The mandatory declaration of environmental performance | Istituto Giordano

The mandatory declaration of environmental performance

The construction sector plays a key role in achieving the ambitious sustainability goals set by the European Union under the Green Deal, which aims for climate neutrality by 2050. Regulation (EU) 2024/3110, known as CPR-2024, has been revised precisely to align construction products with these new climate and circular economy targets.

Main objective: reducing impact and increasing efficiency

The overarching goal of the revision of CPR-2011 is to reduce the climate impact and increase the material efficiency of the entire construction product sector. While CPR-2011 already included limited consideration of environmental sustainability, the 2024 version is significantly broader and introduces:

Mandatory declarations of environmental performance.
Increased use of recycled materials.
Encouragement of product design for reuse and recycling.


Key obligations for manufacturers

For manufacturers of construction products covered by harmonised technical specifications developed under CPR-2024, several obligations must be met:


Mandatory declaration of environmental performance over the product lifecycle

Manufacturers will be required to declare the environmental lifecycle performance of their products according to a set of predetermined essential environmental characteristics. This declaration will be based on EN 15804 (or EN 50693 for heating-related products) and must be included in the Declaration of Performance and Conformity (DoPC).

The introduction of essential environmental characteristics will be phased in. From the application date of CPR-2024 (January 8, 2026), the DoPC must cover the characteristics listed in Annex II, points (a) to (d). This obligation will apply only to construction products covered by harmonised technical specifications developed under CPR-2024.

Performance data may be calculated using free software provided by the European Commission.

a) climate change impacts – total
b) climate change impacts – fossil fuels
c) climate change impacts – biogenic
d) climate change impacts – land use and land use change

Four years after the application date, characteristics from Section 2, points (e) to (m) of Annex II must also be included:

e) ozone layer depletion
f) acidification potential
g) freshwater eutrophication
h) marine eutrophication
i) terrestrial eutrophication
j) photochemical ozone formation
k) abiotic depletion – minerals, metals
l) abiotic depletion – fossil fuels
m) water consumption

Six years after the application date, characteristics from points (n) to (s) of Annex II must be added:

n) particulate matter
o) ionising radiation, human health
p) freshwater ecotoxicity
q) human toxicity, carcinogenic effects
r) human toxicity, non-carcinogenic effects
s) impacts related to land use
 

Other environmental requirements

Beyond essential characteristics, additional environmental obligations may be established for manufacturers through voluntary harmonised standards covering product requirements (safety, functionality, and non-LCA-related environmental aspects) concerning manufacturing, design, and packaging. These may be defined by the European Commission through Delegated Acts (Article 7, paragraph 1). In such cases, manufacturers must refer to these voluntary standards in the technical documentation to demonstrate compliance.
 

Spare parts availability

Manufacturers may be required to ensure the availability of specific spare parts on the market, particularly those essential for replacing components with proprietary designs. This aims to promote circularity, repairability, and waste reduction.
 

Environmental labelling

The European Commission may set specific environmental labelling requirements for certain product families or categories, especially those typically chosen by consumers and whose environmental performance does not significantly depend on installation.
 

Alignment with Basic Requirements for Construction Works (BRCW)

CPR-2024 restructures and details the BRCW, emphasising the lifecycle approach and environmental impact across all stages, including deconstruction. New requirements such as "emissions to the outdoor environment" are introduced or elaborated.


The role of the new Assessment and Verification System 3+ (AVS 3+)

CPR-2024 introduces a new system—AVS 3+—specifically dedicated to assessing the environmental sustainability of products.

The manufacturer is responsible for evaluating environmental performance (data collection, modelling, company-specific data) and implementing factory production control (FPC).
A Notified Body must validate the manufacturer’s environmental assessment. This includes checking input data, assumptions, the assessment process, software use, and conducting an initial on-site inspection to validate company-specific data.
 

Links to other EU regulations

Digital Product Passport (DPP)

CPR-2024 also introduces the **Construction Digital Product Passport**, integrated into the broader DPP framework established by the Ecodesign for Sustainable Products Regulation (ESPR). The DPP will contain comprehensive information on construction products throughout their lifecycle, including the DoPC and other sustainability-relevant details. It will become mandatory 18 months after the Delegated Act establishing the DPP system enters into force.

Green Public Procurement

CPR-2024 reinforces the use of sustainable construction products in public procurement. Contracting authorities will be required to apply minimum environmental sustainability requirements—if specified in Delegated Acts under CPR—for contracts that require such performance. Authorities may still set more ambitious requirements.

ESPR and REACH

CPR-2024 is aligned with the ESPR for sustainability. For energy-related products that are also construction products (e.g., boilers or HVAC systems), sustainability requirements will be defined under the ESPR. REACH regulations indirectly affect construction products by governing the chemical substances used in their production; relevant REACH information must be included with the DoPC.
 

In summary

The new CPR-2024 represents a significant step toward greater sustainability in the construction sector, imposing clear and progressive obligations on manufacturers regarding the declaration of environmental performance, and integrating sustainability into aspects such as labelling, spare parts availability, and public procurement. These changes are designed to improve transparency, support the circular economy, and contribute to the EU's environmental objectives.

 

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