support to bridge the price gap between electricity and fossil fuels. They argue that grid connection delays and high costs must be addressed to protect industrial competitiveness. Furthermore, building insulation must be included to avoid increasing total system costs.123
Why — These policies would reduce factory conversion expenses and secure long-term demand for stone wool.45
Impact — Energy consumers and other sectors suffer from higher costs if buildings remain inefficient.6
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Confederation of Danish Industry and

18 Sept 2025 · Erhvervsnetværk - Sustainability omnibus

ROCKWOOL Group urges equal state aid for stone wool products

5 Sept 2025
Topic — Update of rules for compensating energy-intensive users for indirect carbon emission costs.
Message — ROCKWOOL Group asks the Commission to include stone wool on equal terms with glass wool. This would ensure a level playing field and support the industry's green transition.12
Why — This would allow the company to receive state compensation for its electricity costs.34
Impact — Glass wool manufacturers would lose their current competitive advantage in the insulation market.5
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Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

30 Jun 2025 · Chemicals

Meeting with Jessika Roswall (Commissioner) and

12 Jun 2025 · EU’s Industrial and Sustainability Agenda

Meeting with Elisa Roller (Director Secretariat-General)

12 Jun 2025 · Energy efficiency and its importance for the EU’s decarbonisation and competitiveness goals, as well as on existing and planned EU initiatives supporting energy efficiency, decarbonisation and competitiveness.

Meeting with Rosalinde Van Der Vlies (Director Energy) and

12 May 2025 · High-level Stakeholder Dialogue on 20 May

Meeting with Dan Jørgensen (Commissioner) and

27 Mar 2025 · Housing

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Martin Engell-Rossen (Cabinet of Commissioner Dan Jørgensen)

13 Feb 2025 · European building renovation industry

Meeting with Ditte Juul-Joergensen (Director-General Energy)

17 Dec 2024 · Competitiveness and energy Transition

Meeting with Maroš Šefčovič (Executive Vice-President) and

23 May 2024 · Green transition and 2040 climate target

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur)

3 Oct 2023 · EPBD

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Nordea Bank Abp and

24 May 2023 · REACH revision

ROCKWOOL urges revised recycling targets and stricter chemical controls

3 May 2023
Topic — The initiative establishes criteria for sustainable economic activities contributing to EU environmental goals.
Message — Rockwool proposes a uniform 85% virgin material limit for mineral wool insulation. They also advocate for expanding water-saving categories and restricting hazardous flame retardants.123
Why — These changes would lower compliance hurdles and increase financing opportunities for their technologies.45
Impact — Manufacturers of plastic foam insulation face competitive disadvantages from proposed restrictions on flame retardants.67
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Meeting with Ciarán Cuffe (Member of the European Parliament)

8 Mar 2023 · Fire safety in Buildings (Speaking event)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

3 Nov 2022 · Energy Efficiency

Rockwool urges EU to protect trade secrets in emissions rules

20 Jun 2022
Topic — Revision of EU rules on industrial emissions to improve environmental and health standards.
Message — Rockwool requests making energy efficiency requirements mandatory for all sectors. They call for protecting proprietary manufacturing procedures by not making full transformation plans public. Additionally, they advocate for achievable emission limits instead of the lowest possible values.123
Why — Streamlined permits would allow them to expand production capacity much faster.45
Impact — Environmental groups lose access to granular data on how factories manage pollution.67
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Meeting with Niels Fuglsang (Member of the European Parliament)

31 May 2022 · Energy

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

18 Mar 2022

While the Commission's proposal has many good elements like Minimum Energy Performance Standards (MEPS), harmonised Energy Performance Certificates (EPC) and establishment of National Building Renovation Plans (NBRP) it fails to deliver on renovation depth and to capture the multiple benefits associated with a highly energy efficient building stock. Regarding MEPS it must be ensured that F and G buildings from the beginning are renovated to a high standard (minimum C or higher) together with a clear timeline for the future development of MEPS, laying out when all buildings (not just energy classes F and G) over time should be renovated to ZEB level. A general concern in the proposal is that the energy performance of the building envelope is being disregarded with the sole focus being on decarbonising the energy supply. Buildings have a long lifetime and must be robust for changing conditions. Overlooking the performance of the building envelope not only risks locking in future saving potentials but also leaves behind the multiple benefits connected with highly energy efficient buildings like reduced energy costs and improved health and indoor climate. Using primary energy consumption as the only metric to describe the NEB standard will not secure the building envelope being optimized. Therefor a future ZEB standards should be defined with thresholds for both primary and final energy demands. A future ZEB standard implemented from 2030 should reflect current best practice and not be a step backwards for the development that countries already have gone through regarding energy efficiency in new buildings. We find the benchmark values for ZEB in Annex III to be unambitious for a future new building standard. Finally, in order to define regulatory limits for life-cycle GWP in future regulation, there is a particular need to improve and harmonise the data quality of LCA calculations. In addition, where national calculation tools are used, they shall be required to meet the minimum criteria laid down by the Level(s) framework.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

1 Jun 2021

As the leading European manufacturer of fire safe stone wool insulation, ROCKWOOL Group appreciates the Commission's dedicated work on creating an EU Taxonomy to facilitate climate action-compatible investments and to increase transparency in companies’ environmental performance. ROCKWOOL Group is a listed company in accounting class D, with more than 11.500 employees and required to publish non-financial information pursuant to the Non-Financial Reporting Directive (NFRD). We fully support the request for large companies to disclose aggregated key performance indicators related to Taxonomy aligned turnover, capital expenditure and operational expenditure. However, we are deeply concerned about the proposed level of granularity in the draft delegated act specifying the methodology to comply with the disclosure obligation, going far beyond the level needed by investors for their decision making. Within our business, the proposal in its current form, will seriously harm the competitiveness of our industry both within and outside the EU. EU companies will be asked to disclose business sensitive information, providing competitors with unnecessary and valuable information regarding turnover of individual business activities, investment plans etc. If companies have to disclose data on activity level, it will be easy for competitors to identify size and performance of smaller business areas and the development of a given activity or new business area within the company over time. As a minimum a “notability threshold”, e.g. 10% of total turnover, in line with the International Financial Reporting Standard on segments, should be introduced for reporting on activity level, to support new innovations and protect smaller businesses. Activities below the notability threshold could be reported as part of an aggregated activity. While we do not support the proposed level of granularity to be part of a mandatory disclosure in public reporting, we would recommend, as a better route for compliance, to request an external audit by 3rd party based on the detailed templates in Annex II (Templates for the KPIs of non-financial undertakings). Leaving it voluntary for companies to decide for a more detailed level of disclosure if acceptable from a competition perspective. Furthermore, we find the requirement in Article 9 (3) that requires companies to disclose the key performance indicators covering the previous five reporting periods to be overly burdensome and out of fit with current management reporting which typically requires only one period of comparison. If five years are required, there should be a transition period of five year, allowing one more comparison year to be added per year without any retrospective considerations. Finally, we fully support extending the scope of NFRD requirements to include all large companies, whether they are listed or not and without the previous 500-employee threshold as suggested by the Commission in the Corporate Sustainability Reporting Directive proposal from April 2021.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

11 May 2021 · meeting on Renovation

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

19 Mar 2021

ROCKWOOL fully supports an early revision of the EPBD (option 3) to become an effective tool to deliver on the Renovation Wave and to align ambition with the “fit for 55% package”, delivering 25 mio deeply renovated dwellings by 2030. However, improvements on non-regulatory measures such as technical assistance, training and project financing need to be prioritised in parallel with and linked to higher performance standards (MEPS). The revision offers a unique opportunity to advance the quality and safety of our living and working conditions by further evolvement and strengthening of the energy performance requirements for buildings while simultaneously improving fire safety. ROCKWOOL sees the following elements as being central for the revision: 1) The EPBD should remain the central tool to regulate the energy performance of buildings. The Energy Efficiency First principle should be translated into prioritizing reduction of energy need due to the high level of ancillary benefits associated with highly energy efficient buildings. 2) The EPBD should set a clear 2030 renovation target in line with the Renovation Wave “25 mio building units deeply renovated by 2030” to get the buildings stock on track towards a highly energy efficient building stock by 2050. 3) Introduce a deep energy renovation standard requesting a reduction in final energy need of at least 60%. This will help clarify the right level of “deep renovation” and align the whole value chain around the concept. 4) In general, support for more ambitious nZEB standards is required. The wider long-term ancillary benefits including the positive socio-economic impacts should be taken into account when setting a benchmark for reviewing the appropriate level of nZEB standards for the future. 5) Mandatory Minimum Energy Performance Standards (MEPS) should be designed for different building types and with the aim to support the overall deep renovation of the entire building stock. Sufficient lead time should be applied to signal more ambitious performance standards over time. Introduction of mandatory MEPs should be combined with conditional funding and technical assistance. The fire risk in today’s buildings is permanently changing. Increased use of renewables and other innovative energy efficient solutions/technologies to improve the energy performance of buildings increases the inherent fire risk and impacts the performance of a building in fire. We constantly have to pay attention to new risks, in particular for flammability and toxicity, and to ensure that a high-level of fire safety is being introduced when buildings are being renovated. Over the past years we have seen an increased number of building fires with huge human, social, economic and environmental consequences. This shows that many EU MS lack a sufficiently strong regulatory system on fire safety to adequately address the fire risk in today’s buildings. It is therefore crucial to ensure that fire safety is taken into account in connection with energy renovations and that fire safety is not compromised in the process of enhancing energy efficiency. The public sector should lead by example when renovating public buildings in terms of both energy efficiency and safety. It must be ensured that a building’s fire resilience is not harmed by increased energy efficiency. This is crucial to consider for buildings which are “high-risk” buildings, where people in case of fire have limited evacuation capabilities (children, sick or elderly) and where firefighting can be more complex and time consuming. The danger of toxic smoke and spread of fire are both important elements to be considered, as well. Ideally, these requirements should be extended to the rest of the EU building stock and factored in as part of the development of new tools such as MEPS and deep renovation standards to avoid “shallow” and unsafe renovations taking place.
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Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

15 Mar 2021 · Cohesion policy for building capacity to deliver green energy goals

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

As the leading European manufacturer of fire safe stone wool insulation, ROCKWOOL Group appreciates the Commission's dedicated work on creating an EU Taxonomy to facilitate climate action-compatible investments. This goes hand in hand with the Commission’s ‘fit-for-55%’ commitments and its Renovation Wave strategy. Insulation is a key component in energy efficient buildings, so improving the building envelope is the first priority within the “Energy Efficiency first” approach to lowering buildings’ energy consumption and CO2 emissions. However, we are concerned about how the manufacturing of insulation products is treated in the draft delegated act (DA) for climate change mitigation and the inconsistency with other EU Green Deal priorities. While the draft Taxonomy places building insulation material under the section covering “manufacture of other low carbon technologies” (Section 3.5), it more appropriately belongs under the section “manufacture of energy efficient equipment for buildings” (Section 3.4), as per the original recommendation of the Technical Expert Group on sustainable finance. Under Section 3.5, where insulation is currently placed, economic activities would be considered as contributing substantially to climate change mitigation if they demonstrate substantial lifecycle GHG emission savings compared to the best performing alternative technology/product/solution on the market. This screening criteria places an unreasonable burden on insulation manufacturers to demonstrate compliance with the taxonomy, whereas other energy efficiency products listed in section 3.4 will simply have to comply with minimum performance requirements. With this approach, the draft DA classification contradicts recital 45 of Regulation (EU) 2020/852, by which “within each sector, (the technical screening) criteria should not unfairly disadvantage certain economic activities over others if the former contribute to the environmental objectives to the same extent as the latter”. What’s more, placing insulation in section 3.5 is creating uncertainty and raising concerns among investors regarding how insulation products are to be evaluated against investment criteria. Seen from a Taxonomy perspective, this risks undermining the investment case in what otherwise is an essential element in the green transition for the building sector and the energy efficiency first approach. Including building insulation under Section 3.4 would thus be more appropriate as this section already includes the manufacture of products such as external cladding and roofing systems in which insulation is a key component. We therefore strongly recommend not to discriminate between insulation and other enabling products “delivering substantial contribution to climate change mitigation by improving energy efficiency of buildings”, and to move insulation products back in section 3.4 in line with the original recommendation from the TEG report. We also wish to raise an additional concern regarding the screening criteria for building renovation in section 7.2, which accepts a reduction of primary energy demand of only 30% as being taxonomy eligible as an alternative to a “major renovation”. Such a “shallow” renovation is inconsistent with the Energy Performance of Buildings Directive as well as the “deep renovation” approach recommended in the Renovation Wave Strategy. Aligning the section 7.2 screening criteria with the deep renovation ambition level of “at least 60% improvement” will help ensure investments and resources flow to renovation projects that will genuinely support the EU’s overall climate ambitions.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and

4 May 2020 · Renovation wave and recovery

Meeting with Dominique Ristori (Director-General Energy) and Stichting European Climate Foundation

7 May 2019 · the potential of energy efficiency and benefits of accelerating clean energy transition and climate neutrality for European economy

Meeting with Adalbert Jahnz (Cabinet of Vice-President Maroš Šefčovič) and Stichting European Climate Foundation

1 Apr 2019 · long-term climate neutrality strategy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

22 Mar 2019 · Fire safety & construction products regulation

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

14 Mar 2019 · Energy efficiency

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Feb 2019 · LTS in competitiveness Council

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

4 Sept 2018 · the industry dimension of the Commission’s work on the mid-century strategy

Meeting with Dominique Ristori (Director-General Energy) and Stichting European Climate Foundation

3 Sept 2018 · decarbonisation perspectives

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

Please see feedback in attached Word file and embedded PDF.
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Meeting with Isaac Valero Ladron (Cabinet of Vice-President Miguel Arias Cañete)

13 Apr 2018 · Climate issues

Meeting with Dominique Ristori (Director-General Energy)

23 Feb 2018 · energy efficiency

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

15 May 2017 · Energy Efficiency Legislation

Meeting with Miguel Arias Cañete (Commissioner) and European Insulation Manufacturers Association and

27 Sept 2016 · Energy efficiency in buildings

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and European Insulation Manufacturers Association and

30 May 2016 · energy efficiency in buildings