what UK manufacturers need to know

CPR, CBAM & ESPR

Manufacturers of construction products face new requirements under the Construction Products Regulation (CPR), the Ecodesign for Sustainable Products Regulation (ESPR), and carbon reporting obligations linked to CBAM. These affect what product data to provide, how to support customers, and whether products can be sold in the UK and EU markets. This page provides practical guidance for UK manufacturers on how to prepare.

What's CPR?

The Construction Products Regulation (CPR) defines how construction products are assessed and declared when placed on the UK and EU markets.

As CPR advances, manufacturers are increasingly expected to provide clearer, more structured product information, including environmental data where this is defined in the applicable product standard.

The CPR Working Plan 2026–2029 points to a greater focus on environmental information.

Read the CPR guide

What's CBAM?

The Carbon Border Adjustment Mechanism (CBAM) affects how certain products imported into the EU are reported and priced based on their carbon emissions.

From January 2026, EU importers must account for embedded carbon in covered products, increasing demand for reliable emissions data from manufacturers supplying the EU market.

This marks the start of CBAM's definitive phase, where imports create carbon cost exposure for EU importers.

Read the CBAM guide

What's ESPR?

The Ecodesign for Sustainable Products Regulation (ESPR) is an EU regulation introducing new sustainability and product information requirements over time.

Although it does not apply directly in the UK, ESPR is relevant for manufacturers supplying products into the EU, as it will shape what product information customers need.

Implementation will be phased through EU working plans covering different product groups.

Read the ESPR guide

Are EPDs needed for CPR, CBAM & ESPR?

What's an EPD?

Why products with EPDs?

Benefits of EPDs

Learn EPD basics now

How are EPDs connected to CPR, CBAM & ESPR?

An EPD is no longer just a voluntary document. It is becoming a key part of compliance under new EU sustainability regulations.

1. CPR aligns with EPD methodology — Under the revised Construction Products Regulation (CPR), manufacturers are required to publish environmental characteristics where these are defined in the applicable product standard. These disclosures often follow the same data structure and calculation principles as EN 15804-compliant EPDs.

2. ESPR connects EPDs through the Digital Product Passport (DPP) — The ESPR introduces Digital Product Passports (DPPs) across EU sectors. For construction, CPR and ESPR work together to embed EPD-based data into the DPP, ensuring environmental information becomes part of each product’s digital record.

3. CBAM relies on product-level carbon data — From 2026, EU importers of carbon-intensive products must report embedded emissions under CBAM. While EPDs do not replace CBAM reporting, the product level carbon data they contain helps manufacturers support their EU customers’ compliance.

Get started with EPDs

Environmental product declarations (EPDs)

An EPD is a document that transparently reports the environmental impact of a product or material, based on a product life cycle assessment (LCA). The LCA evaluates the environmental effects throughout the product's lifecycle, from raw material extraction to disposal.

Until recently, EPDs have largely been voluntary in the EU, and they remain so in the UK. However, a new wave of regulations — including the CPR, ESPR, and CBAM — is making life-cycle-based environmental disclosures mandatory for many products. These disclosures align closely with the data structure and methodology of EN 15804-compliant EPDs.

A simple guide to EPDs

Over 80% of specifiers prefer materials with EPDs

According to the 2025 Carbon Experts Report, 83% of AEC professionals say that EPDs influence material selection in building projects.

As one specifier from Foster + Partners explains, EPDs are used early in design to understand embodied carbon ranges, and later to compare products and select lower-carbon options. This reflects how frameworks such as BREEAM v7 (including Mat 01) and RICS Whole Life Carbon v2 are applied in practice, where consistent, verified product data supports assessment and specification.

As a result, materials supported by transparent, third-party verified EPDs are often preferred in procurement.

How UK specifiers use EPDs

Why EPDs give you a competitive edge

1. Support material specification — Specifiers increasingly rely on EPDs to compare environmental impacts and select low-carbon materials early in the design process.

2. Strengthen bids and tenders — Public and private procurement often reward verified sustainability data. Having EPDs helps manufacturers meet green procurement criteria and stand out in project tenders.

3. Stay ahead of regulation — EPDs prepare manufacturers for evolving EU requirements. Alongside the CPR and ESPR, policies like the Carbon Border Adjustment Mechanism (CBAM) are expanding carbon reporting. Verified EPD data keeps you ahead of these changes and positions your products competitively for future compliance.

Understand EPDs in 20 minutes

This short course is designed for construction professionals who don’t need to create EPDs themselves — but do need to understand and communicate what they mean.

In under 20 minutes, you’ll learn:

What EPDs are and why they matter
How to read and interpret an EPD
How EPDs influence sustainable construction and material choices

No prior knowledge is required. By the end of the course, you’ll have a clear grasp of the essentials and feel confident discussing EPDs with colleagues, clients, and partners.

Take the EPD course

Trusted by leading manufacturers

The EPD journey

One Click LCA offers a set of tools and features tailored to support construction products manufacturers throughout their entire EPD journey, from creation to impact and reach analysis of published EPDs.

This guide offers an overview of One Click LCA's EPD solutions and features:

Scaling EPD production with API integrations
EPD templates with product-specific, pre-loaded data
Automation and quality check
Creating internally verified EPDs (Project EPDs) for tenders and contracts
Reaching the right buyers with Manufacturer Pages
Tracking your EPD performance with EPD Usage Analytics

Read about the EPD journey

EPD Generator

Create high quality EPDs ready for third-party verification for any product in any industry. The software also allows you to create private EPDs and TM65-compliant calculations. Meet CPR & ESPR requirements.

Explore the EPD Generator

Product Carbon Footprint

Measure and report product emissions from cradle-to-grave with the Product Carbon Footprint (PCF) tool. Calculate carbon footprint and comply with ISOs 14040, 14044, 14067, CBAM and EN 15804.

Explore the PCF tool

End-to-End Generators

Generate pre-verified EPDs efficiently and at scale. One Click LCA's tailored end-to-end tools offer an automated experience for multiple carbon-intensive categories such as concrete, electronics, luminaires, and HVAC products.

Explore the EPD Generator

EPD Usage Analytics

Track and analyse how your EPDs perform, giving you a clear view of metrics like the number of views and the level of interest your products are generating.

Explore EPD Usage Analytics

Manufacturer pages

Get your products in front of AEC professionals through a database of over 500,000+ LCA datasets. Help specifiers and buyers find your EPDs and get specified.

Explore the Manufacturer pages

"Not all of our competitors create EPDs, and since we do, it's a big benefit for us. Some projects we have won because we had the best EPDs and were able to provide answers surrounding them. With more and more need for reduced carbon footprint when building, EPDs will become increasingly important."

Andreas Lidö

Heidelberg Materials Precast Abetong

"A detailed analysis from One Click LCA on our materials led to us identifying a potential 70% reduction in the global warming potential for our LED board. This achievement was made possible by close collaboration with the supply chain and a deep understanding of the carbon data associated with their materials."

Matt Paskin

Solutions & Marketing Director at Whitecroft Lighting

"I was able to make adjustments that reflected regional conditions with a prospect, on-site and quickly. That moment turned into a serious business discussion. The tool enables not just compliance, but growth."

Steven McLaughlin

Operations Manager at OTB Materials

Frequently asked questions

Learn about CPR, CBAM, ESPR, & EPDs

What is the revised Construction Products Regulation (CPR) and why does it matter for manufacturers?

The revised EU Construction Products Regulation (CPR) requires manufacturers of construction products to disclose environmental performance data such as embodied carbon, in a pashed approach. This creates a stronger need for product-level environmental documentation. EPDs (Environmental Product Declarations), which report lifecycle emissions in line with EN 15804, provide a standardised and widely accepted method for meeting these disclosure requirements.

When will the revised CPR take effect?

January 7, 2025 — The regulation officially entered into force.
January 8, 2026 — First application phase: manufacturers must declare performance for Annex II (a–d), including Global Warming Potential (GWP).
January 9, 2030 — Expanded application: compliance extends to Annex II (e–m), covering additional environmental and sustainability indicators.
January 9, 2032 — Full compliance phase: Annex II (a–s) becomes mandatory, requiring comprehensive lifecycle environmental reporting.

What is the Ecodesign for Sustainable Products Regulation (ESPR)?

The ESPR introduces sustainability requirements for products placed on the EU market, including durability, recyclability, and carbon intensity. It also supports the rollout of Digital Product Passports (DPPs), which must include emissions data. Manufacturers can use EPDs and Product Carbon Footprints (PCFs) to generate verified product-level carbon metrics that can feed into sustainability disclosures and future DPP requirements.

When does the ESPR apply, and what are the product timelines?

The ESPR entered into force on July 18, 2024. Its implementation follows the first Working Plan (2025–2030), which sets the priorities for product-specific delegated acts. Based on the current roadmap, the first requirements are expected to apply progressively from the mid-2020s onward, with indicative timelines for key sectors as follows:

Iron & steel products – anticipated from 2026
Textiles (including apparel) and tyres – expected from 2027
Furniture and aluminium – expected from 2028
Mattresses – expected from 2029
Horizontal sustainability requirements and Digital Product Passports (DPPs) – expected to roll out between 2027 and 2029, depending on product category

What is CBAM and who does it affect?

The EU Carbon Border Adjustment Mechanism (CBAM) ensures that imported carbon-intensive goods face the same carbon costs as EU-made products. It currently applies to sectors such as cement, steel, aluminium, fertilizers, hydrogen, and electricity. While EU importers are responsible for reporting, non-EU manufacturers must provide accurate, verified emissions data to remain competitive and avoid reliance on conservative default values that may make their products appear more carbon-intensive.

What is the CBAM timeline and when do reporting and payment obligations apply?

Transitional phase: October 2023 – December 2025
During this period, EU importers needed to report embedded emissions quarterly but were not required to purchase CBAM certificates.
Definitive phase: from January 2026 onward
EU importers will be required to purchase and surrender CBAM certificates annually, based on the verified actual embedded emissions of imported goods.
First certificate surrender: September 30, 2027
The first surrender of CBAM certificates will take place in 2027, covering emissions from goods imported in 2026.

How do EPDs help manufacturers comply with CBAM requirements?

Although EPDs are not a standalone compliance mechanism for CBAM, they support manufacturers by providing third-party verified emissions data aligned with ISO 14067 and EN 15804+A2 standards. This data can be used to calculate actual embedded emissions using CBAM's methodology, helping manufacturers avoid reliance on default values and reducing the CBAM cost burden for EU importers.

Do I need third-party verified EPDs for CPR, ESPR, or CBAM compliance?

For CPR and ESPR reporting, third-party verified EPDs are often preferred or expected, as they provide recognised, standard-based lifecycle emissions data. For CBAM, emissions data must follow CBAM’s prescribed calculation method and be verified. Providing verified lifecycle or product-level carbon data via EPDs increases reliability, strengthens compliance reporting, and helps avoid default emission factors that may disadvantage the product.

How can One Click LCA help my company comply with CPR, ESPR, and CBAM?

One Click LCA enables manufacturers to calculate, document, and verify product-level emissions in alignment with ISO 14067 and EN 15804+A2. EPD solutions from One Click LCA support both carbon reporting and EPD creation at scale. This verified data can be used to meet CPR disclosure obligations, support ESPR Digital Product Passport requirements, and provide accurate emissions reporting for CBAM compliance.

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