The Polish Windows and Doors Association (POiD) has submitted the window industry's position on the draft standardisation request for windows, doors and related products to Poland's Ministry of Development and Technology. The document concerns the new EU Construction Products Regulation (CPR), Regulation (EU) 2024/3110. POiD reported this in a statement.
POiD prepared its position following an analysis of the draft and consultations with Polish window and door manufacturers. The association believes that the proposed requirements will increase the number of tests, the volume of documentation and the administrative burden. This will raise manufacturers' costs and could weaken the competitiveness of the Polish industry.
“Poland is the European leader in the production and export of windows and doors. We support the main objectives of the CPR, such as digitalisation, transparency and sustainability. However, the new rules should support the competitiveness of businesses rather than create barriers that are impossible to implement in practice,” said Janusz Komurkiewicz, Chairman of the Board of POiD.
One of POiD's concerns relates to the amount of data that manufacturers will be required to declare. The draft provides for 60 technical characteristics, 39 environmental criteria and 175 entries concerning hazardous substances for windows. According to the association, the declaration of product performance, which currently contains up to 15 characteristics on one or two pages, could increase to at least nine pages for each product type.
POiD also objects to the requirement to declare 174 individual hazardous substances for external windows and doors. The association points to an overlap with the requirements of the REACH Regulation. It also notes that European laboratories do not have methods for measuring many of these substances.
Another risk concerns the work of notified bodies. POiD believes that an increase in the number of tests, combined with a large number of product variants, could overwhelm these bodies. The association also considers the 12-month transition period from the publication of harmonised standards to full implementation of the requirements to be unrealistic.
POiD also draws attention to the timeframe for preparing new harmonised standards. According to the association, the European Committee for Standardization (CEN) indicates that at least 36 months will be required from the adoption of the standardisation request.
The association also points to the lack of readiness of the regulatory and IT framework for the Digital Product Passport (DPP). Technical standards concerning data architecture and security are still under development. According to POiD, the European Commission's delegated act on the DPP is expected in 2027.
In its submission to the Polish ministry, POiD set out six technical proposals. The first is to reduce the number of mandatory characteristics to the parameters necessary to meet the requirements of building legislation and ensure the safe use of products.
The second proposal concerns external windows and doors. POiD proposes removing from the draft the requirement to declare 174 hazardous substances and volatile organic compound (VOC) emissions for these products. At the same time, the association proposes retaining the requirements directly imposed by REACH.
The third proposal is to retain simplified assessment methods. POiD supports the equivalent use of calculation methods and tabulated values in accordance with Article 5 of the CPR. This should eliminate the need for laboratory testing of every product configuration.
The fourth proposal is to extend the transition period to at least 36 months from the date the harmonised standards are made available. POiD also proposes retaining the validity of previously conducted Initial Type Testing (ITT).
The fifth proposal concerns the Digital Product Passport. POiD calls for the DPP requirements to be postponed until the delegated acts have been adopted and the work of CEN and the Polish Committee for Standardization (PKN) has been completed. The European Commission should also provide free software and calculation tools.
The sixth proposal involves changing the approach to defining the product type. POiD proposes introducing flexible rules for grouping product variants. These should prevent the need to register every individual window configuration depending on its dimensions.
POiD approached Poland's Ministry of Development and Technology ahead of the vote in the EU Committee on Standards. The association is calling on Poland to oppose the draft standardisation request in its current form and seek its revision. POiD also proposes that Poland engage in dialogue with other EU countries where industry organisations have expressed similar concerns.