European Associations Call on the Commission to Enable Verified Software Tools under the CPR

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Windows, doors and flat glass are largely custom-made and project-specific. Relying on worst-case declarations and extensive physical testing would lead to a very high number of individual declarations, high costs and administrative burden, especially for SMEs. It would also strain Notified Body capacity and reduce the representativeness of declared values. Software-based calculations have been used for many years.

European Aluminium, EuroWindoor, EPPA, Glass for Europe and Small Business Standards (SBS) therefore propose that the Commission amend Annex IX(5) on AVS 3 by delegated act under Article 10(4) CPR. Verified software could then be used to assess the performance of relevant essential characteristics, where foreseen in the standardisation request. A Notified Body would validate the input parameters and the software. Manufacturers would apply the tool within their factory production control.

The associations support the CPR’s goals of harmonisation, transparency and environmental performance. They invite the Commission, Member States and the standardisation bodies to a constructive dialogue on software validation.