What does the revised CPR change for manufacturers?
The original Construction Products Regulation has been in place since 2011, providing a common framework for assessing and declaring the performance of construction products. Under this framework, manufacturers produce a Declaration of Performance (DoP) setting out how their product performs against essential characteristics, with compliant products bearing the CE marking.
Regulation (EU) 2024/3110 replaces the original CPR and introduces strengthened requirements around environmental sustainability, safety and digitalisation.
One of the most significant changes is the introduction of a Declaration of Performance and Conformity (DoPC), which replaces the original Declaration of Performance. The DoPC combines performance and conformity information into a single document and, critically, must include lifecycle-based environmental sustainability performance data.
For the first time, lifecycle environmental impacts are embedded directly into the declaration that manufacturers are required to produce for construction products.
Which lifecycle environmental impacts must be reported under revised CPR and when?
Under the revised CPR, construction product manufacturers will be required to declare lifecycle environmental metrics in their DoPC, covering the full product lifecycle from raw material extraction to end-of-life. The reporting requirements will be introduced on a phased basis.
Key reporting milestones
- From 8 January 2026, manufacturers must report on four climate-related indicators:
- Global Warming Potential (total)
- Global Warming Potential (fossil)
- Global Warming Potential (biogenic)
- Global Warming Potential (land use and land-use change)
- From 9 January 2030: Reporting expands to cover the full set of core environmental impact indicators aligned with EN 15804+A2.
- From 9 January 2032: Additional environmental impact indicators are brought into scope, bringing the total number of indicators to 19.
These dates represent when the requirements enter the regulation. However, enforcement for any specific product family depends on whether the relevant harmonised technical specification has been updated and cited under the revised CPR.
How will the revised CPR requirements be implemented?
Harmonised technical specifications remain the primary mechanism through which the requirements of the revised CPR are implemented. The revised CPR foresees the development of new harmonised standards, the updating of existing standards, and the development of new European Assessment Documents (EADs) to address innovative construction products.
The harmonised technical specifications and EADs lay down the essential characteristics for product families or categories, and the methods for assessing their performance, threshold levels or classes of performance, as well as the product requirements. These specifications are mandatory in the implementing acts adopted by the European Commission and cited in the Official Journal of the European Union.
The revised CPR also empowers the Commission to set minimum threshold levels for the environmental performance of construction products and product environmental requirements, with the aim of preventing and reducing the impact construction products have on the environment.
Which construction products are affected first?
The revised CPR does not apply all its requirements at once. Implementation is progressive and product family-specific, guided by a CPR Working Plan that identifies priority product families and establishes timetables for reviewing and updating harmonised standards.
Priority product families identified for investigation include:
- Concrete
- Steel
- Insulation materials
- Cement
Mandatory obligations for a given product family apply no earlier than 12 months after the relevant harmonised specification enters into force, meaning not all manufacturers face the same timeline.
The planned sequencing and timing of implementation is intended to give industry visibility over what is coming and when, allowing manufacturers to prepare for this regulatory transition.
For organisations that have not yet established the foundations for their data inventory in preparation for product lifecycle environmental impacts, the Working Plan provides a useful reference point for understanding the timelines relevant to product categories and preparing for compliance.
What methodology is used to calculate lifecycle environmental impacts?
The lifecycle environmental performance data required under the revised CPR must be calculated in accordance with EN 15804, the European standard that defines the methodology for producing Environmental Product Declarations (EPDs) for construction products.
EN 15804 defines:
- The lifecycle stages to be assessed
- The environmental impact indicators to be reported
- The rules for data collection and calculation
For manufacturers already producing EPDs and working with LCA data, much of this will feel like a continuation of existing practice.
The revised CPR draws on the same lifecycle assessment (LCA) framework, methodologies and data requirements that have underpinned EPD production in the construction sector for years.
However, an important distinction is that under the revised CPR, the resulting data forms part of a mandatory regulatory declaration rather than a voluntary disclosure.
What role does the Digital Product Passport play?
The revised CPR introduces a Digital Product Passport (DPP) for construction products, which will eventually be mandatory for all products covered by harmonised technical specifications or EADs through a delegated act.
The DPP will provide structured product information including:
- Material composition
- Product durability
- Environmental performance data
- Instructions for use
- Safety information
- Guidance on reuse, recycling and disposal
The DPP is designed to integrate with broader digital frameworks such as Building Information Models (BIM) and Digital Building Logbooks, creating a more connected information ecosystem across the construction sector.
The DPP means that the information declared in the DoPC will also need to be maintained in a standardised digital format. Manufacturers should expect lifecycle data to become a persistent, digitally accessible part of their product information.
What are the implications for public procurement?
The revised CPR requires Member States to align their public procurement practices with mandatory minimum environmental sustainability performance requirements for construction products.
These can be applied through:
- Technical specifications
- Selection criteria
- Contract award criteria
- Conditions for performance of contracts
Member States retain the ability to set more ambitious requirements where they choose to.
This reinforces the growing role of lifecycle environmental impact data in procurement and specification and means the data manufacturers produce for compliance will increasingly support their position in public tenders as well.
For a sector where EPD data is already being requested in tendering and specification, this is a continuation of an existing trend, but with regulatory weight behind it.
How does the revised CPR fit within broader EU sustainability legislation?
The revised CPR is part of a wider EU regulatory framework aimed at sustainability, climate neutrality and circularity.
It is designed to work alongside the Ecodesign for Sustainable Products Regulation (ESPR), which introduces environmental performance and Digital Product Passport requirements across a wider range of product categories.
The revised CPR also supports the objectives of the Energy Performance of Buildings Directive (EPBD), which is driving demand for reliable construction product environmental data at building level.
Together, these regulations signal a significant shift in the role lifecycle environmental performance data plays across EU product legislation.
What should manufacturers do next?
The revised CPR represents a significant development for construction product manufacturers. However, it builds on trends already established through increasing demand for EPDs and verified lifecycle environmental impact data.
Manufacturers should begin preparing now by:
- Identifying relevant product families: Determine which product families your products fall within and monitor developments through the CPR Working Plan.
- Assessing lifecycle data capability: Review whether your existing data collection processes, systems and expertise are sufficient to meet future reporting obligations.
- Establishing a robust data foundation: Identify data gaps, strengthen governance processes, and engage with lifecycle assessment expertise before compliance deadlines approach.
While implementation will be phased over several years, manufacturers that begin preparing early will be better positioned to meet future reporting requirements and customer expectations.
Key takeaways
- Lifecycle environmental impact reporting is becoming a regulatory requirement for construction products sold within the EU.
- Reporting obligations will be introduced in phases between 2026 and 2032.
- Environmental performance data must be calculated using recognised lifecycle assessment methodologies aligned with EN 15804.
- Digital Product Passports will increase transparency and accessibility of product environmental information.
- Organisations that prepare early will be better positioned to meet future compliance requirements and customer expectations.
How Valpak can help
Valpak supports manufacturers in preparing for revised CPR requirements through lifecycle assessment, environmental performance reporting and sustainability data management services.
Whether you need to assess data readiness, undertake lifecycle assessments, support EPD development, or prepare for future compliance obligations, our specialists can help you establish the processes and governance needed to move forward with confidence.
Ready to prepare for revised CPR requirements?
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The revised Construction Products Regulation marks an important step in the evolution of environmental reporting for construction products. Businesses that begin preparing now will be in a stronger position to meet compliance obligations, respond to customer expectations, and demonstrate product sustainability through robust lifecycle data.
