UIPI on Construction Products Regulation Consultation

UIPI comments on Construction Product Regulation Review

July 2022 
Brussels, Belgium

Following the launch of the European Commission’s proposal for a Regulation laying down harmonised conditions for the marketing of construction products, the Commission sook comments from Stakeholders. UIPI contributed and reiterated that sustainability standards for construction products and building appliances are key to develop the building sector’s contribution to the achievement of the new energy and climate targets. In this respect, the Construction Product Regulation (CPR), its implementation and revision will play an important role, as homeowners and building owners rely on such legislation to build and renovate their properties in a transparent, informed, efficient and sustainable way.

Yet, the revision of this legislation must be seen in the general context of the Green Deal and Renovation Wave legislation with the aim of creating a new coordinated legal framework which minimises the burdens for the actors of the building and housing sector by using the legislative instruments and measures best suited to the purpose.

In particular we stressed that:

    • We welcome the greater inclusion of environmental and sustainability aspects in the proposal of revision of the CPR. In particular, the focus on re-use, recycling and circularity requirements both in terms of construction and information obligations is fundamental for a sustainable and transparent building renovations that give property owners the right tools and information to participate in the green transition.
    • The revision of the CPR should be seen in the context of other revisions that are currently taking place, and in particular with the recast of the EPBD. Without an EU-common requirement for reporting the climate impact of construction products, the corresponding EU-common requirements for buildings are not possible.
    • While we welcome the efforts for more available information on construction products through various means, also in digital form, we are hesitant about the proposal to create an EU-wide database for construction product information. An EU common on-line database could be difficult to administrate and goes beyond the real needs of the actors in the construction products’ sector.
    • There is an excessive use of Delegated Acts from the Commission’s side. An unlimited power to the Commission to decide whether certain characteristics should be compulsory or voluntary for some family of products can have significant effects on the actors in the building and construction sector, while giving fewer guarantees that their interests will be duly taken into account.

After the summer, the European Commission’s proposal will be submitted to the ordinary legislative process. We will keep you informed about the developments of this file.

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