CPR and EPDs: A deep dive for construction professionals

CPR is, by nature mandatory. CPR requires that all construction products and key parts sold in the EU declare environmental data, including used products that are sold on the market. The requirement enters in force product category by product category, one year after the relevant product category standards are updated to align with the new regulation.

CPR provides the following exclusions:

• Lifts, escalators, and most mechanical and electrical products are excluded.
• Individually manufactured or custom-made products, and products used only for heritage conservation are exempt from environmental data declaration.

EPDs are by nature voluntary, and they can be created for the products a manufacturer wants to cover. EPDs are typically created for new products, and sometime also for key parts, but rarely for small components.

CPR Product Families

1. Structural and load-bearing products

• Precast concrete products (normal, lightweight, autoclaved aerated concrete)

• Structural bearings and pins for structural joints

• Structural timber products, elements, and ancillaries

• Reinforcing and prestressing steel for concrete (and ancillaries) (including post-tensioning kits)

• Structural metallic products and ancillaries

• Masonry and related products (masonry units, mortars, and ancillaries)

• Building kits, units, and prefabricated elements

2. Building envelope and external components

• Doors, windows, shutters, gates, and related building hardware

• Curtain walling, cladding, and structural sealant glazing

• Roof coverings, roof lights, roof windows, and ancillary products (including roof kits)

• Internal and external wall and ceiling finishes (including internal partition kits)

• Chimneys, flues, and specific related products

3. Insulation and waterproofing materials

• Thermal insulation products (composite insulating kits/systems)

• Membranes (including liquid-applied membranes and kits for water and/or water vapour control)

• Geotextiles, geomembranes, and related products

4. Concrete, mortar, and related materials

• Cement, building limes, and other hydraulic binders

• Products related to concrete, mortar, and grout

• Aggregates

5. Fire safety and protection systems

• Fixed firefighting equipment (fire alarm/detection systems, fixed firefighting systems, fire and smoke control products, explosion suppression products)

• Fire-stopping, fire-sealing, and fire-protective products (including fire-retardant products)

6. Mechanical, electrical, and plumbing (MEP) components

• Pipes, tanks, and ancillaries not in contact with water intended for human consumption

• Construction products in contact with water intended for human consumption

• Power, control, and communication cables

• Space heating appliances

7. Flooring and interior fixtures

• Flooring products

• Sanitary appliances

• Circulation fixtures and road equipment

8. Adhesives, sealants, and fixings

• Construction adhesives

• Sealants for joints

• Fixings

9. Glazing and glass products

• Flat glass, profiled glass, and glass block products

10. Road and infrastructure products

• Road construction products

• Wastewater engineering products

11. Miscellaneous construction components

• Wood-based panels and elements

• Gypsum products

• Attached ladders

Which standards are applied and what environmental data is required?

Environmental data required under the CPR is always based on EN 15804+A2 standard. Further rules and harmonised scenarios are created by product working groups working under CEN, the European Committee for Standardisation. Once a harmonised technical specification (hTS) under the new regulation is in force, it becomes legally binding and the associated rules, including the disclosure of environmental data, must be followed. CPR calls the environmental data Essential Environmental Characteristics.

CPR’s environmental data disclosure requirements are staged, so climate change effects (global warming potential) are required from January 8, 2026, and all EN 15804+A2’s core environmental impact indicators are required from January 9, 2030. The additional environmental impact indicators from EN 15804+A2 are required from January 9, 2032. In practice, manufacturers may be able to save costs by issuing full LCA results from the start; this is expressly allowed. The initially required impact categories are:

• climate change effects — total; 
• climate change effects — fossil fuels;
• climate change effects — biogenic;
• climate change effects — land use and land use change;

Practically all construction product EPDs created in Europe today follow the EN 15804+A2 and ISO 14025 standards. EPDs are verified by a verifier approved by an EPD program operator, which draw up their own Product Category Rules. Many program operators implement core rules, without introducing further variance or non-comparability between EPDs. Other program operators introduce additional requirements.  Many EPD programs require disclosing all LCA categories in EN 15804+A2 already today. EPDs call the data Environmental Impact Indicators.

When do the requirements apply?

Revised rules come into force one year after the harmonised technical specification, created in line with the new regulation, has been published in the Official Journal of the European Union. Such requirements can also be created using European Assessment Documents (EADs), or by direct EU regulation, if no standard is available or due.

EPD requirements are voluntary, but EPDs are increasingly required to be able to sell your product to a client who needs the EPD data for construction project carbon accounting regulations, including in France, Belgium, Sweden, Denmark and Finland, and from 2028 onwards, across the entire EU. These are market-based requirements.

Who verifies the environmental data?

The CPR requires verification by Notified Bodies.  Environmental sustainability assessment is prepared by the manufacturer, based on factory production control conducted by the manufacturer, and validated by a Notified Body. The validation covers the environmental impact calculations and the input data in line with specific assessment and verification system rules (called L3+). Notified Bodies are accredited and subsequently authorised by EU member states. Manufacturers can choose which Notified Body to use for verifying their data.

EPDs are independently verified, which in most cases means third-party verification. Verifiers are authorised by the EPD program operators.  The verification follows the requirements of ISO 14025, and further rules set by the EPD program operators. Most, but not all, EPD program operators allow manufacturers to choose their verifier.

How is data collected, averaged and how long is it valid?

The CPR allows for the declaration of either product-specific data or worst-case data, where actual values are better or equal to what is declared. The results do not have a predetermined expiration date, but your product needs to remain in line with the declared performance.

EPD data collection does not need to cover the entire activity, and while not recommended, it can be an ad hoc process. EPDs allow declaring either product-specific data, or averaged data (with a set variance allowed for averaging). The results are valid for five years, unless your product undergoes a material change, defined as a 10 % change in any environmental impact.

How is the data declared and published?

CPR results are incorporated into a Declaration of Performance and Conformity (DoPC). The DoPC must be available in the languages required by the EU member states, where the product is intended to be made available. The DoPC distribution follows these rules:

1. The DoPC must be provided in electronic format for each product made available, or
2. The DoPC must be incorporated into a CPR-aligned digital product passport, available through the digital product passport system created for the CPR, or
3. The DoPC must be available in human- and machine-readable, commonly readable format, from the manufacturer’s website free of charge accessible at any time.

EPD data is declared in a format aligned with requirements of EN 15804+A2, often using an approved template defined by an EPD program operator. EPDs are made available by the EPD program operators on their websites until they expire.

What next? How can creating EPDs help you prepare for CPR

Manufacturers have to create or update their Factory Production Control systems to include information on material quantities and provenance to be able to calculate the essential environmental characteristics.

Creating EPDs from the input data allows you to prove your system end-to-end while positioning you to win business. Furthermore, the data you have calculated for EPDs can be substantially reused by updating the model to align with your sector’s harmonised technical specification once it is issued.

The third party verification system applied to EPDs is similar to the assessment and verification system 3+ designed for environmental data. As with EPDs, the manufacturer is responsible for gathering data and assessing the environmental impacts, while the verifier validates the accuracy of the calculations and methods used.

How can One Click LCA help you comply with CPR requirements?

One Click LCA fully supports CPR requirements and provide manufacturers a continuity of use across EPDs and CPR requirements. One Click LCA's EPD Generator tool offers an end-to-end solution for manufacturers who need to create environmental product declarations (EPDs) compliant with the EN 15804 standard, which aligns with CPR requirements. With this tool, users can perform unlimited life-cycle assessments (LCAs) and create EPDs at scale for any product category. 

How to prepare for the other aspects of the CPR and DoPC 

While the CPR requirements are not yet in force, and are expected to enter in force in phases between 2026 and 2030,  this is a summary of what you need to prepare for:

1. Find out which harmonized technical specifications or European Assessment Documents apply to your product categories. The current documents are available from the EU under this link. To find out when the revised version is expected, the best visibility is usually at your industry’s trade body, which represents your industry in the standardisation process at CEN.
2. The revised rules will also define which level of assessment and verification system needs to be applied — from full verification by a Notified Body to self-declaration. The level is determined by the assessment of risk and complexity related to the products, including the impact on building safety.
3. Calculate environmental sustainability performance. You need to get your data ready for environmental impact assessment and complete the assessment. One Click LCA can help you create these — more on this in the above chapter.
4. Compile technical documentation in line with the revised rules. The details for your product are defined in the new harmonised technical specification.
5. Prepare general product information, instructions for use, and safety information in line with the CPR requirements. 
6. Prepare your Declaration of Performance and Conformity (DoPC) in line with the CPR requirements.
7. Affix CE marking on your product.
8. Create a Digital Product Passport for your product. This requirement comes only in force 18 months after the relevant secondary regulation has been enacted.

Allowed simplifications under the CPR

1. Where authorised by delegated acts of the European Union, generic values may be provided that can be used without testing or calculation for defined products.
2. When a product is a system assembled from components tested by the providers, the performance can be declared based on component data.
3. When a product corresponds to a product type made and tested by another manufacturer who allows the reuse of test results, they can be used.
4. Microenterprises, whose products are covered by the assessment and verification system 3, can replace type testing and calculation with equivalent data.