What changed and when
Regulation (EU) 2024/3110 replaced CPR 305/2011, entered into force on January 7, 2025, and becomes applicable from January 8, 2026 for most construction products (Government of Ireland, 2026) (Government of Ireland, 2026). The regulation empowers the Commission to mandate environmental characteristics and set up the construction digital product passport via delegated acts (EUR‑Lex, 2024) (EUR‑Lex, 2024).
Why EPD data suddenly runs the show
The CPR’s sustainability indicators will be specified by product family and are expected to align with the European standards that already govern EPDs, notably EN 15804. That means the fastest route to compliance is the same data you use to publish product‑specific EPDs. In practice, the LCA that feeds your EPD also feeds the CPR disclosures for GWP and other indicators once required.
The first working plan is live
The Commission adopted the first CPR Working Plan for 2026 to 2029, which sets priorities for harmonised standards, delegated acts, and the digital product passport for construction products (European Commission, 2025) (European Commission, 2025). Expect phased requirements by product family rather than a single big‑bang date for everyone.
Buildings data will pull you in
A delegated regulation now defines a common EU method to calculate whole‑life GWP for new buildings, creating direct demand for product‑level carbon data that EPDs supply (European Commission, 2025) (European Commission, 2025). Member states must report GWP for new buildings over 1,000 m² from 2028 and for all new buildings from 2030, with results shown on energy performance certificates (BUILD UP, 2026) (BUILD UP, 2026). When owners need building‑level numbers, they will prize verified product numbers.
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What to measure first in 2026
Start with cradle‑to‑gate GWP for your priority lines, reflecting A1 to A3. Add transport and installation where material to your category. Use measured plant utilities, actual supplier invoices, and current electricity factors. If trustworthy averages are missing for a sub‑supplier, say so and document the assumption profile rather than inventing figures.
Priority products and sequencing
Not every category flips on the same day. The working plan sequences harmonised specifications and introduces sustainability characteristics progressively from 2026, so watch your family’s slot and the standardisation request behind it (DIBt, 2026) (DIBt, 2026). Teams that track their specific family avoid surprise retrofits of data models mid‑year.
Commercial stakes, plain and simple
Without an EPD, specifiers often apply conservative default factors. That can push your product out of contention once carbon is scored. With a verified EPD, the project team can count your real number, which keeps you in play even when price pressure rises. One mid‑sized project win often covers the paperwork outlay many times over. We see this pattern repeatedly.
A three‑week readiness sprint
- Map scope for two best‑selling SKUs in a priority family. Confirm system boundary and cut‑off rules that match EN 15804.
- Pull the latest full‑year plant data and top five inputs by mass or cost. Lock supplier contacts and a data‑request calendar.
- Select a program operator now so verification slots do not bottleneck your release.
Picking help that reduces your workload
Choose a partner that does data wrangling inside your organization instead of lobbing templates over the fence. Expect rigorous project management, fluency with program operators in both the EU and US, and guidance on PCR selection that mirrors what competitors used. The right team should free up R&D and plant leaders to run the plant, not chase spreadsheets. Speed with quality beats a slick portal that leaves the heavy lifting to you.
What good looks like by mid‑2026
A prioritized product list, plant‑verified inputs, a published or near‑final EPD for flagship SKUs, and a living evidence file ready for CPR disclosures. That package earns trust in bids and simplifies updates as delegated acts land. It is definately achievable if you start now.
