CE, CPR, and EPDs in one picture
CE marking is your legal passport under the Construction Products Regulation. It rests on harmonised technical specifications and a Declaration of Performance. EPDs sit next to this, not inside it, but buyers increasingly expect them. The revised CPR adds environmental performance declarations and a combined Declaration of Performance and Conformity, which nudges content closer to what an EN 15804 EPD already provides.
The construction ecosystem is big enough that enforcement matters commercially. It represents about 5.5 percent of EU GDP, employs roughly 25 million people, and includes about 430,000 companies with around €800 billion in turnover (Council of the EU, 2024) (Council of the EU, 2024).
What CE marking enforcement looks like in 2025
The new CPR was published on December 18, 2024 and entered into force on January 7, 2025. Most provisions start to apply on January 8, 2026. Penalty provisions, including those tied to environmental performance declarations, kick in on January 8, 2027 (FPS Economy Belgium, 2025) (FPS Economy Belgium, 2025).
Market surveillance is already active. EU authorities validated 4,137 Safety Gate alerts on dangerous non‑food products in 2024, the highest on record, with more than 4,200 follow‑up actions reported. That trend signals stepped‑up checks, including for online sales channels, in 2025 (Spanish Ministry of Consumer Affairs, 2025).
Great Britain in 2025
As of May 21, 2025 guidance, Great Britain continues to recognise CE marking for construction products, following a ministerial statement on September 2, 2024. UKCA remains available, and any future change to CE recognition is expected to include a minimum two‑year transition window if government proceeds with reforms (GOV.UK, 2025) (GOV.UK, 2025).
If you supply both GB and EU markets, keep your technical file aligned with the applicable designated or harmonised standard and document the route to conformity clearly to avoid double work.
Digital Product Passports and the data ripple effect
The CPR introduces Digital Product Passports that will carry the declaration, safety, and use information and are intended to support whole‑building carbon calculations. The Commission’s ESPR framework also entered into force on July 18, 2024, with the first ESPR working plan adopted on April 16, 2025. Product‑specific rules will follow through delegated acts, so data systems built today should anticipate machine‑readable, referenceable records (European Commission ESPR, 2025).
A Commission note highlights that offsite methods enabled by better product data can cut manufacturing‑phase construction waste by about 10 to 15 percent, which is already influencing public buyers’ expectations in tenders (European Commission DG GROW, 2025).
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EPDs under the new CPR lens
An EN 15804 EPD remains a voluntary market document, but the CPR’s environmental performance declarations mean your CE‑facing dossier will need life‑cycle information that overlaps with EPD content. That makes a single, high‑quality data backbone smart. The same primary data set can feed CE documentation, EPDs, and digital passports with consistent numbers and assumptions.
Five fast checks before an audit or buyer visit
- Confirm the correct harmonised standard for each product and keep the cited version in your file.
- Maintain a clean trail to your notified or approved body where applicable and verify certificate dates.
- Map your Declaration of Performance to the new Declaration of Performance and Conformity structure early, even before 2026 applies in full.
- Align environmental performance declarations with the datasets and cut‑off rules you use for EN 15804 EPDs so numbers reconcile.
- Assign owners for surveillance requests. Response time and document completeness often decide outcomes.
Common enforcement tripwires
Missing or inconsistent CE marking on labels and in manuals. DoP values that do not match test reports. An incorrect AVCP system in the file. Certificates that reference withdrawn standards. Environmental claims in marketing that do not align with your declared performance. Marketplaces listing your SKU with outdated files. These are fixable with routine internal reviews.
Linking compliance to revenue
A product with third‑party verified EPDs faces fewer carbon accounting penalties in many projects, which keeps it in play on specs rather than being swapped out for a competitor late in the bid. The administrative lift to produce EPDs is often what slows teams down. Choosing a partner who handles data collection across plants and ERP systems avoids that drag and gets you to credible, referenceable documents quicker. It is not just compliance. It is speed to spec.
Timeline cheat sheet
January 7, 2025 entry into force of the new CPR. January 8, 2026 most provisions start to apply. January 8, 2027 penalty and environmental declaration enforcement begins. CE recognition in GB continues through 2025 with reforms under consultation, with a stated intent that any change would allow at least two years of transition if implemented (FPS Economy Belgium, 2025. GOV.UK, 2025) (GOV.UK, 2025).
What to do next
Treat 2025 as your dress rehearsal. Build one source of truth for tests, declarations, and life‑cycle data. Pilot a Digital Product Passport record on a flagship SKU. Refresh your CE file structure so it maps cleanly to the coming DoPC. Get an EN 15804 EPD in place where competitors already have one. That is the boring work that wins specs. And it definately pays off.
