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Regulatory framework

PVC window systems are subject to important regulations such as the Construction Products Regulation, the Waste Framework Directive, the RoHS Directive for certain hazardous substances and the REACH Regulation.

 

In order to facilitate the alignment of industrial processes with legal regulations EPPA, as a stakeholder, carefully follows the developments of European and national legislation.

Construction Products Regulation (CPR)

It is one of the most important European legal acts dealing with windows. It defines the conditions under which a construction product can be placed on the market and rules on how the performance of a construction product should be expressed. By using the CE mark, manufacturers declare compliance with these essential requirements.

 

Harmonized Product standard EN 14351-1

A harmonized standard for windows was drawn up by the European Committee for Standardization CEN and published as EN 14351-1. It covers windows made of all frame materials and is the standard for determining all essential characteristics based on working requirements laid down in the CPR. These are:

 

  1. mechanical resistance and stability

  2. safety in case of fire

  3. safety and accessibility in use

  4. hygiene, health and environment

  5. protection against noise

  6. energy, economy and heat storage

  7. sustainable use of natural resources

Working for legal certainty

In addition to CPR, window manufacturers must also comply with the requirements of REACH, the Classification and Labelling of Products Directive (CLP), RoHS and others. EPPA members believe that all legal requirements relevant to their products should ideally be contained in a single piece of legislation to reduce administrative burden and increase legal certainty.

European Waste Framework Directive (WFD)

Deals with materials from "End-of-Life (EoL) products" and aims to reduce the impact of waste on the environment and human health by installing appropriate waste management systems.

 

How does the WFD affect the PVC profile industry?

When PVC windows reach the end of their life cycle, they should be recycled. Under the current WFD, an EoL product becomes waste. Therefore, anyone dealing with this waste material must obtain a waste treatment permit.

For PVC windows, recycling has already proven to be the most sustainable option.

 

Proposal to improve this legislation

Landfill ban in 2025 and lead assessment EPPA advocates a landfill ban to avoid waste of the PVC material and to promote the collection and recycling systems. 

SCIP Database

As part of the EU WFD (2008/98/EC), the ECHA has constructed a database containing information regarding the use of Substances of Very High Concern (SVHCs).

Companies supplying articles containing above 0.1% weight by weight (w/w) SVHCs on the EU market have to submit information on these articles to ECHA, as of the 5th of January 2021. The SCIP database will be set up to increase availability of information on articles containing Candidate List substances. The legislator believes that accessibility for waste operators and consumers is increased via the introduction of the database.

RoHS Directive

It implements restriction on hazardous substances in electronic products. Based on a political decision, windows are also judged to be such electronic products. This means that for substances, windows are covered by REACH and by RoHS legislation with non-harmonized legislative requirements. On the product level, windows are subject to the CPR and RoHS.

 

EPPA calls on the European legislator to remove windows from the scope of the RoHS Directive. Windows are non-electronic products but can only be equipped with them. This electronic equipment has been and should continue to be covered by RoHS. Windows are sufficiently regulated by REACH, CLP and CPR legislation. All requirements from RoHS create legal uncertainty and partially contradict the existing, mentioned legislation.

REACH Regulation

It aims to ensure a high level of protection for human health and the environment while allowing the free movement of substances on the European market.

 

How does REACH affect the PVC profile industry?

Due to the use of recycled materials, profile manufacturers are subject to the regulation. Manufacturers must monitor the content of hazardous substances in their products. 

 

For profile manufacturers there are essentially three substances that have or may soon have a critical status under REACH:

  1. Cadmium has already been phased out by the PVC profile industry. An exemption has been created under REACH for residues (legacy additives) found in the recyclate.

  2. Lead stabilizers were used in the past and have been gradually replaced since 2003.

 

However, windows that are now recycled still contain these stabilizers. They are coextruded into new profiles. As these additives are embedded in the matrix, they do not pose a risk to human health. They do not migrate out of the PVC.

 

Restricting the use of lead in recyclates would endanger the recycling activities of the whole industry, as it is currently not economically feasible to remove lead from the recyclate.

 

Proposals

As construction products, windows are subject to two regulatory frameworks when it comes to substances: the REACH legislation and the Construction Products Regulation. The Basic Work Requirement 3 has the potential to adequately cover the handling of hazardous substances. We call for a better alignment of the two instruments to streamline requirements and to remove bureaucratic burdens.

Read more about PVC window recycling in our corresponding Factsheet.

 

The official statement according to Art. 33a REACH regulation can be downloaded here.