Construction Products Delegated Act Tracker: ESPR Construction DPP Status

Construction Products Delegated Act: Interaction with the Revised CPR

The ESPR delegated act for construction products is being developed in close coordination with the revised Construction Products Regulation (CPR, EU 2024/3110), which entered into force in 2024. The revised CPR introduces Digital Product Passport requirements for construction products that are aligned with the ESPR framework. The ESPR delegated act will set the ecodesign requirements (minimum recycled content, maximum carbon footprint, minimum recyclability) while the revised CPR governs the declaration of performance and CE marking process. Manufacturers of construction products must ensure their compliance systems address both frameworks simultaneously — a product that meets the ESPR ecodesign requirements but does not have a valid declaration of performance under the CPR cannot be placed on the EU market.

Priority Construction Product Categories for ESPR

The EU Commission's ESPR work programme identifies the following construction product categories as priorities for the first construction products delegated act: thermal insulation products (mineral wool, EPS, XPS, PUR/PIR), structural steel and reinforcement, cement and concrete, windows and doors, and gypsum-based products. A second delegated act is expected to cover ceramic tiles, sanitary ware, paints and coatings for construction applications, and flooring products. The prioritisation reflects the relative environmental impact of these product categories — thermal insulation and structural steel together account for the majority of the embodied carbon in new EU buildings.

Construction Products DPP and Building Lifecycle Assessment

The ESPR construction products DPP will provide the data needed for whole-building lifecycle assessment (LCA) under EN 15978 (Sustainability of construction works — assessment of environmental performance of buildings). Building LCA is increasingly required by green building certification schemes (BREEAM, LEED, DGNB) and by national building regulations in several EU member states. The ESPR construction products DPP will standardise the format and methodology for environmental product declarations (EPDs), making it easier for architects and building energy assessors to incorporate EPD data into whole-building LCA calculations. Manufacturers that have already produced EPDs for their products under EN 15804 will have a significant head start on ESPR DPP compliance.

Construction Products Regulation (CPR) and ESPR: The Regulatory Overlap

Construction products are currently regulated under the Construction Products Regulation (CPR, EU 305/2011), which requires construction products to have a Declaration of Performance (DoP) and to bear the CE marking. The CPR is being revised (the new CPR is expected to be published in 2025) and the revised CPR will include DPP requirements for construction products that align with ESPR. The ESPR construction products delegated act will build on the revised CPR framework, adding ecodesign requirements for energy efficiency, recycled content, and carbon footprint to the existing CPR performance requirements. Manufacturers of construction products should monitor both the CPR revision and the ESPR delegated act development simultaneously, as the two regulatory processes are closely linked.

Construction Products DPP: Expected Data Requirements

Based on the EU Commission's preparatory study for the ESPR construction products delegated act, the construction products DPP is expected to require disclosure of the following data: primary material composition (concrete, steel, timber, glass, insulation material), recycled content percentage, carbon footprint per functional unit (kg CO₂e per m² or per tonne), energy performance (thermal conductivity, thermal resistance, U-value), durability class (expected service life under defined conditions), chemical substances of concern (VOC content, heavy metals, asbestos), and end-of-life recyclability class. Construction product manufacturers should begin collecting this data now, as the delegated act is expected to be published in 2026–2027 with a 2-year implementation period.

Level(s) Framework and ESPR Construction Products

The EU Commission's Level(s) framework is a voluntary reporting framework for the environmental performance of buildings. Level(s) uses lifecycle assessment (LCA) methodology to assess the environmental impact of buildings across their lifecycle — from material extraction and manufacturing, through construction and use, to demolition and end-of-life. The Level(s) framework provides a methodology for calculating the carbon footprint of construction products that is aligned with the EN 15804 standard for environmental product declarations (EPDs). Construction product manufacturers that have already prepared EPDs for their products using the EN 15804 standard will have a significant head start on ESPR DPP carbon footprint disclosure requirements, as the EPD data is the same data that will be required in the ESPR DPP.

Construction Products DPP: Data Collection Strategy

Construction product manufacturers face a unique data collection challenge for ESPR DPP compliance: their products are often made from raw materials sourced from multiple suppliers across multiple countries, and the environmental data for these raw materials (carbon footprint, recycled content, chemical composition) is often not readily available. The most effective data collection strategy for construction product manufacturers is to use Environmental Product Declarations (EPDs) as the primary data source for the DPP. EPDs are third-party verified lifecycle assessment reports that provide standardised environmental data for construction products, prepared in accordance with the EN 15804 standard. EPDs are already widely used in the construction industry for green building certification (LEED, BREEAM, DGNB), so many construction product manufacturers already have EPDs for their products. Manufacturers that have EPDs can use the EPD data as the basis for their ESPR DPP carbon footprint and recycled content disclosures, significantly reducing the data collection burden.

Manufacturers that do not have EPDs should begin the EPD preparation process now. The EPD preparation process involves: selecting an accredited EPD programme operator (such as EPD International, IBU, or INIES), commissioning a lifecycle assessment study from an accredited LCA practitioner, submitting the LCA study to the EPD programme operator for third-party verification, and publishing the EPD in the EPD programme operator's database. The entire process typically takes 6–12 months and costs €5,000–€20,000 depending on the complexity of the product and the LCA study. Manufacturers that begin the EPD preparation process now will have their EPDs ready well before the ESPR construction products delegated act compliance deadline.

Construction product manufacturers should also monitor the development of the revised Construction Products Regulation (CPR), which is being revised in parallel with ESPR. The revised CPR will introduce new requirements for construction products, including requirements for environmental performance declarations and digital product information. The ESPR construction products delegated act and the revised CPR will be aligned to avoid duplication of requirements — manufacturers should monitor both regulatory processes and engage with their sector trade association (FIEC, BIBM, CEMBUREAU) to understand the implications of each regulatory development for their product portfolio. The EU Commission has committed to publishing a roadmap for the alignment of ESPR and the revised CPR by the end of 2025.

Construction product manufacturers should also note that the ESPR construction products delegated act will be coordinated with the revised Construction Products Regulation (CPR) to avoid duplication. Monitor both regulatory tracks simultaneously.