EBC in favour of an energy labelling for windows under strict conditions

Following the Ecodesign Consultation Forum that took place on 30 September, EBC took position in favour of an energy labelling for windows. 
EBC acknowledges that the current information reported on CE marking on window products is not easily understandable for consumers. EBC also agrees that consumers should be better informed and an energy labelling for windows is a good way to convey information.
However, for EBC to support any European energy labelling for windows, the scheme must meet certain conditions of fundamental importance to construction micro-companies and SMEs:

  1. No additional testing should be required
  2. The thresholds of the classes should better reflect the current national markets. Under the current rating, a good window in certain Member States would be rated F and this will be very difficult to explain to a consumer. This would send a bad signal to the market and it could actually slow down the process of windows’ replacement
  3. A closer consideration should be given to elements with a very high performance in terms of “price vs energy savings”. The current proposal does not take into account cost-optimality, an important provision introduced by the recast EPBD
  4. The current calculation methodology for the definition of classes should be better explained
  5. The Commission should clearly define A & B classes. Nevertheless, the thresholds of the classes should be changed in the future based on technological improvements
  6. The EU map of location of reference conditions should be revised to correspond to the real climatic zones. The label should be flexible enough to take into account specific local conditions
  7. Providing support & accompanying measures for small companies for the transition phase