Summary
EUMEPS supports the proposed Commission Delegated Regulation establishing conditions for the classification without testing (CWFT) of certain construction products regarding their reaction-to-fire performance under the Construction Products Regulation (EU) 2024/3110.
Maintaining existing CWFT provisions for products with well-established and predictable performance can provide regulatory certainty, avoid unnecessary testing and reduce administrative burdens while preserving a high level of fire safety.
For future delegated acts, EUMEPS calls for provisions based on robust scientific evidence, harmonised and reproducible assessment methods, transparent eligibility criteria and broad stakeholder consultation. These provisions should remain technology-neutral and ensure equal treatment across construction products.
The position paper also stresses that any future requirements concerning continuous glowing combustion should only be introduced once appropriate European assessment methods have been developed and scientifically validated. More broadly, EUMEPS supports a performance-based approach that considers how products behave in their intended end-use application and within complete construction systems.