If you export construction products to the EU, changes to environmental reporting are coming. For manufacturers of cement, reinforcing and prestressing steel for concrete, and windows and doors, it is sensible to start preparing now. 

The revised EU Construction Products Regulation (EU-CPR 2024) applies in stages from 8 January 2026, and its provisions on penalties apply from 8 January 2027. In practice, a manufacturer cannot be penalised for failing to meet a new product-specific requirement before that requirement applies to its products. This depends on when the relevant harmonised technical specification is made applicable.

That does not mean manufacturers should wait. Work on the first product families is already under way, and the first cement standards are expected to become mandatory in 2027. Other product families will follow their own timetables. For manufacturers whose data will take months to gather and assess, the time to prepare is now.

What is the revised EU-CPR 2024? 

The EU-CPR (EU Construction Products Regulation) sets the rules for placing construction products on the EU market. Under the revised regulation, manufacturers of products covered by the new requirements will need to declare environmental characteristics based on a life cycle assessment (LCA). Global Warming Potential (so called "carbon footprint") is the first indicator, with further environmental characteristics introduced over time. 

The regulation also provides for the establishment of Digital Product Passports (DPPs). These will make required product information available digitally, including information about environmental performance. 

The 2011 and 2024 regulations will coexist during the transition.  

What does this mean for me as a UK manufacturer? 

In simple terms, if you export a construction product to the EU, you will need to provide the required environmental information when the new rules become applicable to that product. Producing that information will involve an LCA using the relevant European assessment methods, including EN 15804. 

The work behind an LCA can be substantial. You need to establish which products and variants are covered, which manufacturing sites and suppliers are involved, what rules govern the assessment, and where the data will come from. As in any EN 15804-compliant LCA, materials, energy use, waste, transport and other aspects of the product’s life cycle all need to be accounted for.  

I already have an EPD. Am I covered? 

An existing Environmental Product Declaration (EPD) gives you a valuable head start. A construction product EPD prepared to EN 15804+A2 is based on an LCA and contains much of the environmental information relevant to the revised EU-CPR. 

It does not automatically establish that every future requirement is met. The EPD and its underlying model should be checked against the products you currently sell and the requirements that become applicable to them. You may need to update manufacturing data, include further variants or carry out additional modelling. 

With EPD performed to current Standards it is likely that you will have done most of the work required to comply. 

Why do cement, steel, window and door manufacturers need to act now? 

Cement, reinforcing steel for concrete, and doors and windows are among the early product families in the EU’s working plan. The first new cement standards may become mandatory in 2027; the precise timing for other products depends on the development and application of their relevant technical specifications. 

If you export products in these groups, it is important to start assessing your position now. Once the new requirements apply to your products, you will have a finite period to complete any necessary transition. Beginning with your product range and available data now gives you time to identify gaps and address them properly. 

The LCA work will be familiar to anyone who has developed an EPD. It starts with defining the goal and scope, mapping the product system and gathering reliable manufacturing and supply chain data. Relevant complementary product category rules (c-PCRs) add detail for particular product types. For example, EN 17213 provides rules for EPDs for windows and pedestrian doorsets. 

How can Cascade guide you through the process? 

You do not need to interpret the regulation and organise an LCA project on your own. Cascade Sustainability helps manufacturers prepare their LCAs to comply with the requirements. 

We start by understanding what you manufacture, which products you export and what environmental data you already hold. If you have EPDs, we can review their scope and underlying models. If you are starting from scratch, we can help decide which products to prioritise and define an appropriate LCA programme. 

We then guide your team through data collection. Rather than handing you a generic spreadsheet and leaving you to work it out, we prepare a bespoke data request for your products. We always begin with an on-site kick-off, check the information as it comes in, hold regular check-ins and provide telephone support when a question arises. 

From there, we carry out the LCA modelling and explain the results. Where an EPD is the right route, we can manage its preparation, independent verification and publication. As the EU-CPR requirements for your product family become clearer, we can help you assess what further work is needed. 

Reliable, product-specific environmental information can help you respond to requests from buyers and specifiers and support competitive tenders in the UK and EU. 

What are my next steps?

Contact Cascade Sustainability. Tell us which products you export and whether you already have EPDs. We can help you establish where you stand, what data is missing and the most sensible next step. 

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