Construction products are a priority sector in the ESPR Work Plan 2024–2027. The delegated act is expected in 2027–2028, with compliance requirements from 2029. Construction product manufacturers must prepare for energy performance declarations, recycled content data, and hazardous substance disclosures in the DPP.
The ESPR construction products delegated act is expected to cover: insulation materials (mineral wool, EPS, XPS, PIR), structural steel and concrete products, windows and glazing, roofing materials, flooring products, and facade systems. These categories account for the largest share of embodied carbon in EU buildings.
| Data Category | Expected Requirement | Standard |
|---|---|---|
| Energy performance | Thermal conductivity (λ), thermal resistance (R), and energy performance class | EN 12667, EN 13162 |
| Embodied carbon | Global Warming Potential (GWP) per functional unit across lifecycle (A1–A3, C, D) | EN 15804, ISO 21930 |
| Recycled content | Percentage of recycled material by weight, with verification methodology | EN 15804 |
| Hazardous substances | SVHC declarations, VOC emissions class, biocide content | REACH, EN 16516 |
| End-of-life recyclability | Recyclability percentage, waste stream classification, end-of-life scenario | EN 15804 |
| Durability | Expected service life, maintenance requirements, degradation data | ISO 15686 |
| CE marking reference | Reference to Declaration of Performance (DoP) under CPR | CPR Regulation (EU) 2024/3110 |
The revised Construction Products Regulation (CPR — Regulation (EU) 2024/3110) entered into force in 2024 and introduces a Digital Construction Product Passport (DCPP) requirement for construction products. The DCPP and the ESPR DPP are aligned — manufacturers will need to produce a single DPP that satisfies both requirements.
The key difference is that the CPR DCPP focuses on performance characteristics (structural, fire, thermal, acoustic), while the ESPR DPP adds sustainability data (embodied carbon, recycled content, hazardous substances, end-of-life). Both data sets will be accessible through the same QR code and registry infrastructure.
The construction sector accounts for approximately 40% of EU energy consumption and 36% of EU carbon emissions. Construction products — including concrete, bricks, steel, glass, insulation, and other building materials — have a significant embodied carbon footprint that is increasingly recognised as a priority for decarbonisation. ESPR will play a key role in reducing the embodied carbon of construction products by requiring carbon footprint data in the DPP and setting minimum recycled content requirements.
The ESPR construction products delegated act is expected to be adopted in 2026-2027, with mandatory compliance from 2028-2029. The delegated act will cover a broad range of construction products and will interact with the Construction Products Regulation (CPR), which sets performance requirements for construction products. The ESPR DPP will complement the CPR's Declaration of Performance (DoP) by adding sustainability data to the existing performance data.
| Data Category | Expected Data Fields | Basis |
|---|---|---|
| Product identification | Product type, standard reference (EN), declared performance values | CPR + ESPR |
| Recycled content | Recycled aggregate %, recycled steel %, recycled glass % | ESPR Annex III |
| Carbon footprint | CO2e per kg or per m² (EPD data, EN 15804) | ESPR Annex III |
| Substances of concern | Hazardous substances, concentration, location in product | REACH + ESPR Annex III |
| Durability | Expected service life (years), maintenance requirements | ESPR Annex III |
| End-of-life | Recyclability, reuse potential, waste classification | ESPR Annex III |
Environmental Product Declarations (EPDs) are standardised documents that contain lifecycle assessment data for construction products, including carbon footprint data calculated according to EN 15804. Many construction product manufacturers already produce EPDs. EPD data can be used to populate the carbon footprint field in the ESPR DPP, reducing the additional data collection burden. Manufacturers who do not have EPDs should commission them now — the data will be required for the ESPR DPP and EPDs have a five-year validity period.
Construction products in the EU are currently governed by the Construction Products Regulation (CPR, EU 305/2011), which is being replaced by the revised CPR (EU 2024/3110). The revised CPR introduces Digital Product Passport requirements for construction products that align with the ESPR framework. This means construction product manufacturers face a dual regulatory framework: ESPR delegated acts will set ecodesign requirements and DPP data fields, while the revised CPR governs the declaration of performance and CE marking process. Manufacturers must ensure their compliance systems address both frameworks simultaneously.
The ESPR delegated act for construction products is expected to require DPPs that include: product identifier and manufacturer details, material composition and origin, carbon footprint per functional unit (kg CO₂e per m² or per unit), recycled content percentage, end-of-life recyclability rate, chemical substances of concern, energy performance data where applicable, structural performance data referenced to the relevant harmonised standard, and the declaration of performance reference number. For insulation products specifically, the DPP will include thermal conductivity (λ value), thermal resistance (R value), reaction to fire classification, and water vapour transmission properties.
Significant volumes of construction products — particularly ceramic tiles, sanitary ware, insulation materials, and structural steel — are imported into the EU from Turkey, China, India, and Morocco. All manufacturers placing these products on the EU market must comply with ESPR requirements. The construction products delegated act will apply at the point of import, not at the point of manufacture. Non-EU manufacturers must appoint an EU Authorised Representative and ensure their products carry a CE marking based on a valid declaration of performance before the ESPR deadline. The EU's market surveillance authorities have specific powers under EU 2019/1020 to test imported construction products and withdraw non-compliant products from the market.
| Construction Product Category | Governing Regulation | ESPR DPP Expected |
|---|---|---|
| Thermal insulation (mineral wool, EPS, XPS) | CPR + ESPR delegated act | 2027–2028 |
| Structural steel and reinforcement | CPR + ESPR iron/steel delegated act | 2027–2028 |
| Cement and concrete | CPR + ESPR delegated act | 2028–2029 |
| Ceramic tiles and sanitary ware | CPR + ESPR delegated act | 2028–2029 |
| Windows and doors (glazed) | CPR + ESPR delegated act | 2027–2028 |
No. ESPR operates alongside the revised Construction Products Regulation (CPR — Regulation (EU) 2024/3110). The CPR sets performance requirements for construction products; ESPR adds sustainability and DPP requirements. Both regulations apply simultaneously to construction products placed on the EU market.
The ESPR construction products delegated act is expected in 2027–2028, with compliance requirements entering into force in 2029. The Commission's preparatory study is currently underway.
The EU Taxonomy Regulation (EU 2020/852) sets criteria for sustainable economic activities, including construction. ESPR DPP data — particularly carbon footprint, recycled content, and end-of-life recyclability — will be used to demonstrate EU Taxonomy alignment for construction products.
ESPR applies to products placed on the EU market, including products used in renovation. The delegated act will specify whether products installed before the compliance date are subject to DPP requirements.
Construction products are subject to both ESPR and the EU Construction Products Regulation (CPR, EU 2024/3110, replacing Regulation (EU) 305/2011). The CPR sets requirements for the performance of construction products (structural integrity, fire resistance, thermal insulation, etc.) and requires CE marking for products covered by harmonised standards. ESPR adds sustainability requirements (recycled content, carbon footprint, DPP) on top of the CPR performance requirements.
The ESPR delegated act for construction products is expected in 2027–2029. The delegated act will cover: structural materials (steel, concrete, timber); insulation materials; cladding and facade systems; windows and doors; roofing materials; and flooring materials. The delegated act will not cover: construction products that are permanently incorporated into buildings (these are covered by the CPR).
The most significant environmental impact of construction products is embodied carbon — the carbon emissions associated with the extraction, processing, manufacturing, and transportation of construction materials. Embodied carbon accounts for approximately 11% of global greenhouse gas emissions. The ESPR delegated act for construction products is expected to require disclosure of embodied carbon in the DPP.
The methodology for calculating embodied carbon in construction products is specified in EN 15804 (Sustainability of construction works — Environmental product declarations — Core rules for the product category of construction products). Environmental Product Declarations (EPDs) prepared in accordance with EN 15804 provide the embodied carbon data required for the DPP.
Manufacturers of construction products who already have EPDs are well-positioned for ESPR compliance. The EPD data can be directly incorporated into the DPP data record. Manufacturers who do not have EPDs should commission EPD preparation as a priority.
Environmental Product Declarations (EPDs) are the primary tool for communicating the environmental performance of construction products. An EPD is a standardised document that quantifies the environmental impacts of a product over its lifecycle, using the methodology specified in EN 15804 (for construction products) or ISO 14025 (for general products). EPDs are prepared by manufacturers and verified by independent third parties.
The ESPR delegated act for construction products is expected to require that EPD data be included in the DPP. Manufacturers who already have EPDs for their products are well-positioned for ESPR compliance — the EPD data can be directly incorporated into the DPP data record. Manufacturers who do not have EPDs should commission EPD preparation as a priority.
EPDs are prepared in accordance with Product Category Rules (PCRs) that specify the methodology for calculating environmental impacts for a specific product category. PCRs are developed by EPD programme operators (e.g., EPD International, Institut Bauen und Umwelt). Manufacturers should identify the applicable PCR for their product category before commissioning an EPD.
Construction products are subject to both ESPR and the EU Construction Products Regulation (CPR, EU 2024/3110). The CPR sets requirements for the performance of construction products (structural integrity, fire resistance, thermal insulation, etc.) and requires CE marking for products covered by harmonised standards. ESPR adds sustainability requirements (recycled content, carbon footprint, DPP) on top of the CPR performance requirements.
The interaction between the CPR and ESPR creates a dual compliance burden for construction product manufacturers. Manufacturers must comply with both the CPR performance requirements and the ESPR sustainability requirements. The DPP for construction products must include both CPR performance data and ESPR sustainability data.
Insulation materials are a priority sub-category within the construction products delegated act. The EU Commission’s preparatory study for insulation materials is expected to focus on: embodied carbon (the carbon footprint of manufacturing insulation materials); recycled content (the percentage of recycled material in insulation products); chemical substances of concern (particularly flame retardants and blowing agents); and end-of-life recyclability.
The main insulation material types (mineral wool, EPS, XPS, PIR/PUR, natural insulation) have very different environmental profiles. Mineral wool has a relatively low embodied carbon and is recyclable. EPS and XPS have higher embodied carbon but provide excellent thermal performance. PIR/PUR has the highest embodied carbon but the best thermal performance per unit thickness. The DPP will enable architects and builders to compare the environmental performance of different insulation materials on a like-for-like basis.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Register now at Africa's first ESPR-compliant DPP registry.
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