Strengthening the Construction Products Regulation for greater efficiency and sustainability

By contrast, Glass for Europe calls for caution when it comes to using the CPR to address the end-of-life management of construction products. The flat glass sector already practices recycling as 25% of its raw materials are made of recycled glass[5] on average in Europe. Many efforts are undertaken to push this proportion upward, yet, it is not evident to conceive how horizontal measures applying to all construction products will support these efforts.

For instance, reuse of glass is generally not technically possible as installed IGUs have bespoken dimensions. While an IGU cannot be re-dimensioned, re-cutting of certain glass types is possible but can also lead to breakages, e.g. thermally toughened glass. The safety and the remaining lifetime of reused products will be adversely affected and some of their characteristics may be degraded to the extent that the product no longer complies with building codes, for example on energy performance. For glass, the best end-of-life option usually remains recycling. Reuse should be carefully apprehended.

Glass for Europe is prudent regarding ‘regulatory’ privileges for products based on their recycled content. High content of recycled materials cannot presuppose “conformity” to a standard, or to a performance requirement nor can it imply that the product is the best choice for a specific construction. If such a ‘recycled content’ approach is defined, it needs to be product-based to account for different technological possibilities and recycling potentials of construction materials.

Finally, as new considerations are added to the CPR, it is essential that measures are proportionate and avoid burdensome obligations for industries offering a large variety of products. In the glazing industry alone, product configurations are to be counted in hundreds of thousands. For this reason, Glass for Europe believes that EPDs should not be made part of the DoP but instead the DoP should include a digital link to the EPD. In the same way, it should be allowed to work by families of products when obligations are designed or new databases set-up.

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[1] Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC.

[2] European Commission consultation ‘‘Future options for the review of the CPR’ –  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12458-Review-of-the-Construction-Products-Regulation

[3] Glass for Europe – 2050 Flat glass in a climate neutral economy – January 2020 – https://glassforeurope.com/wp-content/uploads/2020/01/flat-glass-climate-neutral-europe.pdf

[4] A high-performance double glazing will offer incomparably higher energy and CO2 emissions savings to the building than a standard product. Throughout its lifetime, its energy and carbon balance will be a lot more beneficial thanks to savings in the in-use phase while it may contain slightly more embedded energy and CO2.

[5] Glass for Europe – 2050 Flat glass in a climate neutral economy – January 2020 – https://glassforeurope.com/wp-content/uploads/2020/01/flat-glass-climate-neutral-europe.pdf