ECODESIGN AND ENERGY LABELLING FOR WINDOWS
EuroWindoor AISBL agreed on July 1st in Copenhagen on a position paper on EU Energy Labeling for windows with arguments and proposals for alternative procedures related to the results of the Ecodesign preparatory study for Windows.
The attending EuroWindoor members made a clear and unanimous agreement against an EU Energy Labeling for windows. More negative impact than positive is expected. Although there was a negative assessment EuroWindoor AISBL is willing to support energy efficiency and the development for better energy efficient windows by using another way instead of EU Energy Labeling. Such a label will not increase the replacement rate of windows, but that is needed. EuroWindoor members see the recast of EPBD as the right place to request from Member States stronger requirements (based on energy balance instead of only U-value) for windows in new buildings and for renovation.
Key arguments against EU Energy Labeling are based on the following:
Window products and the purchase situation of windows cannot be compared with white goods and electronic products.
The energy savings potential depend on the specific climate, building etc. The EU Energy label can potentially misguide, and windows are more than energy performance.
Will be against building regulations so far, which are based on national climatic conditions, and not determined at EU level.
Double regulation (CE marking is already at place and include energy related characteristics for windows)
No documentation of added value for customer (affordability and risk of misguidance)
No documentation of the cost and administrative burden for industry
No justification of an EU label compared to national labels or doing nothing.
Better regulation is questioned.