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If you manufacture or sell construction products in the EU, your Declaration of Performance is about to get a new requirement: proof of environmental performance. The revised Construction Products Regulation (CPR) now expects manufacturers to back their products with life cycle assessment (LCA) data and, increasingly, a full Environmental Product Declaration (EPD) — not as a marketing extra, but as a condition for placing products on the market.
What changed under the new Construction Products Regulation
Regulation (EU) 2024/3110 replaced the 2011 Construction Products Regulation, entered into force in January 2025, and became applicable from 8 January 2026. It renames the old Declaration of Performance the Declaration of Performance and Conformity (DoPC) and — for the first time — requires that document to cover environmental and safety characteristics alongside technical performance, not just technical performance on its own.
Why LCA and EPD data are now part of compliance
The new rules require manufacturers to back any environmental or climate claim with quantifiable, life-cycle-based evidence, aligned with EN 15804 — the same core standard that underpins Environmental Product Declarations. In practice, that means the LCA methodology and reporting format used to build an EPD is becoming the accepted way to satisfy the CPR's environmental disclosure requirements. An EPD itself doesn't replace your CE marking or DoPC, but it is fast becoming the standard evidence base behind both.
The Digital Product Passport: where this data has to live
Alongside the DoPC, the CPR introduces a Digital Product Passport for construction products — a structured, digital record of a product's performance, environmental profile, and circularity data that follows it through the supply chain. LCA and EPD outputs are exactly the kind of data the passport is built to carry, so getting your environmental data into the right format now avoids reworking it later.
Who needs to act, and when
The obligations don't land on every product family on the same day. Harmonised technical specifications are being phased in product family by product family through 2032, so the exact deadline depends on what you manufacture. What doesn't change is the direction: if you place construction products on the EU market, you'll need life-cycle environmental data in a recognized format, and the earlier you start collecting it, the less disruptive the transition.
What manufacturers need to prepare
Getting ahead of the requirement means building three things:
- A product-level life cycle assessment (LCA) covering the relevant life cycle stages under EN 15804
- An Environmental Product Declaration (EPD) that turns that LCA into a verified, standardized document
- A process for keeping both current as products, materials, or suppliers change — since a one-off EPD goes stale fast
How Sustainly helps you get compliant
Building an LCA and EPD from scratch means navigating EN 15804 methodology, sourcing background data, and going through third-party verification — a heavy lift for teams that don't do this daily. Sustainly builds the life cycle assessment, produces the EPD, and keeps both aligned with the Construction Products Regulation as the rules phase in, so your Declaration of Performance and Conformity — and your Digital Product Passport data — are ready before your customers or auditors ask for them. If your products are heading toward these requirements, now is the time to start the data work, not after the deadline for your product family lands.