CPR-2024: Decarbonization of construction products and new sustainability requirements
- hrvatinstella
- Sep 14
- 11 min read
The new version of the Construction Products Regulation (CPR) from 2024 introduces requirements for environmental sustainability of products and digitalization of information for construction product manufacturers.
The regulation is part of a broader package of measures through which the EU aims to decarbonize buildings, which are responsible for around 40% of energy consumption and 36% of energy-related CO₂ emissions.
In addition to the main objectives of the regulation, which remain unchanged, the revised CPR introduces:
A requirement that products must be designed, manufactured, and packaged in a way that reduces their negative environmental impact (Annex III)
A declaration of environmental sustainability information of the product (Annex II)
Digitalization of information through a Digital Product Passport (DPP)
The goal of these changes is to contribute to the sustainability of the construction sector and to improve information exchange along the supply chain, traceability, and transparency - in line with the broader goal of integrating digital technologies into the construction sector.
Who does the CPR Regulation apply to?
As before, the CPR (Construction Products Regulation) applies to manufacturers of construction products. Manufacturers must comply with the Regulation’s requirements when placing construction products on the market that are covered by harmonized technical specifications.
The Construction Products Regulation (CPR) applies to all construction products, including used products and key components, if they are being placed on the EU market.
A construction product is:
Any physical item (shaped or unshaped), including kits and 3D-printed products (CPR-2024 explicitly includes modern technologies),
That is supplied (sold, given, or part of a service) for use in construction,
With the intention of being permanently incorporated into a building or civil engineering work (e.g. houses, offices, roads, bridges, tunnels, pipelines, airports, ports, railways, dams, etc.). "Permanently" means the product is intended to remain a part of the building or infrastructure after construction or renovation is completed.
Examples of products covered:
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When does the application and compliance obligation begin?
CPR-2024 will start applying from January 8, 2026, marking the beginning of its gradual implementation. From that date, the European Commission will begin adopting harmonized technical specifications (hTS) under CPR-2024. These new hTS documents will gradually replace the existing harmonized standards.
Each product family falls under CPR-2024 only once an appropriate hTS is adopted for it through an implementing act.
This is followed by a coexistence period of at least one year before compliance with CPR-2024 becomes mandatory for those products. During this coexistence period, a manufacturer may either continue to follow the currently applicable hTS or voluntarily choose to comply with the new hTS under CPR-2024.
New obligations, such as the Declaration of Product Circularity (DoPC) and the Digital Product Passport (DPP), apply only to products that are covered by a new hTS adopted under CPR-2024.
What is hTS?
Harmonized Technical Specifications (hTS) are technical specifications developed by European standardization organizations, such as CEN or CENELEC, in cooperation with the European Commission. These standards define performance criteria and testing methods for construction products, ensuring that they meet the essential requirements of the CPR.
For a standard to become part of the regulation, it must be made mandatory through an implementing act. After a coexistence period, its application becomes mandatory across the EU.
List of published hTSs:👉 https://ec.europa.eu/docsroom/documents/56834
Exemptions
When a product is considered a construction product and is covered by a harmonized technical specification, the regulation provides for several types of exemptions that can reduce the compliance burden:
Individually manufactured or custom-made products
Products made exclusively for the purposes of heritage conservation or traditional construction
Products placed on the market in the EU’s outermost regions
New requirements
a) Product Requirements Related to Functionality, Safety, or Sustainability
The European Commission may adopt delegated acts establishing product requirements related to functionality, safety, and/or sustainability. These requirements are intended to address aspects that cannot be fully assessed through the declaration of essential characteristics, such as qualitative performance or conditions that require pass/fail validation.
In the area of sustainability, product requirements may include, for example, durability criteria relevant to the goals of the circular economy. The decarbonization of construction products is becoming increasingly important in meeting these requirements.
Examples of environmental characteristics that can become mandatory for construction products
Maximizing product durability and reliability
Minimizing greenhouse gas emissions throughout the product’s life cycle
Maximizing the share of reused, recycled, and by-product materials
Choosing safe, sustainably designed, and environmentally friendly substances
Energy consumption and energy efficiency
Ease of repair during the expected lifespan, including compatibility with commonly available spare parts
Recyclability and reusability
Sustainable sourcing of raw materials
Minimizing the packaging-to-product ratio
Reducing the amount of waste generated
The regulator will also provide guidance on how to meet environmental sustainability requirements, including:
Defining what constitutes the highest level of scientific and technical achievement for addressing environmental aspects related to a specific product category — including minimum recycled content, greenhouse gas emissions over the life cycle, resource efficiency, and reusability;
Providing technical solutions to avoid negative environmental impacts and risks, including the generation of waste materials, or, where avoidance is not possible, to reduce and mitigate them through warnings on the product, its packaging, and in the user instructions.
Declaration of Performance and Compliance (DoPC)
The name of the document has been changed compared to CPR-2011, as manufacturers are now responsible not only for declaring the performance of a product, but also for confirming its compliance with applicable requirements.
What remains the same is that this document continues to serve as the formal document supporting the CE marking, which itself only provides a summary of the information contained in the DoPC.
The DoPC is prepared following the template in Annex V of the CPR and must include:
The performance of the product with respect to its essential characteristics, based on the assessment methods from the applicable hTS (harmonized technical specification) or EAD (European Assessment Document)
The declared environmental performance, covering the entire life cycle of the product, including packaging
Reference to any mandatory product requirements prescribed by EU law, where applicable
Only the CE marking may be used on the DoPC as proof of compliance
The declaration of essential characteristics depends on:
Whether they are mandatory under a delegated act
Whether a minimum performance level has been defined as a condition for placing the product on the market
Whether the characteristics are required in the target market
What’s new compared to CPR-2011?
Manufacturers must now provide a copy of the DoPC electronically for each product placed on the market (Article 16). Until the Digital Product Passport (DPP) becomes mandatory, this obligation can be fulfilled by:
Sending an electronic version of the DoPC to customers, or
Making the DoPC accessible via a website
If a product is placed on the market in multiple EU Member States, the DoPC must be made available in the language(s) of each Member State.
b) Environmental Information Declaration
The obligation to publish the environmental characteristics of products will be gradually applied to each product as their harmonized technical specifications are revised to include them. The environmental characteristics are published in the Declaration of Performance and Compliance (DoPC), which is an integral part of the Digital Product Passport (DPP).
The environmental impact must be calculated taking into account the latest version of the reference package provided by the European Commission, which contains reference flows, impact assessment methods, characterization factors, groups of units, and flow properties applicable according to EN 15804+A2.
Manufacturers will need to calculate the environmental performance of their products themselves or through subcontractors, using LCA (Life Cycle Assessment) software or other methods. The calculation may require obtaining data from suppliers or using databases.
The calculation of the environmental impact of a product is based on the standard EN 15804 (2012) + A2 (2019), “Sustainability of construction works – Environmental product declaration – Core rules for the product category of construction products.” This standard specifies the required environmental characteristics.
For accurate and consistent calculations, it is necessary to follow the complementary Product Category Rules (c-PCR), which provide rules and guidance for applying EN 15804 + A2 to specific product categories. |
The calculation of the environmental impact is based on information about:
The material composition of the product, including details about the raw materials used, their origin, and quantities
The environmental impacts related to energy use, water consumption, emissions, and waste generation during the product’s manufacturing
The use phase of the product and end-of-life processes, such as recycling and disposal
The packaging used or expected to be used
Companies will need to use verified external data, which must comply with EN 15804+A2. External data refers to information collected from sources outside the manufacturer’s own operations, such as environmental impacts from raw material extraction and processing, production processes, transportation, and end-of-life activities. External data can be provided by databases or suppliers themselves.
Decarbonization of construction products is based on a thorough life cycle analysis of the product.
How will environmental information be verified?
The assessment of environmental characteristics will be verified by relevant notified bodies using the AVS 3+ system. The AVS 3+ system focuses on the evaluation of calculations and input data, without additional physical testing. According to AVS 3+, manufacturers are responsible for accurately documenting and providing information about the environmental sustainability of their products.
The verifier checks:
The accuracy and completeness of the required documentation and declarations
Whether the input data align with the technologies used in the production facility
A notified body is an organization designated by an EU Member State to assess the conformity of certain products before they are placed on the market. These bodies carry out various third-party tasks related to verification (audits, testing, etc.).
A list of notified bodies by country is available here:https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/notified-body-list?filter=legislationId:33,notificationStatusId:1
c) Introduction of the Digital Product Passport (DPP)
In the context of the CPR, the DPP is a digital record containing detailed information about construction products. The information must be accurate, complete, and regularly updated.
The DPP must be machine-readable
It must be accessible via QR code or barcode
The DPP will need to be uploaded to the DPP system
The DPP includes all relevant documents for the product, which are as follows (Article 76):
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Development of DPP Ecosystem
To support the implementation and accessibility of the DPP, the CPR foresees the development and use of several digital systems. These systems have different roles in storing, hosting, and enabling access to the data contained in the DPP or related to product tracking and compliance monitoring.
a) The European Commission will establish a DPP system. Although the details are not yet defined, once the system is established, the data included in the DPP will have to be stored there. The method of implementation will be presented at a later stage; at this phase, the following options are being explored for the future implementation of the DPP:
Direct uploading of the DPP into a central database,
Linking the system with service providers’ databases, or
Direct linking to manufacturers’ websites.
b) When a product is placed on the market, companies will be required to upload data, including unique identifiers and possibly other information related to the product passport, into a digital register managed by the European Commission.
c) The Commission will establish a publicly accessible web portal where stakeholders can search and compare data from the DPP.
Obligations of Stakeholders in the Value Chain
Manufacturers are required to prepare the Declaration of Performance and Compliance (DoPC), the Digital Product Passport (DPP), and to obtain the CE marking for their products. They must also ensure that the product is accompanied by all necessary general product information, user instructions, and safety information.
Importers, distributors, and authorised representatives are responsible for verifying the manufacturer’s compliance. They must check whether the documentation and labels provided by the manufacturer are complete, accurate, and accessible. The goal is to ensure that products placed on the EU market are compliant, safe, and properly documented.
End users (builders, installers, contractors...) are not subject to legal obligations under the CPR. However, they will benefit from clearer, more structured, and more accessible information. For example, data from the DPP can be used to calculate GHG emissions over the entire life cycle of new buildings.
"We can imagine that, just as today an investor (private or public) may ask a designer to revise a project to adjust economic costs, we will see investors encouraging designers to adapt projects to improve sustainability performance."
Incentives and demand for sustainable construction products
Chapter XII of the Construction Products Regulation relates to how construction products will be incentivesed by Member States and treated in public procurement across the EU. For SMEs (small and medium-sized enterprises), this has several important implications and highlights the importance of decarbonizing construction products.
1. Incentives (Article 82)
Public subsidies, grants, or tax incentives for construction products will only be granted to products that fall within the top two performance classes (e.g. for energy efficiency, durability, or recyclability).
This means:
SMEs will need to meet higher environmental or technical standards if they want their products to benefit from financial support or tax relief.
If an SME produces less sustainable products, it risks losing competitiveness, as buyers and contractors will be directed toward “higher-class” subsidized products.
2. Public Procurement (Article 83)
Public tenders (government contracts) will be subject to mandatory minimum environmental sustainability requirements.
Contracting authorities (e.g. hospitals, schools, public administration buildings, sports halls) may specify sustainability criteria in the form of:
Technical specifications (e.g. the product must meet specific eco-standards)
Selection criteria (e.g. only bidders with eco-certifications may participate)
Award criteria (e.g. extra points for environmentally friendly products)
Contract performance conditions (e.g. the execution of the contract must meet environmental requirements)
To be eligible for public contracts, construction products must meet minimum environmental requirements (which will be defined later through delegated acts). These requirements may cover areas such as energy efficiency, carbon footprint, recycled material content, life cycle performance of the product, etc.
Decarbonization of Construction Products – How to Prepare for the New Obligations?
Small and medium-sized enterprises (SMEs) that wait for the publication of hTSs (harmonized technical specifications) before starting to adapt risk becoming uncompetitive. For priority product groups such as windows, doors, insulation materials, façades, concrete, bricks, and tiles, the time to start adapting has already begun.
Calculate the carbon footprint of the product
Publishing the carbon footprint of a product will be mandatory, and for companies with multiple product categories, the calculation process can take six months to a year. Timely planning can reduce costs and save resources.
Benchmarking and product mapping
State incentives and public procurement criteria will be based on the currently most sustainable products. It is necessary to conduct a market analysis, determine the benchmark, and map your own products on the sustainability scale.
Develop a product decarbonization plan
The environmental characteristics of a product are influenced by:
the type of energy used in the production facility (fossil fuels vs. renewable energy),
machinery efficiency,
the amount of scrap,
the carbon footprint of purchased materials,
product transportation methods,
the distance of suppliers,
delivery methods, and
the ability to repair and recycle the product at the end of its life cycle.
All these phases of the product life cycle are opportunities to reduce environmental impact and improve sustainability. A decarbonization plan should be developed, and adaptations should start in a timely manner. EU funds are available to support such projects.
Implementation of the plan
In line with the decarbonization plan, it may be necessary to:
find new suppliers or cooperate with existing ones to reduce their carbon footprint
electrify production and install a solar power plant
procure electricity with a certificate of origin from renewable sources
find a transport partner with an electrified fleet
change product formulation to improve durability
Product certification
Third-party verification of environmental characteristics (e.g. EU Ecolabel) increases customer trust and ensures eligibility for public tenders — especially in buildings aiming for LEED or BREEAM certification. Additionally, verification of Environmental Product Declarations (EPDs) positively impacts a company’s reputation as a reliable supplier.
Prepare digital product passports (DPP)
Product data will become increasingly relevant as BIM and lifecycle carbon tracking software are adopted in building design. The DPP must include all required product information, be machine-readable, and accessible via QR code. Suppliers ready for this digital transition will have a clear advantage in future tenders and client demands.
How can the Sustainability Office support you?
The Sustainability Office acts as your external office, a long-term partner guiding you through the transformation towards sustainability and compliance with EU regulations.
We have the expertise, experience, and capacity. We offer not only advice but also practical solutions.
Reach out to us with confidence and secure new market opportunities.
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