TL;DR: What this CPR guide covers
- The Construction Products Regulation (CPR) sets harmonized rules for construction products sold in the EU. It applies to any product intended for permanent use in buildings or infrastructure – whether made inside or outside the EU.
- The updated CPR regulation introduces mandatory environmental reporting, digital documentation and broader CE marking requirements – with the first obligations beginning to apply from January 2026 for product groups covered by updated harmonized standards and implementing acts.
- The CPR is closely aligned with ESPR, EPBD and CSRD, meaning product-level data must be ready to feed into digital product passports and building-level carbon reporting.
- To comply with CPR regulation, manufacturers need to identify their product family, collect reliable data, digitize declarations, engage suppliers and build reusable product models – not just one-off EPDs.
- Ecochain helps manufacturers create high-quality product footprint models, generate EPDs at scale and prepare data for CE marking, DPPs and tenders – backed by in-house LCA experts.
Construction Products Regulation 2024 – why it matters now for manufacturers
The European construction industry is entering a new era of digital and sustainable transformation.
If you manufacture construction products for the EU market, Construction Products Regulation (CPR) compliance is no longer just about CE marking, product performance and safety. The new CPR framework brings sustainability reporting, stronger enforcement, and the foundation for digital documentation like the Digital Product Passport.
The updated Construction Products Regulation (Regulation 2024/3110) goes far beyond the 2011 version. It brings stricter enforcement, clearer market rules and new sustainability data requirements that impact your declarations, your product documentation and your go-to-market readiness across the EU.
In short: To access the EU construction market, manufacturers now need to meet a new set of CPR requirements – applicable from January 2026 onward.
And for many teams, the biggest question right now is: What exactly do we need to do to stay compliant with CPR, CE marking, and the new sustainability requirements?
This guide breaks it down. We’ll cover what CPR is, how it’s changing, what products are affected, how to comply and how to transform compliance obligations into competitive advantage.
What is the Construction Products Regulation (CPR)?
The Construction Products Regulation – often referred to as CPR – is the EU’s core legislation for placing construction products on the market.
It ensures that products used in buildings and infrastructure across the EU meet a common set of rules for performance, safety and now, sustainability.
The CPR was introduced in 2011 (Regulation EU No 305/2011) to replace the old Construction Products Directive. Its goal was to remove technical barriers in the single market and harmonize how products are assessed, declared and compared.
The key mechanism: Manufacturers declare how their product performs for covered characteristics using the Declaration of Performance (DoP). This links their product to relevant harmonized technical specifications – typically European standards (hENs) – and enables CE marking.
With CPR compliance, you can:
- Affix the CE mark for products covered by harmonized rules.
- Place those products on the EU/EEA market without repeating separate national type‑testing for the same characteristics.
- Make your product’s declared performance transparent and comparable for specifiers and regulators.
But here’s what’s changing: The revised CPR (Regulation 2024/3110) keeps the core framework but significantly expands its scope. It brings:
- Stricter rules on documentation, including more use of digital formats
- Mandatory disclosure of sustainability‑related performance indicators, phased in over time
- A stronger focus on life‑cycle‑based environmental data
- An explicit legal basis for Digital Product Passports (DPPs) for construction products, but full requirements will be defined later through delegated acts expected after 2026
For manufacturers, CPR compliance is no longer a one‑time exercise focused only on technical specs, but an ongoing requirement that ties together product design, data management, production and reporting.
What products and manufacturers does the CPR apply to?
One of the most common questions we hear is: Does the CPR apply to our products?
If you manufacture products that are intended to be permanently incorporated into buildings or civil engineering works in the EU – then the answer is usually yes.
The CPR covers a wide range of construction products, including those used in:
- Buildings (residential, commercial, industrial)
- Infrastructure works (roads, bridges, tunnels, etc.)
- Structural or fire protection systems
- Insulation and energy performance layers
Regulation (EU) 2024/3110 organizes products into 36 product families – ranging from concrete and steel components to internal finishes and technical building systems. These families help determine which harmonized standards (hEN), European Assessment Documents and conformity routes (for example, hEN or European Technical Assessments, ETA) apply in your case.
Examples of product types covered under CPR:
- Concrete, cement and mortar products
- Structural metallic components and assemblies
- Thermal insulation materials
- Floor, wall and ceiling finishes
- Doors, windows and shutters
- Fire safety products such as fire‑resisting doors, fire stopping and smoke control components.
Some products are outside the CPR’s scope or are primarily regulated under other EU legislation. For example, lifts and certain machinery are covered mainly by the Lifts Directive and Machinery Regulation, and bespoke or one‑off heritage components may remain outside harmonized CPR rules if they are not placed on the market as standardized products. In situations where no harmonized standard exists, ETAs can still provide a valid route to demonstrate performance and support CE marking.
If your products fall into more than one family – or include both standardized and custom components – you may need to declare multiple performance characteristics or use different conformity routes depending on the intended application.
What are the core objectives of the Construction Products Regulation?
At its core, the Construction Products Regulation is about making the internal EU market for construction products work better – by ensuring that performance data is reliable, comparable and consistent across borders.
The revised CPR does not change this fundamental purpose, but it expands the scope to cover environmental performance and digital traceability more explicitly.
Here’s what CPR regulation sets out to achieve:
Harmonization of standards – CPR creates a ‘common technical language’ for construction products across EU countries. This means, for example, that a window tested against a harmonized standard in Germany can be placed on the market in France under the same set of essential characteristics, as long as it carries the CE mark and has a Declaration of Performance (DoP) aligned to the relevant harmonized specifications.
Product performance for basic requirements – CPR itself does not certify ‘safety’ in general, but it requires that construction products declare their performance for characteristics linked to the basic requirements for construction works. These include, among others:
- Mechanical resistance and stability
- Safety in case of fire (including reaction to and resistance to fire where relevant)
- Hygiene, health and environmental aspects
- Safety and accessibility in use
- Protection against noise
- Energy economy and heat retention
- Sustainable use of natural resources
These performance characteristics must be assessed and declared using standardized methods (testing, calculation or descriptive approaches set out in harmonized technical specifications).
Market transparency: Declarations of Performance (DoPs) make it easier for customers, specifiers and authorities to understand and compare how products perform for the declared characteristics. The idea is that clearer information supports better design and procurement decisions, fewer disputes, and more trust in what is being sold and installed.
Environmental accountability and digitalization: With the revised CPR, sustainability is no longer just a voluntary add‑on. The new rules introduce mandatory reporting of climate‑ and environment‑related performance indicators, based on life‑cycle information and aligned with standards used for Environmental Product Declarations (EPDs), phased in between 2026 and 2032. Over time, this environmental performance data will be increasingly available in digital formats and Digital Product Passports, making it easier to reuse the same data across CE marking, green building schemes and regulatory reporting.
How CPR connects to other EU sustainability regulations
The revised CPR (Regulation (EU) 2024/3110) is deeply interconnected with other EU sustainability regulations – especially those pushing for carbon transparency, resource efficiency and digital documentation in product supply chains.
1. CPR and Eco-design for Sustainable Products Regulation (ESPR)
CPR is designed to align with the ESPR – the EU’s horizontal framework to make sustainable product design the default across industries. For construction products, this means:
- Greater emphasis on durability, reparability, recyclability and minimization of life‑cycle environmental impacts
- Mandatory disclosure of life‑cycle environmental impacts, phased in over time
- A foundation for DPPs – the key transparency mechanism under both regulations
If your products are covered by CPR, ESPR requirements will likely apply as well (with CPR taking precedence where there’s overlap).
2. CPR and Energy Performance of Buildings Directive (EPBD)
The revised EPBD introduces building-level carbon metrics – including operational energy and embodied carbon. That second part? It depends heavily on product‑level footprint data.
CPR creates the legal basis for including construction product data (like EPDs and GWP) into building-level performance assessments.
If you supply products for EU buildings, your declared CPR impact values will directly influence a project’s ability to meet EPBD targets – and win tenders.
3. CPR and Corporate Sustainability Reporting Directive (CSRD)
While CPR is product‑focused and CSRD is company‑focused, there’s a clear practical link.
CSRD reporting often requires product‑level data (like Scope 3 emissions, embodied carbon, recyclability) as part of broader ESG disclosures.
The clearer and more verifiable your CPR documentation and environmental data are, the easier it becomes to plug them into CSRD reporting.
In practice, you won’t be managing ‘CPR data’ vs ‘EPBD data’ vs ‘ESPR data’ separately. You’ll need one reliable product data foundation and LCA automation software like Ecochain that supports all of them.
What the 2024 CPR revision brings and why it matters now
In November 2024, the European Parliament and Council adopted a major revision of the Construction Products Regulation (Regulation (EU) 2024/3110).
This is the most significant update since CPR was introduced in 2011 – and it fundamentally changes what compliance looks like for manufacturers.
Key dates:
- 18 December 2024 – Regulation published in the EU Official Journal
- 7 January 2025 – New CPR enters into force
- One year later, from 8 January 2026 – Most rules start to apply
Why is this important now? The updated CPR expands beyond traditional technical performance to bring:
- Mandatory environmental impact reporting (phased in)
- Legal basis for Digital Product Passports
- Stronger enforcement and market surveillance
- New digital documentation formats (DoPs, DoPCs – Declaration of Performance and Conformity, CPR instrument that will increasingly replace standalone EPD-style reporting)
- Alignment with ESPR, EPBD and other green regulations
For manufacturers inside and outside the EU, complying with these rules is the price of admission to the world’s largest construction market.
What key changes did the latest 2024 CPR update bring?
The revised CPR introduces several major updates, especially around environmental data, digitalization and performance declarations.
Here’s what you need to know:
- Digital Product Passports (DPPs): CPR establishes the legal basis for DPPs for construction products, which will contain technical specifications, performance data, installation/maintenance instructions, end‑of‑life information and environmental indicators. These will be machine‑readable and compatible with Building Information Modeling (BIM) systems and ESPR requirements. However, the detailed format and obligations will be set by delegated acts (expected after 2026), with mandatory use phased in (likely voluntary initially, then required 18 months after the delegated act). PDF datasheets alone will no longer suffice in the long term
- Enhanced declarations and CE marking: The DoP and DoPC will include environmental indicators alongside technical performance. The CE mark signals conformity for all declared characteristics – including those related to sustainability – but you’ll need to declare and document carbon impact (and eventually circularity) using standardized methods.
- Mandatory environmental reporting: From 2026, GWP reporting will begin for product families once the relevant harmonized standards and delegated/implementing acts are adopted. Additional indicators (e.g. acidification, eutrophication, resource depletion) will phase in through 2032.
- Digitalization of declarations: DoPs and DoPCs must be made available electronically in a standardized, machine‑readable format on the manufacturer’s website. They will integrate with the future DPP system – no more just static PDFs in a folder.
- Phased environmental indicators:
- 8 January 2026 – GWP declarations mandatory for products covered by updated harmonized standards/implementing acts.
- 9 January 2030 – Core environmental indicators (ozone depletion, acidification, eutrophication, etc.) become mandatory.
- 9 January 2032 – Full set of life‑cycle indicators required.
What does this mean for manufacturers? The way you manage product data is changing – fast. You’ll need new systems, better data access and scalable processes to stay compliant.
What’s the difference between CPR 2011 and the new CPR 2024?
The core idea of the Construction Products Regulation hasn’t changed: Products must declare their performance against essential requirements using harmonized technical specifications. But the 2024 revision transforms how manufacturers must do this, especially around sustainability, digitalization and traceability.
Here’s what’s different:
| CPR 2011 | CPR 2024 |
| Focused on technical performance (e.g. strength, fire resistance) | Adds mandatory environmental performance declarations (e.g. GWP/carbon footprint, circularity indicators) phased in from 2026–2032 |
| Paper‑based or PDF documentation acceptable | Requires electronic, machine‑readable documentation; legal basis for full Digital Product Passports (DPPs) via delegated acts |
| CE mark based on declared technical characteristics only | CE mark covers all declared characteristics, including environmental ones once required by harmonized specs |
| Environmental data optional or market‑driven | Environmental data mandatory for relevant characteristics, phased in from 2026 to 2032 |
| DoPs in manufacturer’s choice of format | Standardized electronic DoPs & new DoPC required, integrated with digital systems |
| Limited formal alignment with sustainability regs | Explicitly aligned with ESPR (DPPs, ecodesign), EPBD (building carbon), CSRD data needs |
In short, CPR 2024 turns environmental performance into a legal obligation – not just a customer request. It also raises the bar for how data is managed, shared and verified across the value chain.
CPR timeline and key dates: When does the new CPR apply?
The revised Construction Products Regulation (Regulation 2024/3110) entered into force in early 2025. Its requirements are being phased in over several years – starting with climate impact reporting in 2026, and expanding to full life cycle indicators by 2032 – to give manufacturers time to adapt their systems, processes and data.
The table below highlights key milestones you need to know:
| Date | Milestone |
| 7 January 2025 | CPR 2024 enters into force |
| 8 January 2026 | CPR 2024 becomes applicable; GWP (Global Warming Potential) declarations required for selected products; new Market Surveillance rules replace CPR 2011 chapter |
| 31 December 2026 | Impact assessment for Green Public Procurement to be completed |
| 8 December 2026 | Member States must notify the European Commission of their national penalties for non-compliance |
| 9 January 2030 | Mandatory declaration of all core environmental indicators |
| 9 January 2031 | Existing EADs (European Assessment Documents) under CPR 2011 are no longer valid |
| 9 January 2032 | Full declaration of all life cycle environmental indicators becomes mandatory |

Figure 1 – CPR 2024 implementation timeline and key compliance milestones (2025–2032) | Source: European Commission
You don’t need to solve everything in one quarter – but CPR 2024 is already applicable. If you haven’t started building the right data foundation yet, now is the time.
CPR compliance for non‑EU manufacturers: What you need to know
If you manufacture outside of the EU but want to place construction products on the EU market, the Construction Products Regulation applies to you in exactly the same way. There is no separate CPR route or exemption for non‑EU manufacturers.
That means you need to:
- Assess your products against the correct harmonized technical specifications (typically hENs or ETAs)
- Provide a valid Declaration of Performance (DoP) for the relevant essential characteristics
- Affix the CE mark before your products are placed on the EU market
- Declare environmental performance indicators (like GWP, phased in from 2026) using the required methods
- Prepare for digital documentation, including eventual Digital Product Passports
Important: The CE mark and DoP must be affixed by the manufacturer (you, as the non‑EU producer). EU importers or distributors cannot do this on your behalf. If you don’t provide the required documentation, EU importers and customers cannot legally place your product on the market – even if the product itself performs well.
9 steps to prepare and comply with the new CPR requirements (2026 and beyond)
Whether you’re just getting started or already adapting to CPR 2024, these nine steps help you strengthen your data, documentation and cross-team alignment – so you’re ready not just for what’s required now, but what’s coming next.
1. Identify your product family – Map your portfolio to the correct CPR product family. This determines which harmonized standards or technical assessments apply – and what documentation is needed.
2. Collect performance and environmental data – You’ll need both technical performance data (e.g. structural strength, fire safety, acoustic properties) and environmental impact data (e.g. Global Warming Potential, energy and resource use). An accessible LCA automation software like Ecochain helps you generate environmental impact data for your products reliably and repeatedly – without having to build it from scratch each time.
3. Create or update your declarations – Declarations of Performance (DoP) and Conformity (DoPC) are increasingly expected in digital formats. CPR makes environmental performance disclosure mandatory, and EN 15804-based Environmental Product Declarations (EPDs) remain the most practical way to generate those indicators.
4. Build a reusable LCA data foundation – Instead of creating one-off LCAs or isolated EPDs, build a connected model that you can reuse across product variants, factories and regions. Ecochain helps you scale product impact reporting while staying aligned with CPR, ESPR and upcoming DPP formats.
Continue reading: Choosing the right EPD software for construction manufacturers: 7 key factors to consider
5. Start digitizing your documentation – Digital Product Passports aren’t mandatory for most categories yet – but the groundwork begins now. Start moving your technical and environmental declarations into structured, machine-readable formats with software solutions like Ecochain. This reduces rework later and positions you for digital compliance when it becomes required.
6. Engage your supply chain early – Lifecycle data also depends on what’s happening upstream. Set up clear data-sharing agreements with suppliers, define system boundaries, and align on scope expectations – especially for complex or multi-site value chains.
7. Work with accredited experts and bodies – Ensure your declarations and data are high-quality and verifiable. Work with accredited labs, notified bodies, and experienced LCA partners to validate methods, avoid errors and support third-party review.
8. Align your organization – CPR 2024 touches product, R&D, regulatory, sustainability, IT, marketing and sales. Bring leadership into the conversation early and make sure they’re aware of what’s changing – and why the work (and budget) can’t be postponed any longer. Discuss with different functions at your company how these requirements affect operations, timelines and customer-facing documentation.
9. Monitor regulatory updates – CPR, ESPR and EPBD are evolving. Harmonized standards are being revised, and additional indicators will be phased in over time. Set up reliable monitoring through official sources or industry groups to stay aligned with what’s coming next.
How Ecochain helps you turn CPR compliance into a business advantage
Staying compliant with the revised CPR is only part of the job. The bigger challenge – and opportunity – is building a reliable data foundation that scales across your portfolio and supports your business long-term. That’s where Ecochain comes in.
Construction products manufacturers use Ecochain to build accurate, reusable product footprint models that feed into declarations, EPDs, and help them get ready for Digital Product Passports.
Instead of starting from scratch for each request, they reuse verified data across products, sites and stakeholders – whether it’s for CE marking, tender submissions or ESPR alignment.
Ecochain supports your entire workflow:
- Building high-quality, product-specific footprint models using both primary and secondary data
- Creating EPDs aligned with EN15804 and regional formats (MRPI, NMD, EPD International, IBU)
- Publishing product impact outputs at scale – without paying to verify each one individually
- Preparing machine-readable declarations for DPP integration when the time comes
- Supporting with expert input for data quality, verification and regional guidance (available in Dutch, German, and English)
Whether you manage ten products or hundreds or thousands, our software and services help you move faster, avoid duplication, and stay compliant – with defensible data that holds up under scrutiny.
Want to see how we help manufacturers stay compliant – and win more business with credible product impact data? Talk to our team.