EPD vs CPR: towards the end of national environmental product declarations?
New Construction Products Regulation (CPR 2024/3110): key points for 2025–2029
The entry into force of the new Construction Products Regulation (CPR 2024/3110) is reshuffling the cards in the European regulatory landscape. At the heart of the debate lies a sensitive question: l will European programme operators have to abandon their environmental declarations (known as FDES in France, a B-EPD in Belgium, an EPD IBU in Germany, etc.)? CPR does not abolish EPD, but it radically transforms its role. They will no longer serve as an autonomous source of information and will gradually become a national version of data , now fully harmonised at the European level, generated under the CPR. These new declarations will be called DoPCs (Declarations of Performance and Conformity).
A completely restructured regulatory framework
CPR 2024/3110, which came into force in January 2025 and will apply from January 2026, reorganises the entire technical framework for environmental declarations. DoPCs can only function when backed by a set of harmonised (by product family) and revised standards. The following image illustrates this new approach: essential characteristics, product requirements and general information are now organised into a coherent system that is strictly aligned with European legislation (via harmonised standards).
Full harmonisation of environmental data
The major change concerns environmental data. Until now, manufacturers often had to produce several EPDs for each country: an FDES for France, a B-EPD for Belgium, an EPD IBU according to a German programme, for example. This fragmentation is disappearing, as the CPR requires that all harmonised standards per product family systematically incorporate the indicators of EN 15804 , both for LCA indicators and additional indicators. From now on, a single set of environmental data will be produced for each product. This set will be included in the CE marking, the Digital Product Passport (DPP) and used in national regulations. This unification will gradually replace all national programs, which constitutes a real paradigm shift for the sector.
To understand how these developments are taking shape, we can look at the first product families already involved in the process.
TIP and GLA: the two ‘fast track’ families leading the way
Two product families are particularly advanced in the process: insulation products (TIP – Thermal Insulation Products) and flat and profiled glass (GLA, Glass Products). These two categories have completed Milestone I, are in Milestone III (CPR acquis process- image below) and already have dates for their standardisation and adoption requests (2026–2029). Glass, in particular, already has pre-identified product requirements that will be formalised by a delegated act. Insulation and glass manufacturers will therefore be the first to declare a single European environmental data set, which can be used everywhere and integrated into CE and DPP marking (via DoPCs).
WeLOOP is actively involved in this European transition as a member of CEN/TC 350, and more specifically of WG3 dedicated to Life Cycle Assessment methods, while already contributing to technical work via CEN/TC 88 on insulation products (TIC).
The 34 product families concerned: a systemic reform
Beyond these two examples, the reform applies to 34 product families, covering the entire construction sector: concrete, steel, masonry, wood, glass, insulation, membranes, plaster, sanitary appliances, adhesives, geotextiles, cables, etc. This list demonstrates a systemic transformation. Each of these families will gradually follow the same path: CPR Acquis: product definition, requirements drafting, standardisation, mandatory adoption. For all of them, the LCA data will be identical at the European level. National FDES, DEP, and EPDs will then be presented in different formats with the same European value, usable in building LCA (via BIM). This transition does not only concern a few products: it affects the entire European construction products market.
Towards the end of national declarations? A gradual but irreversible transformation
The DoPC does not abolish EPD, but removes the possibility of producing different data across countries. Member States will have to rely on the single European data integrated into the CE marking and DPP. Ultimately, the CPR 2024/3110 reform marks the end of national environmental declarations as independent systems. It does not mean the disappearance of EPD at the national level, but the end of their methodological autonomy.
The real revolution of the CPR is therefore not technical, but systemic: it puts an end to 25 years of fragmentation by imposing a single model of environmental transparency for all construction products in Europe.
