Introduction: Why the Construction Products Regulation Was Revised
The Construction Products Regulation has been the cornerstone of EU single-market rules for construction products since 2011. Regulation (EU) No 305/2011 established the framework for CE marking, Declarations of Performance, and harmonised technical specifications that allow construction products to move freely across EU member states. But the original regulation was designed for a different era. It focused on mechanical performance, fire safety, and health characteristics. Environmental sustainability was barely mentioned.
Major overhaul: CPR 2024/3110 retains the core function of facilitating the internal market but adds three new dimensions: environmental sustainability (GWP declaration), Digital Product Passport (DPP), and a reformed Assessment and Verification System (AVS).
After years of evaluation and stakeholder consultation, the European Commission concluded that the CPR needed fundamental revision. The result is Regulation (EU) 2024/3110, published in the Official Journal of the European Union in December 2024. This new regulation represents the most significant overhaul of EU construction-product regulation in over a decade.
Key Changes in CPR 2024/3110
major new dimensions added: GWP declaration, Digital Product Passport, and reformed Assessment & Verification System
Environmental Sustainability: GWP Declaration
The headline environmental provision is the requirement for manufacturers to declare the Global Warming Potential of their construction products. This obligation reflects the EU’s broader climate ambitions and acknowledges that construction products collectively contribute a significant share of lifecycle carbon emissions in the built environment. The legal text empowers the Commission to require GWP declaration through harmonised technical specifications, bringing environmental data into the same regulatory framework that already governs mechanical and safety characteristics.
For manufacturers, this means that environmental performance will no longer be a voluntary differentiator but a regulated characteristic. The data basis for GWP declaration will be life-cycle assessment methodology as defined in EN 15804+A2, the European standard for construction-product EPDs. Manufacturers who already hold Environmental Product Declarations will have the foundational data needed for compliance.
Digital Product Passport (DPP)
CPR 2024/3110 introduces the concept of a Digital Product Passport for construction products. The DPP is envisioned as a digital record accompanying each product, containing performance data, environmental information, and traceability data accessible through a standardised digital interface. The DPP concept aligns with the broader EU Digital Product Passport initiative under the Ecodesign for Sustainable Products Regulation (ESPR) but is tailored to the specific requirements of the construction sector.
The DPP is intended to facilitate market surveillance, support circular-economy objectives by providing information about material composition and recyclability, and streamline the flow of product data from manufacturers through the supply chain to building operators and end-of-life handlers.
Reformed Assessment and Verification System (AVS)
The regulation revises the assessment and verification system for construction products, updating the roles of notified bodies, technical assessment bodies, and market surveillance authorities. The reformed AVS aims to improve the reliability of product performance data, reduce the burden on manufacturers where possible, and strengthen enforcement against non-compliant products.
Critical Clarification: What Is NOT Yet Mandatory
Do not confuse entry into force with enforcement: The regulation is published law, but many substantive requirements (GWP declaration, DPP) are NOT yet operational. They depend on new harmonised technical specifications and implementing acts that have not yet been published.
Understanding the CPR 2024/3110 requires distinguishing between the regulation as published law and the specific obligations it creates. The regulation has entered into force, but many of its substantive requirements are not yet operational. This distinction is frequently misunderstood, and getting it wrong could lead to unnecessary panic or, conversely, complacency.
GWP Declaration Is NOT Yet Mandatory
The regulation provides the legal basis for requiring GWP declaration, but the obligation itself will only become enforceable through a specific, multi-step mechanism:
- New harmonised technical specifications (hTS). The Commission must mandate CEN to develop new hTS that incorporate the GWP declaration requirement. As of March 2026, no new hTS incorporating GWP requirements have been published.
- Publication in the Official Journal. Once a new hTS is finalised by CEN and accepted by the Commission, it must be published (its reference cited) in the Official Journal of the EU. Only upon publication does the hTS become a harmonised standard with legal force.
- Coexistence period. After publication, a coexistence period of typically 12–36 months begins, during which manufacturers can comply with either the old or new standard.
- Withdrawal of old hTS. At the end of the coexistence period, the old harmonised standard is withdrawn, and compliance with the new hTS becomes the sole means of achieving CE marking. Only at this point does GWP declaration become fully mandatory.
This means that several years will likely elapse between the regulation’s entry into force and the actual moment when manufacturers must declare GWP as a condition of placing products on the EU market. The timeline depends on the pace of CEN standardisation work, the Commission’s processing of hTS references, and the length of coexistence periods.
Digital Product Passport Is NOT Yet Mandatory
The DPP requirement faces an even longer path to operational status. It requires not only new harmonised technical specifications (the same mechanism described above for GWP) but also implementing acts from the European Commission specifying the technical architecture, data format, and interoperability requirements for the digital passport system. As of March 2026, neither the necessary hTS nor the implementing acts have been published. The DPP therefore remains a regulatory objective rather than a current obligation.
Manufacturers should monitor developments in the European Commission’s DG GROW construction sector page for updates on both hTS development and DPP implementing acts.
What Remains From CPR 305/2011
The core regulatory architecture of the CPR continues under the new regulation. CE marking remains the mechanism for demonstrating compliance with harmonised technical specifications. The Declaration of Performance remains the document through which manufacturers communicate their product’s essential characteristics. Notified bodies continue to perform third-party assessment and verification tasks. And the fundamental principle of mutual recognition, that a product complying with harmonised standards in one member state can be placed on the market in all member states, remains intact.
Manufacturers already familiar with the CPR system will recognise the basic structure. The new regulation adds environmental dimensions to this familiar framework rather than replacing it entirely.
Timeline Expectations
| Milestone | Estimated Timing | Status (as of March 2026) |
|---|---|---|
| Regulation enters into force | Early 2025 | Completed |
| CEN standardisation work begins/accelerates | 2025–2026 | In progress |
| First new hTS with GWP published in Official Journal | 2027 (earliest) | Not yet |
| Coexistence period (12–36 months) | 2027–2030 | Not yet |
| Mandatory GWP declaration for first product families | ~2028–2030 | Not yet |
| DPP implementing acts published | TBD | Not yet |
These estimates are speculative and could shift in either direction. What is certain is that the obligation will come, and manufacturers who are unprepared when it arrives will face a more compressed and more costly transition than those who begin preparing now.
What Manufacturers Should Do Now
Obtain Environmental Product Declarations
The single most effective preparatory action is to obtain EPDs for your key products. An EPD, based on a life-cycle assessment complying with EN 15804+A2, provides exactly the GWP data that the CPR will require. Having EPDs in place means that when new hTS are published, your environmental data infrastructure is already built. The process of obtaining an EPD takes three to six months, so starting now provides comfortable lead time.
Build Data Infrastructure
Even if you are not ready to commission a full LCA, begin building your environmental data infrastructure. Ensure that energy consumption data by carrier type, raw-material input records, transport documentation, and waste generation data are systematically collected and archived. This data will form the foundation of any future LCA, and having it organised and accessible will significantly reduce the cost and time required when you do commission an EPD.
Engage with Your Programme Operator
Establish a relationship with a programme operator that can guide you through the EPD process when you are ready. EPD Polska provides guidance on PCR selection, LCA practitioner recommendations, and the registration process. Understanding the programme operator’s requirements and timeline expectations will help you plan effectively.
Monitor Standardisation Developments
Follow the work of CEN Technical Committee 350 and the Commission’s construction-sector page for updates on new harmonised technical specifications. Industry associations and programme operators often provide digests of standardisation developments that can help you stay informed without needing to track every committee meeting.
Prepare for the Digital Product Passport
While the DPP is not yet operational, the direction of travel is clear. Begin thinking about how your product data, including performance characteristics, environmental data, material composition, and supply-chain traceability, is structured and stored digitally. Companies with well-organised digital product data will be better positioned to meet DPP requirements when the implementing acts are published. The DPP framework will likely build on existing data structures, so investment in digital data management is unlikely to be wasted.
Start now: An EPD takes 3–6 months to obtain and provides exactly the GWP data the CPR will require. Manufacturers who begin now will have comfortable lead time before obligations take effect.
Implications for the Broader Market
CPR 2024/3110 sends a clear signal that environmental sustainability is moving from the periphery to the centre of construction-product regulation in Europe. Architects, structural engineers, and procurement officers will increasingly require environmental data as a standard part of product specifications. Building rating systems will align their requirements with the CPR framework. And corporate sustainability reporting under the CSRD will drive demand for verified product-level environmental data through the supply chain.
The manufacturers who will benefit most from this transition are those who treat environmental data not as a regulatory burden but as a strategic asset. An EPD is simultaneously a compliance tool, a marketing asset, a procurement qualification, and an operational improvement catalyst. The revised CPR provides the strongest regulatory push yet for manufacturers to invest in this asset.
Frequently Asked Questions
When exactly does GWP declaration become mandatory under the new CPR?
There is no fixed date. GWP declaration becomes mandatory for a specific product family only after the following sequence is completed: new harmonised technical specifications incorporating GWP requirements are developed by CEN, published in the Official Journal of the EU, subjected to a coexistence period (typically 12-36 months), and the old harmonised standards are withdrawn. As of March 2026, no new hTS have been published, so GWP declaration is not yet mandatory for any product family. Realistic estimates suggest the earliest mandatory application could be around 2028-2030, depending on the pace of standardisation.
Does the new CPR require an EPD specifically, or is any GWP calculation acceptable?
The regulation does not explicitly require an EPD as such. It requires GWP declaration in accordance with harmonised technical specifications. However, those specifications are expected to reference the methodology of EN 15804+A2, which is the same methodology underlying EPDs. In practice, an EPD produced according to EN 15804+A2 will provide the data needed for CPR compliance. Whether the formal requirement is labelled „EPD” or „environmental performance declaration” is a matter of terminology; the underlying data and methodology are the same.
Is the Digital Product Passport mandatory now?
No. The DPP requires both new harmonised technical specifications and implementing acts from the European Commission specifying the technical architecture and data requirements. Neither has been published as of March 2026. The DPP is a future requirement that manufacturers should prepare for, but it is not a current obligation.
Does CPR 2024/3110 apply to products manufactured outside the EU?
Yes. The CPR applies to all construction products placed on the EU internal market, regardless of where they are manufactured. A product manufactured in Turkey, China, or the United States must comply with the same harmonised technical specifications as a product manufactured in Germany or Poland if it is to carry the CE mark and be sold in the EU. This includes any future GWP declaration and DPP requirements once they become operational.
How does the new CPR interact with the CSRD and the Green Claims Directive?
The CPR, CSRD, and the EU Green Claims Directive (which was withdrawn by the European Commission in June 2025, with its future status uncertain) are separate pieces of legislation, but they are complementary in intent. The CPR regulates the product itself and its declaration of performance (including, in future, environmental performance). The CSRD requires companies to report on their sustainability performance, including Scope 3 emissions that depend on product-level data. If a directive similar to the Green Claims Directive is adopted in the future, it would regulate how environmental claims are made to consumers and require substantiation. EPDs and the data infrastructure behind them serve multiple regulatory frameworks simultaneously, making the investment in environmental product data highly leveraged across compliance obligations.
