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:
mechanical resistance and stability
safety in case of fire
safety and accessibility in use
hygiene, health and environment
protection against noise
energy, economy and heat storage
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.
Solving the product/waste interface dilemma
The European Commission has committed to untangle the issues of overlapping and partly contradicting product, chemical and waste legislation. For the PVC profile value chain it is of utmost importance to bring the CPR. REACH (and other substances-related pieces of legislation) as well as the WFD in alignment. Legal concepts must not contradict but always enable to the most sustainable use of materials and products throughout the life cycle.
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 was 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. Where relevant, products of EPPA members have been listed in the database. Please read more in Technical Guideline for the PVC Window Value Chain.
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.
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:
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.
Lead stabilizers were used in the past and have also been entierly replaced in the PVC profile industry since 2003.
However, windows that are now recycled still contain these stabilizers as legacy additives. 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.
Read more about PVC window recycling in our corresponding Factsheet.
The official statement according to Art. 33a REACH regulation can be downloaded here.