The revised Construction Products Regulation is making lifecycle environmental impact reporting a regulatory requirement for construction products placed on the EU market. With phased reporting requirements beginning from January 2026, manufacturers need to understand what data is required, when obligations apply, and how to prepare for compliance.
The provision of product lifecycle environmental impact data has evolved beyond a market-driven activity and into the core of EU product regulation.
Did you know that lifecycle environmental impact data will soon form part of the mandatory regulatory declaration for many construction products placed on the EU market?
The revised EU Construction Products Regulation (CPR) entered into force on 7 January 2025 and embeds lifecycle environmental impacts directly into the regulatory framework for construction products placed on the EU market. For manufacturers of construction products, meeting these requirements will be essential for maintaining access to the EU market.
Over recent years, demand for lifecycle environmental impact data for construction products has increased substantially. The construction sector has seen growing uptake of Environmental Product Declarations (EPDs), driven by procurement requirements, green building certification schemes, and increasing expectations from specifiers and clients for verified environmental performance data.
For many manufacturers, producing lifecycle impact data already supports tendering activities, customer requirements, and product sustainability objectives. The revised CPR formalises and standardises an approach that has already gained significant traction across the sector, making lifecycle environmental impact reporting part of the regulatory framework.
This blog explains how the revised Construction Products Regulation introduces lifecycle environmental impact requirements, how these requirements are phased, and what organisations should consider as implementation progresses.
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 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 must include lifecycle-based environmental sustainability performance data.
For the first time, lifecycle environmental impacts are embedded directly into the declaration manufacturers are required to produce for construction products.
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 through to end of life.
From 8 January 2026 Manufacturers must report four climate-related indicators:
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 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 individual product families depends on whether the relevant harmonised technical specification has been updated and cited under the revised CPR.
Harmonised technical specifications remain the primary mechanism through which revised CPR requirements are implemented.
The revised CPR provides for:
These specifications define the essential characteristics for product families, assessment methodologies, performance classes, threshold levels, and product requirements.
The revised CPR also enables the European Commission to establish minimum environmental performance thresholds and product environmental requirements to reduce the environmental impact of construction products.
The revised CPR does not apply all requirements simultaneously. Implementation is progressive and product-family specific, guided by the CPR Working Plan.
Priority product families currently identified for investigation include:
Mandatory obligations for individual product families apply no earlier than 12 months after the relevant harmonised specification enters into force.
This phased approach provides greater visibility and enables manufacturers to prepare for compliance. Organisations that have not yet established robust lifecycle environmental impact datasets should use the Working Plan to understand likely timelines and begin preparing accordingly.
The lifecycle environmental performance data required under the revised CPR must be calculated in accordance with EN 15804, the European standard used for producing Environmental Product Declarations for construction products.
EN 15804 defines:
For organisations already producing EPDs and undertaking life cycle assessments, this will largely build upon existing practices.
However, there is one important difference. Under the revised CPR, the resulting lifecycle data becomes part of a mandatory regulatory declaration rather than a voluntary environmental disclosure.
The revised CPR introduces a Digital Product Passport (DPP) for construction products.
The DPP will eventually become mandatory for products covered by harmonised technical specifications or EADs and will provide structured information including:
The DPP is designed to work alongside wider digital frameworks such as Building Information Models (BIM) and Digital Building Logbooks, helping to create a more connected construction information ecosystem.
Manufacturers should expect lifecycle environmental impact data to become a permanent and digitally accessible component of product information.
The revised CPR requires Member States to align public procurement practices with mandatory environmental sustainability performance requirements for construction products.
These requirements may be incorporated through:
This reinforces the growing role of lifecycle environmental impact data within procurement and specification processes.
For a sector where EPD data is already commonly requested during tendering and specification processes, this represents a continuation of an established trend, supported by a stronger regulatory framework.
The revised CPR forms part of a wider EU regulatory framework focused on sustainability, climate neutrality, and circularity.
It has been designed to complement:
Together, these regulations signal a significant shift in the role environmental performance data plays across EU product legislation.
The revised CPR represents a significant development for construction product manufacturers. However, it builds on trends already established through the increasing demand for EPDs and verified lifecycle environmental impact data.
Manufacturers should begin preparing now by:
Determine which product families your products fall within and monitor developments through the CPR Working Plan.
Review whether your existing data collection processes, systems and expertise are sufficient to meet future reporting obligations.
Identify data gaps, strengthen governance processes, and engage with lifecycle assessment expertise before compliance deadlines approach.
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.
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.
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