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3.5
Enabling ActivityC16, C23, C25, C27, C28

Manufacture of Energy Efficiency Equipment for Buildings

Manufacturing insulation materials, windows, doors, heat pumps, and smart building controls that improve building energy performance.

Substantial Contribution to Climate Change Mitigation

The activity covers the manufacture of products that substantially improve building energy performance. Eligible products include: thermal insulation materials (with lambda values within the top two EU Energy Label classes), high-performance windows and doors (Uw values at or below 1.0 W/m2K for windows), heat pumps meeting the Ecodesign Regulation (EU) 2016/2281 minimum seasonal performance criteria (SCOP above 3.5 for air-source units), smart thermostats, building automation and control systems (BACS) of class A or B per EN 15232, and LED lighting systems.

As an enabling activity under Article 10(1)(i), the manufactured equipment must demonstrably improve the energy efficiency of buildings in which it is installed. Products must be placed on the EU market with valid CE marking and, where applicable, comply with the Energy Labelling Regulation (EU) 2017/1369 and relevant Ecodesign implementing measures.

Facade and insulation products must demonstrate thermal performance using harmonised EN standards (EN 13162 to EN 13171 for thermal insulation products). Heat pump refrigerants must have a GWP below 675 (F-Gas Regulation phase-down trajectory), with a pathway toward GWP below 150 for new product lines.

Substantial Contribution to Climate Change Adaptation

A CRVA must be performed in accordance with Appendix A, covering the manufacturing facility under RCP 4.5 and RCP 8.5 climate scenarios.

DNSH: Climate Change Adaptation

Physical climate risks to the manufacturing facility must be identified and appropriate adaptation solutions implemented, covering temperature-related, water-related, wind-related, and solid mass-related hazards per Appendix A.

DNSH: Water and Marine Resources

The activity must comply with the Water Framework Directive (2000/60/EC). Manufacturing processes involving wet coating, mineral fibre production, or metal finishing must meet applicable BAT-AELs for water discharge and consumption.

DNSH: Circular Economy

Products must be designed for durability and recyclability. Insulation materials must be recyclable or recoverable at end of life. Products must meet waste hierarchy requirements, with manufacturing scrap rates minimised and production waste recycled where feasible. Products intended for buildings must support disassembly per ISO 20887 principles.

DNSH: Pollution Prevention and Control

The activity must comply with the Industrial Emissions Directive and applicable BAT conclusions. Insulation materials must not use blowing agents with GWP above 5 for foams. Products must not contain SVHCs under REACH. Formaldehyde emissions from wood-based products must comply with E1 class or better (EN 717-1).