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Letter from industry associations to the Ministry of the Interior and Kingdom Relations: New EU bureaucracy makes the manufacturing of construction products too complex

Letter from industry associations to the Ministry of the Interior and Kingdom Relations: New EU bureaucracy makes the manufacturing of construction products too complex

Following the lead of 14 German trade associations in the construction and window industries, six Dutch trade associations are warning against new EU requirements that will make construction more expensive and impose additional administrative burdens on small and medium-sized enterprises. In a joint letter, they call on the Minister of Housing and Spatial Planning, Elanor Boekholt-O’Sullivan, to ensure that the Netherlands does not approve the current draft in September. The goal is to achieve a fundamental revision before it leads to binding requirements for European product standards.

The European Commission plans to publish a so-called Standardization Request, which will specify what information and supporting documentation manufacturers will be required to provide for construction products in the future. For nearly all windows and doors in a project, the current proposal would mean: significantly more technical information, additional testing, extensive data on materials and the environment, and new digital documentation. According to the alliance, this effort is disproportionate to the benefits for building owners and consumers.

More paperwork, but no improvement product

Window and door frames, including windows and doors, are largely custom-made. Even changes in dimensions, glazing, panel fillings, hardware, or fittings create new product variants. If extensive documentation must be prepared for all these variants, the workload multiplies. According to industry estimates, the documentation for the window and door frames of a single-family home could grow from a few pages to a bulging folder. The building owner ends up with more paperwork—but not a better or safer product.

The costs are borne by building owners, buyers, and tenants

Additional administrative staff, external testing, new IT systems, and the ongoing maintenance of large amounts of data cost time and money. These additional costs would ultimately be borne by building owners, investors, buyers, and tenants.Cost increases of this magnitude make this request for standardization an impossible task.

Such an increase in costs and bureaucracy would come at the worst possible time: the Netherlands needs more new construction, a faster pace of renovation, and additional investments in energy efficiency. However, new uncertainties and avoidable costs reduce the economic viability of projects and can delay or prevent investments.

In addition, companies in the sector cannot simply pass on these increased costs. It is practically unfeasible and will inevitably lead to business closures or circumvention of the rules.

6 Industry associations are calling on the minister to take action

The joint letter calls on the Ministry of the Interior and Kingdom Relations (BZK) to advocate for a Dutch ‘No’ vote in the upcoming referendum. The associations emphasize that the goal is not to prevent uniform European rules. The draft must be revised so that the burden on small and medium-sized enterprises remains manageable and construction costs do not rise unnecessarily.

The associations propose to:

• establish appropriate rules for custom-made products and small and medium-sized enterprises, and consider excluding custom-made products from the scope;

• to require only the product performance information that is truly necessary;

• the ability to use proven calculations and software-based methods instead of repeated, costly external tests;

• Digital product passports should only be introduced once the legal framework and technical infrastructure are in place.

The associations are ready to develop concrete solutions and will continue to monitor the European process and the subsequent development of product standards critically and constructively. The goal is clear: to maintain our high product quality while ensuring European comparability—without unnecessary bureaucracy, avoidable additional costs, or obstacles to housing construction and renovation.

Broad alliance of the construction and facadeindustry

The joint appeal to the ministry is supported by the following associations:

  • the Association of the Metal Windows and Facade Industry (including Sun Protection) (VMRG)
  • the Association of the Plastic Façade Elements Industry (VKG)
  • the Dutch Trade Association for the Carpentry Industry (NBVT),
  •  Bouwend Nederland GLAS Professional Group
  •  The General Trade Association for Hardware and Locks (VHS). 

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