Introduction: The CPR Is Live — But What Does That Mean in Practice?
General application date of CPR 2024/3110 — but practical GWP and DPP obligations depend on new harmonised technical specifications that have not yet been published.
Regulation (EU) 2024/3110, the revised Construction Products Regulation, reached its general date of application on 8 January 2026. For the first time in EU construction-product law, the regulation embeds environmental sustainability, digital product data, and circular-economy principles directly into the single-market framework. Headlines have focused on mandatory GWP declaration and the Digital Product Passport (DPP). But three months in, the picture on the ground is more nuanced than the headlines suggest.
This article examines what has actually changed for manufacturers since January 2026, what remains conditional on forthcoming harmonised technical specifications (hTS), and what practical steps producers should take now to prepare for obligations that will crystallise over the next two to four years.
Critical distinction: CPR 2024/3110 establishes the legal framework for GWP declaration and the Digital Product Passport. However, these obligations become binding for a specific product family only after the European Commission mandates CEN to develop a new harmonised technical specification (hTS), that hTS is published in the Official Journal of the EU, and the coexistence period with the old standard expires. As of March 2026, no new hTS under CPR 2024/3110 has been published.
What Has Actually Changed Since January 2026
The Regulatory Framework Is in Force
The overarching legal structure of CPR 2024/3110 now applies. This means that the definitions, the scope, the obligations on economic operators, and the institutional framework — including the reformed Assessment and Verification System (AVS) — are part of EU law. The regulation replaces CPR (EU) No 305/2011 as the governing instrument for placing construction products on the EU internal market.
However, the practical effect for most manufacturers has been limited. The reason is structural: the CPR operates through harmonised technical specifications. A manufacturer’s concrete obligations — what to test, what to declare, what to verify — are defined not by the CPR itself but by the hTS applicable to their product. Since no new hTS under the revised CPR has been published in the Official Journal, most manufacturers are still operating under the old harmonised standards (hENs) cited under CPR 305/2011.
The Transition Provisions
CPR 2024/3110 includes transition provisions that allow products complying with existing harmonised standards to continue to be placed on the market. This means that current CE markings and Declarations of Performance remain valid during the transition. The regulation does not create a cliff-edge where overnight all products must comply with new requirements.
| Aspect | Status (March 2026) | Trigger for change |
|---|---|---|
| CPR 2024/3110 framework | In force (8 Jan 2026) | Already applies |
| GWP declaration | Not yet mandatory for any product | New hTS published + coexistence period ends |
| Digital Product Passport | Not yet operational | New hTS + EC implementing acts (registry, format, data carriers) |
| Existing CE markings / DoPs | Remain valid under transition | Old hEN withdrawn from OJ after coexistence |
| AVS reform | Legal framework applies | New hTS define specific AVS requirements per product |
Strengthened Obligations for Economic Operators
One area where changes are already tangible is the enhanced obligations for importers, distributors, and fulfilment service providers. The revised CPR clarifies and extends their responsibilities in ensuring that products on the EU market comply with applicable requirements. Importers must verify that the manufacturer has drawn up the required documentation — including the Declaration of Performance and, eventually, the DPP. Distributors must check that products bear the CE marking and that required documentation accompanies them.
These provisions apply now, although in practice their bite will increase as new hTS are published and the scope of required documentation expands.
GWP Declaration: The Mechanism Explained
Why GWP Is Not Yet Mandatory
The headline provision of CPR 2024/3110 is the requirement for manufacturers to declare the Global Warming Potential of their products. Article 22(4) specifies that the Declaration of Performance must include the environmental sustainability characteristics set out in Annex I, Part B — which includes GWP broken down into four sub-indicators (total, fossil, biogenic, and land-use/land-use change).
However, this obligation is activated through the harmonised technical specification applicable to the specific product. The sequence is precise:
The hTS activation chain:
- The European Commission issues a standardisation request to CEN for a specific product family.
- CEN develops the new harmonised technical specification (hTS), including GWP assessment methods.
- The hTS is cited in the Official Journal of the EU — coexistence period begins.
- During coexistence (typically 12–36 months), both old and new standards are valid.
- The old standard is withdrawn from the OJ — coexistence ends.
- Only now is GWP declaration mandatory for that product family.
As of March 2026, the Commission has published its First CPR Working Plan (2026–2029), which identifies priority product families for standardisation requests — including cement, concrete, steel structural products, and thermal insulation. But the standardisation requests are still being finalised, and CEN technical committees have not yet begun drafting the new hTS documents.
This means that the realistic timeline for the first mandatory GWP declarations is not before 2028–2029 at the earliest, depending on how quickly the standardisation process proceeds and the length of the coexistence periods.
EN 15804+A2 as the Data Foundation
While the exact assessment methodology in new hTS is still to be defined, it is widely expected to align with EN 15804+A2, the European standard for construction-product EPDs. EN 15804+A2 already defines the four GWP sub-indicators (GWP-total, GWP-fossil, GWP-biogenic, GWP-luluc) that correspond to the Annex I requirements in CPR 2024/3110.
This means that manufacturers who already hold an Environmental Product Declaration compliant with EN 15804+A2 will have the foundational environmental data needed to populate the GWP fields in future Declarations of Performance. An EPD does not substitute for a DoP, but it provides the LCA data on which the DoP declaration will be based.
The Digital Product Passport: Where Do We Stand?
The Legal Framework
CPR 2024/3110 introduces the Digital Product Passport (DPP) as a future companion to the Declaration of Performance. The DPP is envisioned as a structured digital dataset linked to a unique product identifier, carrying performance data, environmental data, compliance information, and traceability data that can be accessed by market surveillance authorities, specifiers, and — in some cases — end users.
The DPP concept is aligned with the broader EU Digital Product Passport initiative under the Ecodesign for Sustainable Products Regulation (ESPR), but is tailored to the specific context of construction products under the CPR framework.
Why DPP Is Not Yet Operational
The DPP has an even longer path to practical implementation than GWP declaration, because it requires two sets of prerequisites:
| Prerequisite | Status (March 2026) | Who delivers |
|---|---|---|
| New hTS for product family | Not yet published | CEN (on EC mandate) |
| EC implementing acts: DPP registry infrastructure | Not yet published | European Commission |
| EC implementing acts: DPP data format and carriers | Not yet published | European Commission |
| DPP service provider accreditation rules | Not yet published | European Commission |
No DPP without implementing acts: Even when new hTS are published, the DPP cannot be issued without the Commission’s implementing acts establishing the digital registry, data formats, unique identifiers, and data carrier requirements. None of these have been published as of March 2026.
The practical implication is clear: manufacturers should monitor DPP developments but should not invest in DPP-specific IT systems until the Commission publishes the implementing acts that define exactly what the DPP must contain, how it must be structured, and where it must be registered.
What the Commission’s First Working Plan Signals
Priority Product Families
The Commission’s First CPR Working Plan (2026–2029), published in December 2025, provides the clearest indication of which product families will face new requirements first. The priority list includes:
- Cement and building limes — high-volume, high-carbon-intensity products already well-covered by existing EPD programmes.
- Concrete and concrete products — including precast and ready-mixed concrete, where producer-specific EPDs vary significantly.
- Structural steel products — where the distinction between primary (BOF) and recycled (EAF) routes creates large GWP differences.
- Thermal insulation products — covering mineral wool, EPS, XPS, PUR/PIR, and bio-based alternatives.
The Working Plan outlines the Commission’s intention to issue standardisation requests to CEN for these product families. However, the plan itself does not create legal obligations — it sets the direction and timeline for the standardisation process.
Estimated Timeline for Priority Products
| Milestone | Estimated timeframe | Caveat |
|---|---|---|
| Commission standardisation requests issued | 2026–2027 | Timing subject to EC internal process |
| CEN drafts new hTS | 2027–2028 | CEN TC timelines are indicative |
| hTS published in Official Journal | 2028–2029 | Requires formal citation procedure |
| Coexistence period | 12–36 months after citation | Duration set in each hTS |
| Old hEN withdrawn — GWP mandatory | 2029–2032 | Depends on product family and coexistence length |
Practical Steps for Manufacturers in Q2 2026
The fact that GWP and DPP are not yet mandatory does not mean manufacturers should do nothing. On the contrary, the preparation window is the most valuable phase for building competitive advantage.
Step 1: Audit Your Product Portfolio
Identify which of your products fall within the Commission’s priority product families. If you manufacture cement, concrete, steel, or insulation, you are in the first wave. Map your portfolio against the Working Plan priorities to understand which products will face new requirements earliest.
Step 2: Commission or Update EPDs
An EN 15804+A2-compliant EPD is the most efficient way to generate the GWP data that will eventually populate your Declaration of Performance. If you already have EPDs, check that they are current, compliant with the +A2 methodology, and cover the product variants most relevant to your market. If you do not have EPDs, begin the process now — an LCA study and EPD verification cycle typically takes 3–6 months.
Why start now? Manufacturers who have current EPDs when the new hTS are published will be able to comply with GWP declaration requirements immediately, without the delay of commissioning an LCA study under time pressure. Early movers also gain market positioning advantages in green public procurement tenders that already reference EPDs.
Step 3: Prepare Digital Documentation Workflows
The CPR’s digital-first approach to product documentation is already in effect. Start migrating Declarations of Performance and technical documentation to structured digital formats. This prepares your internal systems for the eventual DPP requirements and reduces the transition burden when implementing acts are published.
Step 4: Monitor the Standards Calendar
Track CEN technical committee activities for your product family. The relevant TCs include:
- CEN/TC 51 — Cement and building limes
- CEN/TC 104 — Concrete and related products
- CEN/TC 135 — Execution of steel structures and aluminium structures
- CEN/TC 88 — Thermal insulating materials and products
Join industry associations and standardisation mirror committees to get early visibility on draft hTS timelines.
Step 5: Engage Your Supply Chain
GWP declaration requires upstream data — particularly for modules A1 (raw material supply) and A2 (transport to factory). If your LCA relies on generic database values, start collecting supplier-specific data now. Producer-specific data improves the accuracy and competitiveness of your EPD, and will strengthen your GWP declarations when they become mandatory.
The Bottom Line
CPR 2024/3110 is live legislation, but its most transformative provisions — mandatory GWP declaration and the Digital Product Passport — are conditional on new harmonised technical specifications and implementing acts that have not yet been published. For manufacturers, this creates a preparation window, not a compliance deadline.
The smartest use of this window is to invest in EPD programmes, build digital documentation capabilities, and engage with the standardisation process. When the new hTS are published and coexistence periods begin, prepared manufacturers will transition smoothly while unprepared competitors scramble.
Information current as of publication date. Obligations take effect after the publication of new harmonised technical specifications and European Commission implementing acts in the Official Journal of the EU.