Product Policies

The Ecodesign Directive, the Energy Labelling Directive, the Ecolabel Regulation and Green Public Procurement constitute the core legal framework defining energy and environmental requirements for a wide range of products. They are complementary: while the first one deals with minimum requirements and the second provides performance rankings, the third awards best products and the last creates a market pull for green products through public procurement. The European Commission identifies priority product groups, studies them and sets requirements when relevant.

European Aluminium strongly supports sustainable consumption policies provided that the following criteria is fulfilled:

• Product-specific legislation should always have the priority over the above multi-product ones
• No requirements should be set for intermediate products
• The methodologies applied for setting requirements should properly reflect the end-of-life recycling benefits of metals

The aluminium industry has been involved in European Commission studies dealing with window products, power cables, office buildings and food catering services .

Road vehicles are included in several transport-specific legislations of the European Union pursuing similar objectives as the above sustainable consumption package. These are the Regulations setting CO2 emission performance standards for cars and vans, the CO2 Labelling Directive for cars, the upcoming legislation on CO2 emissions of heavy duty vehicles, the End-of-Life Vehicles Directive and the Directive on the promotion of clean and energy-efficient road transport vehicles.

The aluminium industry advocates for technology neutral CO2 regulations for vehicles as they will allow to take full benefit of light weighting into account, and stresses that with metals, making vehicles lighter and recyclable are compatible goals.

Sustainable consumption

For most construction products, there are no requirements in the form of minimum energy or environmental performance levels under the Ecodesign Directive. The aluminium industry is supportive of this situation since, if needed, such requirements would better be put in place by implementing existing provisions of the Construction Products Regulation, which would minimize compliance costs. It should also be noted that several construction products are already submitted to minimum energy performance requirements under the Energy Performance of Buildings Directive.

Construction products are intermediate products for which the usefulness of Energy labels or Ecolabels is highly questionable since holistic optimization of complete buildings is more beneficial in terms of energy and environmental savings than component-by-component approaches. Instead, our industry sees Energy Performance Certificates under the Energy Performance of Buildings Directive and the aggregation of Environmental Product Declarations (EPDs) at building level as the right approaches.

Single market

The Construction Products Regulation (CPR) lays down harmonised rules for the marketing of construction products in the European internal market and provides a common technical language to assess construction products’ performance. Declaration of Performance (DoP) and CE marking are key parts of it.

European Aluminium works together with with all the European Institutions and other stakeholders to introduce simplified procedures allowing affordable compliance for manufacturers.