New European CPR: How Window Manufacturers Can Prepare for the Transition from EPDs to Future Environmental Declarations
The entry into force of the Construction Products Regulation (EU) 2024/3110 (CPR) marks a new milestone for window and door manufacturers. In this context, the European Commission is preparing new Product Category Rules (c-PCRs) that will govern future environmental declarations and their gradual integration into the Declaration of Performance and Conformity (DoPC).
The draft standardisation request published in January 2026 already outlines the main directions of this transition. Although the detailed work still has to be carried out by CEN, it already points towards greater harmonisation of Life Cycle Assessment (LCA) methodologies, improved environmental data quality, and compatibility with the future Digital Product Passport.
For window manufacturers, this evolution goes far beyond a simple regulatory update. It has the potential to transform the way EPDs are developed, maintained, and updated by enabling more parametric and automated approaches. This article explores the key changes expected under the future c-PCRs and explains why environmental configurators are already becoming a strategic solution for anticipating the upcoming CPR requirements.
What the European Commission Is Already Planning
The draft standardisation request published by the European Commission services proposes several requirements that, if retained in the final adopted version, will shape the future c-PCRs. According to the current draft, the future c-PCRs are expected, in particular, to:
This last requirement is likely to represent the most significant change.
The End of “Static” EPDs?
Today, most published EPDs correspond to a limited number of representative dimensions. This approach is effective as long as dimensional variations remain limited. However, windows are highly parametric products.
The draft standardisation request explicitly requires the future c-PCR to provide calculation methods that enable the extrapolation of environmental performance to products of different dimensions.
Although this methodology has not yet been defined, the message sent to the market is clear: the future rules will need to enable a more parametric assessment of environmental performance, particularly based on product dimensions.
Configurators Become a Natural Solution
For several years now, some manufacturers have already anticipated this change.
Environmental configurators already make it possible to automatically recalculate the environmental impacts of a window based on selected key parameters.
In other words, they already provide a practical solution to one of the objectives explicitly pursued by the draft c-PCR: calculating the environmental performance of products with different dimensions.
The objective is no longer simply to produce an EPD, but to have a system capable of generating reliable declarations across an entire product range.
Manufacturers That Anticipate This Change Will Have a Competitive Advantage
Manufacturers will need to address several market developments simultaneously:
Marketed product variants
Product customization
Regulatory updates
Growing customer demand for environmental data
In this context, manually maintaining dozens—or even hundreds—of EPDs will quickly become unmanageable.
Configurators enable manufacturers to:
They also provide a solid foundation for meeting future product data digitalisation requirements.
The future c-PCRs are not solely about extrapolation.
Dimensional extrapolation is currently attracting significant attention. However, it represents only one part of the changes ahead. The future work of CEN will also need to harmonise:
More harmonised life cycle scenarios
Calculation rules should be further harmonised across Europe, particularly for transport, installation, use and end-of-life scenarios. However, additional requirements specific to national or voluntary programmes may still remain.
Better justification of the service life
Manufacturers will need to document much more precisely the assumptions used to justify the declared service life of their products.
Common modelling rules
The future c-PCRs are expected to provide more detailed guidance on:
- supplier data;
- system boundaries;
- allocation rules;
- generic data;
- optional components;
- integrated accessories (shutters, solar shading devices, ventilation devices, etc.).
Better digital interoperability
The information contained in future declarations will need to be structured in interoperable, human-readable and machine-readable formats to ensure compatibility with the future Construction Digital Product Passport for construction products.
Why act now?
Under the current draft timeline, the main c-PCRs are expected to be adopted by CEN in 2028, ahead of the new harmonised standards planned for 2029. However, these dates remain subject to change.
That may still seem a long way off.
However, developing an environmental configurator involves far more than simply creating a software tool. It requires structuring technical data, developing LCA models for the different product ranges, defining calculation rules, carrying out validation phases, and coordinating with verification bodies.
At WeLOOP, an environmental configurator project is typically completed within 4 to 6 months, thanks to our proven methodology and expertise in RE2020 requirements and EPD programmes. Across the market, however, similar projects may take more than a year to develop, particularly when product data must be completely restructured or the calculation rules need to be developed from scratch.
Manufacturers that already have a parametric configurator in place will benefit from a structured foundation when the future c-PCRs are published. Depending on the scope of the changes ultimately adopted, they will be able to update their data, LCA models and calculation rules without necessarily having to rebuild their entire EPD generation process from scratch. This forward-looking approach can deliver significant benefits in terms of time, costs and business continuity.
Our vision at WeLOOP
At WeLOOP, we believe that the future c-PCRs will mark a major shift in the way EPDs for windows and doors are produced. Our approach is to prepare for this transition today by developing configurators that comply with current requirements while being designed to easily accommodate future regulatory changes.
Several configurators developed by WeLOOP are already being used to support RE2020 compliance and automate the generation of environmental declarations while ensuring their technical consistency. The transition to the future c-PCRs will involve far more than a simple documentation update: it will require tools capable of evolving alongside the new European rules.
Get ready today for the future Digital Product Passports (DPPs)
The new Construction Products Regulation (CPR) signals a fundamental shift in the environmental assessment of windows and doors. While many technical details still need to be defined by CEN, one trend is already clear: environmental declarations will become more harmonised, more digital, more configurable and subject to stricter traceability requirements.
For manufacturers, the question is no longer whether their methods will need to evolve, but how to prepare for this change. Environmental configurators are already emerging as one of the most effective ways to anticipate this transition, ensure regulatory compliance and continue meeting market expectations with speed and confidence.
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