Regulation (EU) 2024/3110 · environmental characteristics

Where will the environmental figures in your declaration of performance come from?

Under the new Construction Products Regulation the environmental performance of a product becomes part of its declaration of performance and conformity. The calculation software is provided by the Commission. What the Commission does not provide is the data you feed into it — or the evidence that the data is true.

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What actually changed

Article 15(2) of Regulation (EU) 2024/3110 requires the declaration of performance and conformity to cover the environmental sustainability performance of the product over its whole life cycle, against the pre-determined environmental essential characteristics listed in Annex II. Annex II sets out nineteen characteristics, lettered (a) to (s) — the same indicator set as EN 15804+A2. Recital 7 states that the Commission is to make available the characterisation factors applicable in accordance with EN 15804 or future applicable standards.

The part most people miss

Article 15(2) also requires those values to be calculated using the latest version of the software made available free of charge on the Commission’s website, and provides that a software update becomes mandatory one year after its publication.

So the calculation stops being a competitive question. Everyone will use the same free tool. What remains open — and what decides whether the declared figures survive scrutiny — is the quality and traceability of the life-cycle data entered into it.

The dates, from the Regulation itself

These are the dates set by Regulation (EU) 2024/3110. They are not a programme interpretation and no operator can shorten or extend them.

What appliesFrom
Annexes I, II, III, IV, VII, IX and X, and the articles listed in Article 967 January 2025
The remaining provisions of the Regulation, other than Article 928 January 2026
Annex II characteristics (a)–(d): climate change — total, fossil, biogenic, land use and land use change8 January 2026
Penalties under Article 928 January 2027
Annex II characteristics (e)–(m): ozone depletion, acidification, eutrophication, photochemical ozone formation, resource use, water use9 January 2030
Annex II characteristics (n)–(s): particulate matter, ionising radiation, ecotoxicity, human toxicity, land-related indicators9 January 2032

Why this does not mean every product is caught in January 2026

Article 95(9) provides that the requirements and obligations of Chapters I, II and III apply to a given product family or product category one year after the adoption of the implementing act under Article 5(8) that makes a harmonised standard mandatory, or after the act under Article 6(1) covering that family, unless the implementing act sets a later date. Until then, under Article 95(3) the harmonised standards referenced under Regulation (EU) No 305/2011 and in force on 8 January 2026 remain valid under that Regulation until the Commission withdraws them.

Article 95(9) also allows an economic operator to apply a new harmonised technical specification from the date it enters into force, ahead of the one-year period, by carrying out the procedure leading to a declaration of performance and conformity. Acting early is a choice, and it is available now.

Which products are first — and it is already decided

The first standardisation request under the new Regulation, Commission Implementing Decision C(2025) 4828 of 28 July 2025, sets deadlines for revising the following standards. The revised versions are to carry life-cycle environmental characteristics and factory production control requirements in the text of the standard itself.

StandardProductRevision due
EN 197-1Common cements30 June 2027
EN 16908Cement and building lime — environmental declarations30 June 2027
EN 413-1Masonry cement31 December 2027
EN 459-1Building lime31 December 2027
EN 15368Hydraulic binder for non-structural applications31 December 2027
EN 14216Very low heat special cements30 June 2028
EN 14647Calcium aluminate cement30 June 2028
EN 15743Supersulfated cement30 June 2028
EN 13282Hydraulic road binders30 June 2028

If you make cement, lime or a hydraulic binder, the environmental characteristics of your product become part of a harmonised specification before they do for almost anyone else. The useful consequence is that the work has a deadline you can plan against, rather than an open-ended obligation.

The question that decides the quality of the answer

Free software applied to weak data produces weak figures with a compliant appearance. When a buyer, an assessor or a market surveillance authority asks where a number came from, the answer has to be traceable. This is where declarations differ from one another, and it is the part of the work we build around.

01

Measured, not estimated

Where the declaration relies on measured product characteristics, results come from an accredited testing laboratory rather than values taken from sector averages.

Accredited testing laboratory
02

Production data already under surveillance

Where the manufacturer holds factory production control certification under Regulation (EU) No 305/2011, the production behind the inventory is audited on a continuing basis by a notified body. That is a stronger basis than data assembled once for the purpose of a declaration.

Notified body under the CPR
03

Independent verification

The life cycle assessment and the declaration are verified independently, following EN ISO 14025 and the impartiality requirements of EN ISO/IEC 17029. The verifier is never the author of the assessment.

EPD Polska, operated by Multicert
04

Published and checkable

The declaration is published in English with a unique registration number, a validity period and a named verifier, in a register open to anyone without registration or a fee.

Public register

Factory production control certification, product testing and CE-related certification are carried out by the accredited and notified bodies we work with, each within its own notified scope. Those bodies do not verify environmental declarations, and we do not present them as doing so. What their work provides is the evidence base underneath the life-cycle data.

What we state

An environmental product declaration issued under this programme gives you verified life-cycle data prepared to EN 15804+A2 and EN ISO 14025, independently verified, published with a unique identifier, together with the underlying assessment and the record of where the primary data came from.

What we do not

A declaration does not replace the declaration of performance and conformity, and its indicator values do not automatically become the values entered there. Preparing that declaration, and calculating its environmental characteristics with the Commission’s software, remains the manufacturer’s responsibility. Nor does a declaration rank one product above another, or substitute for testing and certification required for CE marking.

The rules of the programme, including the position on ISO 14025:2026 and the transition, are set out in the General Programme Instructions — see Programme rules & verification.

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