Developing an EU energy label for windows

Comments on the 9 consultation questions of the EC working document / explanatory memorandum dated 9 September 2015 – ENER Lot 32    Glass for Europe, the association of European manufacturers of building, automotive and solar-energy glass, welcomes the conclusion of the eco-design preparatory study on window products (Lot 32) and the working documents released by the European Commission on 9 September 2015 (corrected version).Glass for Europe and all its member companies, which supply the vast majority of glass used in windows installed on European buildings, have always been supportive of the eco-design / energy labelling process and in favour of the introduction of a meaningful EU energy label for windows.To our views, in order to be meaningful an EU label must: Be easily understandable by consumers Allow a proper ranking of window products, i.e. a frame plus glazing, according to the Best Available Technologies (BATs) identified in the preparatory study Take account of the three main climatic conditions in Europe to provide a proper assessment of the annual performance of a window (combining heating & cooling). Allow product differentiation to reward energy-efficient glass solutions and to be conducive to innovation Glass for Europe is of the opinion that the proposal for a label presented on page 12 of the corrected draft delegated regulation can fulfil all the above essential requirements, while other options can have detrimental implications for one or more objectives.It is with a view to move in this direction, that Glass for Europe responds to the nine consultation questions from the European Commission.

All references to EC working documents (tables, pages, etc.) relate to the corrected working documents circulated on 9 September 2015.

Table of Content

Why an EU energy label? 2

Features and implications of the proposed label option (page 12 of draft delegated regulation) 3

Detailed responses to the nine consultation questions 4

Summary of responses to the 9 questions 10

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600450 Developing an EU energy label for windows
Date: 17 September 2015

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