• Plastics Europe supports a future-orientated Construction Products Regulation – one that recognises the value of plastics as a high-performance, durable, and sustainable construction material.
• The CPR should remain a material neutral / performance-based regulation, with an approach based upon scientific assessments and bearing in mind the specific product characteristics needs.
• A one-size-fits-all approach to circularity will not work in construction due to the diversity of materials and the longer loops in service lifetime. Many design-related actions will only provide results in the long term and material recovery of existing construction materials needs to continue to improve.
• For increased circularity and sustainability, a technology-neutral approach that recognises chemical recycling or renewable feedstocks using the mass balance accounting principle will best enable the recycled content use where possible.
• The transition of the construction ecosystem must continue to be assessed via factual and scientific based methods (Level(s), LCAs, EPD’s). EPDs are the widely used approach for transparently communicating the environmental performance. Plastics Europe recommends accepting the mass balance credit method as chain-of-custody in the Environmental Product Declarations.
• Finally, the Commission proposal requires significant further elaboration and details, notably the points on delegated acts and what products are in and out of scope.