The Construction Products Regulation

If your company makes, imports or buys construction products for the EU market, the Construction Products Regulation (CPR) already governs how they are CE marked and what their declaration says. The new version of the regulation adds something the old one never had: the product’s environmental performance over its life cycle, starting with its climate impact. That turns LCA results from a voluntary extra into part of the product’s legal paperwork.

The important word is phased. The obligation arrives product family by product family, and for most products it has not arrived yet. This lesson explains how to tell when it reaches yours.

What the CPR is

The Construction Products Regulation, Regulation (EU) 2024/3110, sets the EU’s harmonised rules for placing construction products on the market. It was adopted on 27 November 2024, published in the Official Journal on 18 December 2024, entered into force on 7 January 2025, and applies from 8 January 2026 (Article 96), with some provisions applying earlier.

It replaces the previous regulation, Regulation (EU) No 305/2011. The replacement is gradual: most of the old regulation was repealed from 8 January 2026, but the parts that keep existing harmonised standards working remain until 8 January 2040 (Article 94). Until a product family moves to new standards under the new CPR, it largely carries on under the old system.

The key idea: harmonised technical specifications

The CPR works through harmonised technical specifications: harmonised European standards (drafted by CEN on the Commission’s request) and European assessment documents. They say which essential characteristics of a product must be assessed and how.

When a product is covered by a harmonised technical specification under the new CPR, the manufacturer must draw up a declaration of performance and conformity (DoPC) before placing it on the market (Article 13). The DoPC replaces the old declaration of performance and is the manufacturer’s legal statement of how the product performs.

So the environmental obligation reaches a product in two steps:

1. A new harmonised standard for its product family is made mandatory, by an implementing act, under the new CPR.
2. From then on, the DoPC for products in that family must include the environmental information the regulation requires.

What the declaration must include

The CPR lists predetermined environmental essential characteristics in its Annex II. They are life cycle assessment indicators, and they line up with the indicators you met in lesson 1: climate change (total, fossil, biogenic, land use and land use change), ozone depletion, acidification, eutrophication, photochemical ozone, resource depletion, water use, particulate matter, ionising radiation, ecotoxicity, human toxicity and land use.

Article 15 says the DoPC must cover the product’s performance over its life cycle for at least these groups of characteristics, from these dates:

Annex II characteristics	What they are	From
Points (a) to (d)	Climate change: total, fossil, biogenic, land use and land use change	8 January 2026
Points (e) to (m)	Ozone depletion, acidification, eutrophication, photochemical ozone, resource depletion, water use	9 January 2030
Points (n) to (s)	Particulate matter, ionising radiation, ecotoxicity, human toxicity, land use	9 January 2032

Read the two conditions together

These dates are the earliest the requirement can apply. It only applies to a product once a harmonised technical specification under the new CPR covers it. A date in the table on its own does not mean your product needs a declared GWP today.

The performance must include the product’s packaging, and Article 15 says it is to be calculated with software the Commission makes available free of charge. Updates to that software become mandatory one year after they are published.

Where EN 15804 fits

The regulation’s preamble (recital 7) explains that the Commission’s calculation software should use, in particular, the characterisation factors applicable under EN 15804, or future applicable standards. In practice, this ties the CPR’s environmental declaration to the same method family as construction EPDs.

That is why EN 15804+A2 EPDs are the best preparation a manufacturer can have. A DoPC is not the same document as an EPD, and the product-family rules are still being written, but the underlying LCA, data and indicators are largely the same work.

When will it reach my product?

The Commission publishes a working plan that sets the order in which product families get new harmonised technical specifications. The first working plan, COM(2025) 772 of 16 December 2025, covers 2026 to 2029. It is a plan, not a legal deadline, and dates can move.

At the time of checking:

• The Commission’s harmonised standards page says existing standards will be replaced as new ones are made mandatory under the new CPR, and that the first are probably those for cement, in 2027. The working plan schedules the new cement standards to be made mandatory in Q4 2027.
• The working plan’s priority list starts with precast concrete, structural metallic products, reinforcing steel, doors and windows, cement and thermal insulation.
• The working plan also says the Commission is supporting the drafting of complementary PCRs and has launched work on European background datasets, to be used where company-specific data are not available.

The CPR also allows the Commission to set mandatory minimum environmental requirements for construction products in public procurement through delegated acts, and it introduces a digital product passport for construction products. The details of both are to be set out in further acts.

How to track your product family

Find your product family in Annex VII of the regulation, then check the Commission’s harmonised standards page and the latest working plan for it. When an implementing act makes a new standard mandatory for your family, the clock starts.

What to do now

1. Manufacturers: get an EN 15804+A2 EPD for your main products. It builds the LCA model, data and verification habits you will need for the DoPC. Customers are already asking for it.
2. Manufacturers: find your product family and follow it. Watch the working plan and the harmonised standards page. Join your trade association’s CPR work if you can.
3. Manufacturers: collect primary data. Plant energy, material inputs, waste and supplier data (see LCA 202). Background datasets set by the Commission are expected to be conservative, so good company-specific data will matter.
4. Buyers and specifiers: start asking for GWP by module now. Ask for EN 15804+A2 EPDs and learn to read them (lesson 2). Once DoPCs carry GWP, you will have a harmonised figure to compare, and you will already know how.
5. Everyone: don’t over-claim. Until a product family is covered, a supplier saying their product is “CPR-compliant on carbon” is making a claim the regulation can’t yet back.

Exercise

A sales colleague writes: “The CPR has applied since January 2026 and requires GWP in the declaration from 8 January 2026, so from now on every product we sell in the EU needs a GWP figure on its DoPC.” What is right and what is wrong?

Answer

Right: the new CPR, Regulation (EU) 2024/3110, applies from 8 January 2026, and Article 15 sets 8 January 2026 as the date from which the DoPC must cover the climate change indicators.

Wrong: the obligation applies to products covered by a harmonised technical specification under the new CPR. Until the new standard for a product family is made mandatory, products in that family continue under the old framework, and there is no new-CPR DoPC to put a GWP on. At the time of checking, the Commission expected the first new mandatory standards (for cement) in 2027. The right advice is: “Find out when our product family is scheduled, and get EN 15804+A2 EPDs ready in the meantime.”

What you should now be able to do

• Say what Regulation (EU) 2024/3110 is and when it applies.
• Explain why the environmental declaration reaches products family by family.
• List which environmental characteristics must be declared, and from which dates.
• Explain how the CPR connects to EN 15804 and to EPDs.
• Tell a manufacturer and a buyer what to do now.

Sources

• Regulation (EU) 2024/3110 of 27 November 2024 laying down harmonised rules for the marketing of construction products, EUR-Lex (recital 7; Articles 13, 15, 94 and 96; Annexes II and VII). Text read via the EU Publications Office.
• European Commission, CPR overview.
• European Commission, Products and harmonised technical specifications (first standards under the new CPR probably for cement, in 2027).
• European Commission, (First) CPR Working Plan for 2026–2029, COM(2025) 772 (priority list, schedule, c-PCRs, background datasets).

Checked: 2026-09-29