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How to prepare your company for Construction Products Regulation (CPR): A guide to communicate what’s changing

Contents

Team meeting construction products regulation discussion | Ecochain

Summary (TL;DR) of what this post is about

  • Getting internal buy-in is the most common CPR regulation readiness challenge sustainability managers face. This post is a step-by-step guide to communicating CPR changes internally, covering everything from the first leadership conversation to cross-functional team alignment. These insights are drawn from our Behind the Product Impact video series.
  • When communicating to your management the need to comply with CPR, the revenue framing usually works where the regulatory framing doesn’t. Non-compliance with EU CPR regulation often means lost tender access and lost customers. 
  • CPR product data requirements in most cases go well beyond what most manufacturers currently have structured. EN 15804 Environmental Product Declarations, Life Cycle Assessment (LCA) foundations, and supplier-specific inputs all need to be in place. Getting there is a company-wide effort, not a solo sustainability project.

Why getting internal buy-in on CPR regulation is harder than it sounds

Here’s a scenario we’ve heard all too often: you’ve spent the last few months getting up to speed on the Construction Products Regulation (CPR). You understand the timeline. You know GWP declarations are mandatory now, more impact categories are coming, and that LCAs aren’t optional. You’ve even started thinking about which products to prioritize.

Then you walk into a meeting with leadership and try to explain it.

Halfway through, someone asks if this is the same as Corporate Sustainability Reporting Directive (CSRD). Another person says they thought CPR was “being handled by the compliance team.” By the end of the meeting, the conversation has drifted. The main thing the room agrees on is that you’ll revisit it next quarter.

Sound familiar? You’re not the only one.

Getting internal traction on CPR is one of the most common challenges sustainability and product managers raise in conversations with us. The regulation is complex enough that translating it into plain business language takes real effort. Once you do, it can still feel abstract to people who haven’t been following it.

In a recent episode of our Behind the Product Impact video series, Dr. Pratik Gholkar, our Sustainability Strategist, and Emma Thunnissen, Sustainability Expert at Ecochain, dig into this exact challenge. This article pulls the key takeaways from that conversation into a practical communication guide for how best to frame Construction Products Regulation (and upcoming Digital Product Passports or DPPs) internally.

CPR in plain language: What to say and how to say it

Before getting into the communication side, we’ll start with a quick summary of CPR. We use plain language that you can reuse in internal slides or emails.

What changed: The Construction Products Regulation isn’t brand new. The 2024 update (Regulation EU 2024/3110) significantly revised the framework that’s been in place since 2011. It was published in the EU Official Journal in December 2024, entered into force in January 2025, and became applicable from 8 January 2026. Learn more about the 2024 CPR amendment.

What the revised CPR regulation requires, and when:

  • From 8 January 2026: Global warming potential (GWP) declarations are mandatory for construction products covered by updated harmonized standards
  • From 2030: Additional core environmental indicators become mandatory (acidification, eutrophication, ozone depletion, and others)
  • From 2032: Full set of life-cycle environmental indicators required

What this actually means: Every declared GWP value needs to come from a life cycle assessment (LCA). A supplier estimate or a product data sheet won’t satisfy the requirement. The methodology matters as much as the number.

Where Environmental Product Declarations (EPDs) fit in: A high-quality, third-party verified EPD aligned with EN 15804+A2 is the most practical way to meet CPR’s environmental declaration requirements. It also feeds directly into the Declaration of Performance and Conformity (DoPC) mandated by CPR. Learn more about how CPR is driving EPD demand.

What’s coming next – Digital Product Passports (DPPs): Digital Product Passports are the next layer. CPR establishes the legal basis for DPPs for construction products, which will carry technical specs, environmental data, and lifecycle information in machine-readable formats. The detailed format and obligations are still being defined through delegated acts expected after 2026, but the data you build for CPR feeds directly into them. One foundation, multiple uses.

As Dr. Pratik Gholkar, our Sustainability Strategist, puts it: “CPR is no longer a myth. It’s the reality. The sooner you accept it, the better you will get at it.

Continue reading: Construction Products Regulation (CPR) 2024–2032 guide: What manufacturers need to know

The revenue case: How to frame Construction Products Regulation for leadership

Start with what non-compliance actually costs the business if you want your leadership team to pay attention to CPR. Don’t start with the regulation. 

In conversations with manufacturers across the EU, Dr. Pratik Gholkar has seen an emerging pattern: “There is a gap between the implications of law and the direct revenue impacts. When the sustainability manager is clear enough to bridge that gap, I have seen most often higher management getting convinced and then they form a plan.”

Framing the CPR in terms of revenue works because it translates an abstract compliance deadline into something a CFO or commercial director immediately recognizes as their problem too.

Consider using this scenario with leadership

For example, you supply construction products to customers across multiple EU markets. Say you have €2–5M in annual revenue from key customers (e.g., distributors, contractors, developers) who are starting to require CPR-compliant documentation as part of their procurement process. If you can’t provide it, you don’t just risk getting a fine. You get dropped from their supplier list. The customers you’ve been supplying for years stop buying from you.

As Pratik frames it: “Imagine you sell your product in 50 different locations across the EU, and you are one of the key suppliers. But if you do not have the documents compliant for that product as per CPR, you’ll probably be dropped out of the suppliers list. Revenue impacts are way bigger than the fines.”

Phrasing you can use in internal conversations or slides:

  • “This CPR regulation isn’t just a legal box to tick. Without compliant product documentation, we risk being excluded from tenders and losing customers we already have – and that’s millions in revenue exposure, not just fines.”
  • “The fines we face if we’re not CPR-compliant are real, but they’re not the main exposure. The main exposure is the revenue we lose if we can’t document our products the way key customers are starting to require.”
  • “CPR is already applicable. Customers are asking for this documentation now and making procurement decisions based on it. They aren’t waiting for 2027.”

Beyond the sustainability team: Making Construction Products Regulation a company priority

One of the most important things to communicate early: CPR compliance doesn’t sit with one person or one team.

“Compliance to CPR is just not a one man’s job. It’s the company’s responsibility.” – Dr. Pratik Gholkar, Sustainability Strategist at Ecochain

This distinction matters practically, not just philosophically. Here’s how it tends to work – and where the friction usually shows up: 

  • Leadership and business owners: Responsible for setting the plan. This includes deciding which products to prioritize, allocating resources, and making CPR readiness a formal company objective.
  • Sustainability and LCA teams: Responsible for executing the plan. This involves collecting and structuring product data, running LCAs, generating EPDs, and managing the documentation.

If the leadership team shows up only to sign off on timelines but doesn’t reinforce priorities across the business, a sustainability manager often becomes the person trying to move a mountain alone. If they do it well, it looks like they own the whole thing. If they struggle, the company assumes “the sustainability team isn’t ready.” 

Framing CPR as a cross-functional topic from the start changes that dynamic.

In companies handling this well, you’ll see:

  • Product and R&D: Own the product data (e.g., BOMs, material specs, process details) that LCAs are built from.
  • Procurement and supply chain: Own and gather the supplier data, which is often one of the biggest gaps in LCA readiness. Ensure procurement is involved from the beginning so they can begin collecting the data.
  • Sales: Understand the commercial compliance pressure before anyone else does. They’re often closest to customer requests for EPDs and product documentation.
  • Operations: Own energy consumption, waste fractions, and production process data.
  • IT/data: Build the right data management systems. Having these systems in place is increasingly important as CPR moves toward digital declarations and eventually DPPs.

Phrasing you can use when bringing these teams into the conversation:

  • “This isn’t just a sustainability project. It touches product data, supplier relationships, and customer documentation. We’ll need everyone’s help to get this right.”
  • “We’re not asking one specific team to become LCA experts. What we do need is for each team to share the data they already own, and to understand why it matters for CPR.”
  • “Sales – have you had a customer ask for an EPD or environmental product data recently? This request is becoming more common. We need to make sure we can respond when they do.”
  • “Procurement – the data we need for CPR-compliant LCAs goes beyond the BOM; we need supplier-specific material and energy data. We’d really appreciate your help getting it into a structured format.”

Scoping your starting point to Construction Products Regulation: What to propose internally

Following leadership attention and cross-functional buy-in, you can start the conversation about scope. Scoping is a key, sometimes rate-limiting step, and many internal CPR discussions stall here. “Comply with CPR across our full portfolio” sounds like an enormous task, because it is.

“Start small. Start now. Identify your portfolio – which products require CPR compliance immediately? Because it might not be the case that your complete portfolio requires CPR compliance right now. Then among those products, identify which are your high-selling products. Start with those first.”– Dr. Pratik Gholkar, Sustainability Strategist at Ecochain

For internal communication, this translates into proposing a focused pilot rather than a full programme. Something like: “We’re proposing to start with these 3-5 products. Here’s why we chose them, and here’s what we need to make it happen.”

When selecting your pilot products, look for two things:

  • CPR scope timeline: Which product families are coming into scope soonest, based on their harmonized standard?
  • Commercial importance: Which products, if compliant, would make the most difference to tender outcomes or customer requests today?
Continue reading: Construction Products Regulation (CPR): 7 common questions every manufacturer asks

On the data side, one of the most consistent findings from working with manufacturers on CPR readiness is that companies often believe they have what they need. Most of the time, they have some of it – just not in a form that works for lifecycle analysis and product impact reporting.

As Pratik puts it, “Most often manufacturing companies have the data, but it is not structured to do LCA. You need the data in a proper structure.”

The gaps tend to show up in the same places across manufacturers:

  • Usually available: Bill of materials, some transport data from key suppliers.
  • Often missing or unstructured: Energy consumption per production stage, waste fractions in manufacturing, supplier-specific material inputs beyond the BOM.

Best practice for collecting Construction Products Regulation data internally

If you’re trying to kick off the data collection process internally, you could use the following slide format as a starting point to map what you have and what you need.

What we have:

  • Bill of materials (BOM) for priority products (materials, weights, units, annual volumes)
  • Some transport data from key suppliers

What we’re missing or need to structure:

  • Energy use per production stage (e.g. kWh, fuels, by line or process)
  • Waste fractions in manufacturing (types, quantities, and destinations)
  • Supplier-specific material data beyond the BOM (EPDs or LCAs, energy and waste data for key materials)

Why this matters:

  • Structured product data is what makes LCAs, EPDs, PCFs and other environmental reports we might need in the future repeatable instead of one-off projects.
  • Getting this right now means each new CPR milestone (e.g., EPDs, GWP in CE marking, portfolio coverage) becomes easier to absorb, not harder.

Phrasing you can use when starting the data conversation internally:

  • “We actually have a lot of the CPR-required data already. The challenge is that it’s spread across different systems and teams. The first step is mapping what we have, not collecting everything from scratch.”
  • “Data collection is where most CPR projects get delayed. If we start that conversation now, before we’re under deadline pressure, we have more room to do it properly.”
  • “We don’t need perfect data to start. Let’s start with organizing our data into a structured, documented format we can build on. We can get there incrementally.”
  • “The BOM is a starting point, but for a CPR-compliant LCA, we also need energy use per production stage and supplier-specific inputs. That’s where procurement and operations come in – and we can’t do this without them. “
Continue reading: The data you need for a Life Cycle Assessment (LCA)

Making the case for CPR regulation, LCA software and expert support

Most manufacturers bring in external LCA expertise at some point – and most also reach for dedicated LCA software to make the work manageable at scale.

This is something worth raising with your leadership and broader team early. For most manufacturers, the combination of the right software and expert support is the faster, more sustainable path to CPR compliance than trying to build everything from scratch internally.

Emma puts it plainly: “It’s not embarrassing or bad to ask for external help. Working with experts and building in-house knowledge at the same time is important – because you need to do it yourself in the end, and you often need to do it for your full portfolio. This isn’t a short-term thing.”

The goal isn’t to outsource CPR compliance. The goal is to build the internal knowledge and systems to handle it at scale. LCA automation software gives your team a structured environment to collect data, run calculations, and generate EPDs repeatably – without starting from zero each time. Expert support covers the parts that take the longest to get right: methodology, harmonized standard selection, and verification preparation. It’s worth framing it this way internally, especially when planning a budget around this.

LCAs and EPDs are genuinely complex. Getting the methodology right, understanding which harmonized standard applies to your product, and preparing for third-party verification are all challenging tasks. The right tools and guidance together shorten the learning curve and reduce the risk of rework later.

Phrasing you can use when making the case for external support:

  • “We want to build this capability in-house – we just need the right software to structure our data and expert guidance on the parts that take the longest to get right. This helps us get to the results faster and avoid costly rework.”
  • “Going it alone means we might build something that doesn’t hold up under verification – and then we’ll need to rebuild. The right LCA software vendor that also offers expert guidance is going to help us minimize that risk.” 
  • “CPR isn’t going away. The investment in getting this right now, with the right LCA software solution and expert support, pays off every time a new requirement arrives.”

Your CPR regulation communication checklist: Five moves to make this month

“Just start” is the best advice we can give you in your CPR journey. You don’t need a perfect plan to start the conversation. Starting with using the clear framing outlined in this blog is already a big step.

Follow these steps to get started:

  1. Prepare an overview of CPR and its connection to revenue for leadership: This can be a brief slideshow or a 2-page document. Stick to the basics. What does CPR require for your business to continue to sell without delays or fines? What’s the key timeline? What’s the revenue risk of not having compliant documentation when customers ask? Lead with the commercial exposure, not the regulatory detail.
  2. Map your data gaps – especially supplier data: In your cross-team session, focus on ‘who owns which data, and where are the biggest gaps?’ Supplier-specific material and energy data is usually the biggest bottleneck. Start that conversation with procurement early. 
  3. Run a short mapping session across key teams: Gather product, procurement, sales, and operations teams in a room. Focus on “who owns which piece of the data we need, and where does it live?” Avoid open-ended existential questions like: “How do we comply with CPR?”
  4. Propose 3-5 products to start with: Identify your highest-volume sellers in product categories likely to come into the CPR scope first. A focused pilot creates clear, tangible direction.
  5. Have an expert conversation: Get a realistic read on where you are, what your gaps are, and what your best next steps are for your specific products and product categories.

Good to keep in mind: If you already have EPDs, verify their quality now. Are they third-party verified? Approved by a recognized Program Operator? Calculated according to EN 15804+A2 (not the older +A1 standard)? If yes, you’re already off to the races when it comes to CPR compliance.

The companies best positioned for CPR compliance don’t wait until everything is clear. 

They’re the ones who get ahead of the task as soon as they can – starting the internal conversation early, narrowing the scope to something manageable, and building from there.

Ready to talk through your CPR starting point?

Watch the full Behind the Product Impact episode with Dr. Pratik Gholkar and Emma Thunnissen. They cover the revenue framing, the data readiness question, and what internal buy-in means in practice.

If you’d prefer a direct conversation about your CPR and product footprinting needs, get in touch with us. We’ve worked with hundreds of construction product manufacturers, and we know how to set you up for success.

Continue reading: Construction Products Regulation (CPR): 7 common questions every manufacturer asks

Frequently asked questions (FAQs)

How do I explain Construction Products Regulation compliance to leadership without losing their attention?

Explaining CPR compliance to leadership works best when you lead with revenue risk, not regulatory detail. Instead of walking through the regulation, show what non-compliance costs commercially: which customers are already asking for CPR-compliant documentation, what they represent in annual revenue, and what happens when you can’t provide it. The fine risk is real but secondary. The primary exposure is being dropped from supplier lists and losing tender access – and that framing lands with a CFO or commercial director immediately.

Which internal teams need to be involved in CPR compliance?

CPR compliance requires involvement from multiple internal teams, not just sustainability. Product and R&D often own the bill of materials and material specs that LCAs are built from. Procurement and supply chain own supplier data, which is often the biggest gap. Sales are usually the first to hear customer requests for EPDs and environmental documentation. Operations own energy consumption and waste data per production stage. Leadership sets priorities and allocates resources. Treating CPR as a sustainability team project almost always creates bottlenecks.

How do you scope a CPR compliance project internally when the full portfolio feels overwhelming?

Scoping a CPR compliance project starts with two filters: which product families are coming into scope soonest based on their harmonized standard, and which products matter most commercially right now. Starting with 3–5 priority products gives the project a clear, manageable shape – and makes it easier to get internal buy-in than proposing a full portfolio programme from the start.

What data do manufacturers typically already have for CPR-compliant LCAs, and what’s usually missing?

Most manufacturers already have a bill of materials and some transport data from key suppliers. What’s typically missing or unstructured is energy consumption per production stage, waste fractions in manufacturing, and supplier-specific material inputs beyond the BOM. The data gap is rarely about not having data at all – it’s about that data sitting across different systems and teams in formats that don’t work for lifecycle analysis.

Is CPR compliance for sustainability teams only?

No, compliance with Construction Products Regulation isn’t only relevant for sustainability teams. While sustainability and product teams are often responsible for executing the work (i.e., LCAs, EPDs, data collection), the planning decisions (i.e., which products to prioritize, what resources to allocate) need to be a company-level commitment. Getting leadership and cross-functional teams involved early eases the CPR process.

When should a manufacturer bring in external LCA support for CPR compliance?

Bringing in external LCA support – whether that’s LCA software, expert guidance, or both – makes sense for most manufacturers at the start of their first LCA or EPD project. The methodology, harmonized standard selection, and third-party verification preparation all have a steep learning curve. The right software structures your data and makes LCAs repeatable at scale. Expert guidance shortens the learning curve and reduces the risk of rework. The goal isn’t to outsource compliance permanently, but to build internal capability faster with the right tools and support alongside.

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