European producers of technical fabrics, represented by the Tech-Fab Europe association[1], welcomes the new Construction Products Regulation (EU) 2024/3110 (CPR)[2] as a positive step toward clearer, more consistent rules for construction products and harmonised standards across Europe. However, it calls for Open Mesh Fabrics (OMF) to be formally recognised as key parts within External Thermal Insulation Composite System – ETICS kits, ensuring that upcoming standards reflect their essential role in the system’s safety, durability, and overall performance, as the  new EU CPR in recital 12[3] is underlining the importance of performance assessment of key parts like open mesh fabrics into ETICS systems.

Why Open Mesh Fabrics are Key to ETICS Performance

Under Article 4 of the CPR, the Commission is to establish a working plan for the development of harmonised technical specifications for product families listed in Annex VII, including product requirements as well as general product information, instructions for use and safety information, covering at least the following three-year period. The list in Annex VII of the CPR includes “THERMAL INSULATION PRODUCTS. COMPOSITE INSULATING KITS/SYSTEMS” (ETICS), and OMF serve to guarantee certain ‘essential characteristics’ of that product family.

Annex I of the CPR lists the basic requirements for construction works which are to be taken as the basis for the identification of essential characteristics of products and for the preparation of standardisation requests, harmonised technical specifications and European assessment documents. The first and foundational requirement in that list is the “Structural integrity of construction works”, which includes durability, structural resistance, and robustness.

In this regard, OMF plays a multi-faceted and critical role:

• Structural robustness: OMF reinforcement is essential for the mechanical performance of ETICS, particularly impact resistance, crack control, durability, and dimensional stability.
• Safety and integrity: OMF ensures the cohesion and strength of the rendering layers, preventing failures that compromise fire resistance, insulation function, and façade durability.
• Compliance with Basic Requirements for Construction Works (Annex I CPR): OMF directly guarantees the mechanical resistance, durability, and energy performance of the ETICS.

The OMF within the ETICS are thus key for guaranteeing the ETICS’ integrity. Without traceable CE-marked OMF there is a risk of substitution with non-compliant fabrics, undermining kit safety and durability (not to mention market fairness).

What Needs to Be Done

1. Key part designation in the ETICS kit standardisation request:
   1. Explicitly designate OMF as a key part requiring CE marking and traceable declarations linked to the ETICS kit’s Declaration of Performance and Conformity (DoPC).
2. Adaptation of product standards for technical fabrics:
   1. Introduce a dedicated intended use: “Open Mesh Fabric for ETICS kits”.
   2. Define performance classes (impact resistance, tensile strength, alkali resistance, fire behavior).
   3. Ensure alignment with kit-level harmonization.

Benefits of Recognising OMF as Key Parts

• For market surveillance by relevant authorities: Ensures traceability and closes compliance gaps.
• For harmonized regulatory conditions within EU: All OMF sold on the EU market must meet the same harmonised CE requirements, including imports.
• For kit manufacturers: Reduces redundant testing, simplifies DoPC updates, and clarifies responsibilities between kit manufacturers and OMF suppliers.
• For end-users and public interest: Strengthens trust in ETICS performance and safety, supporting Europe’s energy efficiency and climate targets.

Broader Impact

• Establishes a replicable model for the designation of reinforcement components in other kits (e.g. renders, roofing, wall systems).
• Supports digital traceability via CE marking and Digital Product Passports.
• Strengthens Europe’s leadership in sustainable construction product regulation.

Conclusion

Open Mesh Fabrics are indispensable to the safety, performance, and durability of ETICS systems. Recognising them as key parts under the CPR ensures a robust, fair, and future-proof framework that benefits all the value chain, manufacturers, system holders, regulators, and end-users.

DOWNLOAD THE POSITION PAPER: Open Mesh Fabrics as Key Part of ETICS Systems                                                                                                                           

[1] https://tech-fab-europe.eu/

[2] (CPR Article 3, point 16) ‘key part’ means a part which is used as a component or spare part for a product and which has been specified by a harmonised technical specification as essential for the characterisation, safety or performance of a product.

[3] https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng The compliance of construction products with Union legislation often depends on the compliance of their key parts with that legislation. However, since key parts are often integrated into various construction products, ensuring mandatory rules applicable to key parts of construction products. The same approach should be used for parts or materials intended to be used for construction products which would benefit from the voluntary application of the Regulation.