EU Construction Products Regulation: What Manufacturers Need Now
If Europe is on your sales map, the Construction Products Regulation shapes how your products enter, move, and get specified. A major recast took effect, with new timelines, digital product passports, and clearer expectations around environmental information. Here is the plain‑English guide that turns legal text into operational checklists, so commercial teams can plan launches and keep CE marking smooth.
CPR in a nutshell
The EU replaced the 2011 CPR with Regulation (EU) 2024/3110. It was published on 18 December 2024, entered into force on 7 January 2025, and most provisions begin to apply on 8 January 2026 (DIBt, 2024) (EUR‑Lex, 2024). The new text keeps the single market goal, clarifies roles for manufacturers, importers and distributors, and adds tools for the green and digital transitions.
What it actually covers
The CPR governs how you place construction products on the EU market and how you communicate performance. It relies on harmonised standards and European Assessment Documents. Where your product is within scope of a harmonised technical specification, CE marking comes after you issue the required declaration and follow the correct AVCP system. National rules still decide how works perform, the CPR sets the common language for product performance.
DoP becomes DoPC
You will see the Declaration of Performance evolve into a Declaration of Performance and Conformity, usually called DoPC. The UK’s 2025 statutory update even references Articles 13 and 15 of 2024/3110 by name, which is a useful reading aid for teams that sell into Great Britain and the EU (UK legislation, 2025). Day to day this means tighter alignment between the performance you declare and conformity obligations in one package.
Environmental performance and EPDs under the CPR
The recast makes environmental performance information part of the common language. Authorities can enforce penalties related to environmental performance declarations from 8 January 2027, which signals a step change for LCA data quality and availability (FPS Economy, 2025) (FPS Economy, 2025). EPDs based on EN 15804 remain the practical route to provide consistent, third‑party verified data. Some markets or product families may treat EPD data as de facto expected. When a harmonised text or delegated act specifies environmental data, treat it as table stakes.
Digital Product Passport, explained simply
Articles 75 to 78 set up a construction digital product passport. It will hold your DoPC, technical documentation, labels, and environmental data in a machine‑readable format that travels with the product and is accessible to authorities and users. The Commission will define specifics by delegated acts, so smart teams start mapping the data model now. Belgium’s guidance offers a clear overview of purpose and scope (FPS Economy, 2025) (FPS Economy DPP, 2025).
Why this matters commercially
Buildings use about 40% of EU energy, and over one third of energy‑related emissions come from buildings, so policy pressure will not relax (European Commission, 2025) (European Commission EPBD, 2025). Buyers want low‑friction compliance with credible carbon data. Products with current, clearly communicated performance and environmental declarations get specified faster, and stay in specs when carbon accounting is mandatory. An EPD you can place confidently beside a CE mark reduces risk for project teams.
Timelines that change your workflow
- 18 Dec 2024: Regulation 2024/3110 published. 7 Jan 2025: enters into force. 8 Jan 2026: most provisions apply.
- 8 Jan 2027: enforcement and penalty provisions for environmental performance declarations start.
- 9 Jan 2031: EADs under 305/2011 stop applying. 9 Jan 2036: ETAs issued under 305/2011 no longer valid. 8 Jan 2040: 305/2011 fully repealed.
These dates are published by Belgium’s federal authority and align with the EU text (FPS Economy, 2025).
Harmonised standards, EADs and your route to CE
If a harmonised standard covers your product, that is your main path. If it does not, an EAD plus ETA is your route. The new CPR also lets the Commission step in and create harmonised specifications if standardisation lags. That reduces the risk of long periods without a workable route to market. Keep an eye on standardisation requests and the CPR Acquis groups.
EPD scope and PCR choices
EPDs for construction products typically follow EN 15804 PCRs. If no product‑specific PCR exists, generic construction material PCRs from reputable program operators can bridge the gap. The practical way to choose a PCR is to review what your competitors used, when those PCRs expire, and which program operator your market accepts. A quality LCA partner will do that homework and organise the data collection so your engineers do not become part‑time auditors.
Data you should assemble now
Treat the DPP as a future‑proof folder. Start with a clean bill of materials, process flow, utilities by site and line, transport legs, packaging, and end‑of‑life assumptions. Add plant‑level QA documents that support your AVCP system. Map data owners by field. Decide which product families get product‑specific EPDs now and which can start with representative ones. This avoids a scramble when a harmonised text starts requiring additional enviromental information.
Country variations without surprises
Member States will keep making rules for construction works, yet the CPR asks them to use the common language and avoid requesting non‑harmonised product information that would block trade. That lowers the chance of bespoke ask lists at tender stage, although sector‑specific nuances will remain. Track national guidance, then align your CE and EPD packages to that common core.
How to turn this into momentum in 90 days
Week 1 to 2, map product families, their harmonised route, and current declaration status. Week 3 to 6, run a rapid data‑collection sprint that locks a reference year and fills LCA gaps. Week 7 to 10, draft EPDs and DoPC content in parallel, pick the program operator that fits your markets, and prepare the DPP fields you can populate early. Keep leadership in the loop with a one‑page heat map of products and deadlines. It is simple, not easy, and it is definately doable.
The short version for teams
The eu construction products regulation now hardwires environmental data and digital product passports into the same system that powers CE marking. The dates are set. The winners will treat EPDs, DoPC, and DPP as one workflow, not three projects. That is how you keep speed, stay compliant, and win the spec before competitors react.
Frequently Asked Questions
When do the new CPR rules start to apply and what happens to the old ones?
Published 18 Dec 2024, in force 7 Jan 2025, most provisions apply from 8 Jan 2026. EADs under 305/2011 stop applying on 9 Jan 2031, ETAs under 305/2011 become invalid on 9 Jan 2036, and the 2011 CPR is fully repealed on 8 Jan 2040 (FPS Economy, 2025).
Do we need an EPD for CE marking now?
EPDs are still the standard way to provide environmental performance under EN 15804. Where the harmonised text or a delegated act requires environmental data, it becomes part of your obligations and authorities can enforce penalties from 8 Jan 2027 (FPS Economy, 2025).
What is the Digital Product Passport in practice?
A structured, machine‑readable record that includes your DoPC, technical documentation, labels, and environmental data. Details come via delegated acts. It must be accessible, secure, and interoperable with BIM and the EU‑wide DPP system (EUR‑Lex, 2024).
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
