Building Materials: ESPR Requirements, CPR Interaction, EPDs, Recycled Content, and DPP Compliance Guide
Building materials — steel, concrete, glass, ceramics, timber — are a priority category for ESPR due to their significant environmental impact. The delegated act is expected in 2026–2027. The DPP will require carbon footprint per functional unit (via EPD), recycled content, and end-of-life recyclability. The revised Construction Products Regulation (EU) 2024/3110 adds complementary requirements.
Truth Anchor: ESPR Article 5(1) identifies construction products as a priority category. The revised Construction Products Regulation (EU) 2024/3110 requires CE marking and performance declarations for construction products. — EUR-Lex CELEX:32024R1781
EPDs as the Foundation for Building Material DPPs
Environmental Product Declarations (EPDs) are ISO 14025-compliant documents that disclose the environmental performance of construction products. EPDs are already required for construction products in many EU public procurement specifications (Green Public Procurement criteria, Level(s) framework). The ESPR DPP for building materials will build on the EPD framework — manufacturers who already have EPDs will have a significantly lower DPP preparation burden.
EPDs for building materials are published on programme operator databases such as EPD International, Institut Bauen und Umwelt (IBU), and the INIES database. The ESPR DPP is expected to reference the EPD as the source of carbon footprint and lifecycle data, rather than requiring manufacturers to recalculate this data for the DPP.
Concrete: The Clinker Ratio Challenge
Concrete is the most widely used building material in the world and one of the largest sources of CO2 emissions. The carbon footprint of concrete is primarily determined by the clinker content of the cement — clinker production emits approximately 0.83 kg CO2 per kg of clinker. Reducing the clinker ratio by substituting supplementary cementitious materials (SCMs) — fly ash, ground granulated blast furnace slag (GGBS), silica fume — is the most effective way to reduce concrete’s carbon footprint.
The ESPR DPP for concrete is expected to require disclosure of the clinker ratio, SCM content, and recycled aggregate content. This will create market pressure to reduce clinker ratios and increase SCM use — a significant change for concrete producers who currently use high-clinker Portland cement for simplicity.
What Building Material Manufacturers Must Do Now
Obtain Environmental Product Declarations (EPDs): EPDs provide the carbon footprint and lifecycle data required for the DPP. Commission EPDs for all major product lines now.
Audit recycled content: Determine recycled content percentages for all building materials. Steel manufacturers should document EAF vs BOF production routes.
Document supplementary cementitious materials (concrete): Determine fly ash, GGBS, and silica fume content for concrete mixes. This will be required in the DPP.
Verify CPR compliance: Confirm CE marking and performance declarations under the Construction Products Regulation for all construction products.
Prepare DPP data templates: Create DPP data templates for all building material product lines, referencing EPD data where available.
Building Materials Under ESPR: The Construction Products Delegated Act
Building materials (concrete, bricks, tiles, glass, structural steel, and other construction products) will be subject to the ESPR construction products delegated act, expected in 2026-2027. The delegated act will cover a broad range of construction products and will set requirements for recycled content, carbon footprint, substances of concern, and the Digital Product Passport. The construction sector accounts for approximately 40% of EU energy consumption and 36% of EU carbon emissions — making it a priority for ESPR.
Building Materials DPP: Expected Data Fields
Data Category
Expected Data Fields
Basis
Product identification
Product type, standard reference, declared performance values
Embodied Carbon: The Key Metric for Building Materials
Embodied carbon — the carbon emissions associated with manufacturing, transporting, and installing building materials — is the key environmental metric for the construction sector. As buildings become more energy-efficient in use, embodied carbon becomes a larger share of a building's total lifecycle carbon footprint. The ESPR building materials DPP will make embodied carbon data publicly accessible, enabling architects, engineers, and developers to compare products on this dimension and choose lower-carbon alternatives.
Which Building Materials Are Covered by ESPR?
The ESPR regulation applies to all energy-related products and products that have a significant environmental impact across their lifecycle. For building materials, this encompasses a broad range: structural materials (concrete, steel, timber, masonry), envelope materials (insulation, windows, roofing), interior finishes (paints, coatings, flooring, tiles), and building services equipment (HVAC, lighting, water heating). The ESPR delegated act process will determine which specific building material categories are prioritised and on what timeline. The EU Commission's preparatory studies have identified construction as one of the highest-priority sectors due to its contribution to embodied carbon — the carbon emissions associated with the manufacture and installation of building materials, as distinct from the operational carbon of running the building.
Embodied Carbon and the Building Materials DPP
Embodied carbon is the carbon footprint of a building material across its full lifecycle — from raw material extraction through manufacturing, transport, installation, maintenance, and end-of-life disposal or recycling. The ESPR building materials DPP will require manufacturers to declare the carbon footprint per functional unit using the methodology specified in EN 15804 (Environmental Product Declarations for construction products) and ISO 14044 (Life Cycle Assessment). This data will be expressed as kg CO₂ equivalent per declared unit — for example, kg CO₂e per m² of flooring at a specified thickness, or kg CO₂e per tonne of cement. Manufacturers that have already produced Environmental Product Declarations (EPDs) for their products will have a significant head start on ESPR DPP compliance, as EPDs contain most of the data that the DPP will require.
The EU Product Database for Building Materials
The EU product database established under Article 12 of ESPR will serve as the central repository for building material DPP data. Manufacturers will be required to register their products in this database before placing them on the EU market. The database will be accessible to market surveillance authorities, construction professionals, building certifiers, and the public. For building professionals — architects, structural engineers, quantity surveyors, and building energy assessors — the database will provide a standardised source of environmental performance data for use in whole-building lifecycle assessments and green building certification schemes such as BREEAM, LEED, and DGNB.
Carbon footprint, recycled gypsum content, fire performance
EN 15804, EN 520
Frequently Asked Questions: Building Materials ESPR Requirements
The ESPR delegated act for construction products (including building materials) is expected in 2026-2027, with a compliance date of 2028-2029. Steel, concrete, glass, and ceramics are expected to be covered.
Yes. The revised Construction Products Regulation (EU) 2024/3110 and ESPR overlap for construction products. The CPR requires CE marking and performance declarations. ESPR adds DPP requirements. Manufacturers must comply with both.
Steel is one of the most recycled materials globally. EU steel production already uses approximately 50% recycled scrap. The ESPR delegated act is expected to require disclosure of recycled steel content and may set minimum recycled content requirements.
Concrete is expected to be covered by the construction products delegated act. The DPP for concrete will require disclosure of cement content (clinker ratio), recycled aggregate content, supplementary cementitious materials (fly ash, GGBS, silica fume), and carbon footprint per m³.
An EPD is an ISO 14025-compliant document disclosing the environmental performance of a construction product. EPDs are already required for construction products in many EU public procurement specifications. The ESPR DPP for building materials will build on the EPD framework.
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
Building materials are subject to both ESPR and the revised Construction Products Regulation (CPR), which is currently being updated to align with the EU's Green Deal objectives. The revised CPR will require manufacturers of construction products to provide a Declaration of Performance that includes environmental performance data, and will introduce a Digital Product Passport for construction products. The ESPR delegated acts for building materials will complement the revised CPR by setting minimum performance requirements for specific product categories.
The interaction between ESPR and the revised CPR is complex and is still being worked out by the Commission. The general principle is that the CPR sets the framework for construction product performance declarations, while ESPR sets the minimum performance requirements and DPP data requirements. Manufacturers of building materials will need to comply with both regulations, but the Commission is working to ensure that the DPP requirements are aligned so that manufacturers do not need to create separate DPPs for each regulation.
Priority Building Material Categories Under ESPR
The ESPR Working Plan identifies several building material categories as priorities for delegated act development: structural steel and reinforcement steel; aluminium profiles and panels; concrete and cement; ceramic tiles and sanitaryware; flat glass; gypsum products; and wood-based panels (particleboard, MDF, OSB, plywood). These categories are priorities because they have significant environmental impacts (high carbon footprint, high resource consumption) and because there is significant potential for improvement through ecodesign requirements.
Frequently Asked Questions
ESPR delegated acts for building materials are expected to be adopted in 2025–2028, depending on the product category. The Commission is prioritising product categories with the highest environmental impact. Manufacturers should monitor the ESPR Working Plan for updates on the timeline for their specific product category.
The EU Taxonomy Regulation sets criteria for environmentally sustainable economic activities, including construction. Building materials that meet ESPR requirements are more likely to qualify as inputs to EU Taxonomy-aligned construction activities. Manufacturers who can demonstrate ESPR compliance will have a competitive advantage in the sustainable construction market.
The ESPR delegated acts for building materials are expected to require manufacturers to calculate and disclose the carbon footprint of their products using a standardised methodology (the EU Level(s) framework or the EN 15804 standard for construction products). The Commission may also set maximum carbon footprint thresholds for specific product categories.
Yes. ESPR applies to all products placed on the EU market, regardless of where they are manufactured. Importers of building materials are responsible for ensuring that the products they import comply with ESPR requirements, including the DPP requirement. This is a significant compliance challenge for importers of building materials from countries with less stringent environmental regulations.
Cement production accounts for approximately 7% of global CO2 emissions. The ESPR delegated act for cement and concrete is expected to require manufacturers to calculate and disclose the carbon footprint of their products and to set minimum requirements for the use of supplementary cementitious materials (SCMs) such as fly ash, slag, and calcined clay, which can significantly reduce the carbon footprint of cement.