You CE-mark your products. You issue Declarations of Performance. You might even have EPDs for some of your product lines. And now someone mentions CPR revision, GWP requirements, and Digital Product Passports in the same sentence.
Four abbreviations. It sounds like four separate compliance projects landing on your desk at once.
They’re not. They’re one chain. And if you already have EPDs, you’ve done most of the heavy lifting without realizing it.
CPR: The rules you already follow, with a new chapter
You’ve been living under the Construction Products Regulation since 2011. Every time you CE-mark a product or issue a Declaration of Performance, that’s CPR at work.
The revised version (Regulation 2024/3110) doesn’t tear up what you know. It adds a chapter. The big change: environmental performance data is no longer something you can choose to include. For many product categories, it’s now required.
Since January 8, 2026, manufacturers of Annex II (a-d) products must include Global Warming Potential in their Declaration of Performance. If you make concrete, steel, insulation, or similar high-impact products, this applies to you right now.
The Commission laid out a product-family roadmap in the CPR Working Plan, published in December 2025. It tells you which harmonized standards get revised first, and when those revisions become binding. Concrete, steel, and insulation lead the queue.
There’s also a Digital Product Passport requirement in the revised CPR. Construction DPPs become mandatory 18 months after the EU’s digital infrastructure is operational, likely around 2029-2030. That sounds distant, but the preparation has a long lead time.
Worth noting: the CPR is separate from the ESPR (Ecodesign for Sustainable Products Regulation). Construction products get their own DPP track. But steel manufacturers, for example, will answer to both regulations.
Penalty enforcement begins January 8, 2027.
GWP: The number that wins (or loses) you projects
GWP stands for Global Warming Potential. In practical terms, it’s the carbon footprint of your product: how many kilograms of CO2-equivalent it takes to produce one functional unit. One square meter of insulation at a given R-value. One cubic meter of concrete at a given strength class.
You calculate it through a Life Cycle Assessment. For construction products, the standard is EN 15804+A2. At minimum, you need cradle-to-gate data (raw materials, transport, manufacturing). Increasingly, the full lifecycle including use and demolition is expected.
A technical detail for your LCA consultant: GWP is no longer reported as a single number. EN 15804+A2 splits it into three: fossil emissions, biogenic carbon (important for timber), and land use change. All three go into your EPD.
But the real reason GWP matters isn’t technical. It’s commercial.
Buildings account for about 40% of EU energy consumption and 36% of greenhouse gas emissions. That puts construction products squarely in the regulatory spotlight. And the market is moving faster than the regulation. Architects already filter products by GWP when specifying materials. Public procurement in Norway and across the EU increasingly favors low-carbon options with documentation to prove it.
If you can show your numbers, you’re in the conversation. If you can’t, the manufacturer who can takes the project.
From 2030, product-level GWP data will feed directly into mandatory whole-life carbon calculations for new buildings. The numbers you report today determine how easily architects can specify your products tomorrow.
EPD: You probably already have the data
An EPD is essentially a nutrition label for environmental impact. It takes the GWP number (and other environmental indicators) from your LCA and packages it in a standardized, third-party verified format that the market trusts.
In Norway, EPDs are registered through EPD-Norge (now operating internationally as EPD-Global), which has over 8,600 declarations. They’re valid for five years.
Getting your first EPD involves about eight steps: consultation, finding the right Product Category Rules for your product type, running the LCA, getting it independently verified, and registering the result.
Nobody pretends it’s cheap. The registration fees are modest (roughly EUR 100-400 per year per EPD), but the LCA consultant doing the actual analysis costs EUR 4,500-13,500 or more. Add verification, and a first EPD for a typical SME runs EUR 7,000-18,000 in total.
That’s real money. But here’s what makes it a good investment rather than a sunk cost: roughly 60-70% of what a Digital Product Passport will eventually require is already in your EPD. GWP data, material composition, resource use, lifecycle stages. All there.
The gaps are specific: recycled content percentages, reuse potential, substances of concern, and end-of-life instructions. Those you’ll need to add. But the core environmental data, the expensive part to produce, is done.
One more thing changing in your favor: EPDs are going digital. EPD-Norge now offers data in ISO 22057 JSON format, built for BIM integration. That structured, machine-readable format is much closer to what DPP expects than a traditional PDF. If you’re renewing an EPD soon, ask for digital delivery. You’ll save yourself a conversion step later.
The important thing to remember: DPP doesn’t replace your EPD. It wraps around it. Your EPD becomes the environmental data layer inside a larger digital record. The investment you’ve already made carries forward.
DPP: Not new data. New delivery.
Picture this: an architect scanning a QR code on your insulation product and instantly seeing its carbon footprint, recycled content, CE marking details, and end-of-life recycling instructions. All verified, all current, all machine-readable.
That’s a Digital Product Passport. A persistent digital record tied to your product’s unique identifier, accessible to anyone in the value chain.
For construction products, a DPP will contain your EPD data plus the pieces EPDs don’t cover: recycled content percentages, reuse and recycling potential, CE marking, Declaration of Performance, substances of concern, and end-of-life guidance.
The format is designed for software, not filing cabinets. Each product gets a globally unique identifier and a QR code on the product or packaging that links to the data. When someone scans it, they reach your data hosted on your own infrastructure (or your DPP provider’s). There’s no central EU database storing your product information.
Construction DPPs won’t arrive on a single deadline. They phase in as harmonized standards are revised for each product family, following the roadmap in the December 2025 Working Plan. Concrete, steel, and insulation first. Others follow.
Norwegian manufacturers have an advantage here. Standard Norge’s committee SN/K 624, with 47 member organizations, is directly shaping the European standards through CEN/CLC/JTC 24. Companies involved in this committee influence the rules rather than just react to them.
If you have EPDs with solid data quality, the transition to DPP isn’t about going back to collect new data. It’s about packaging what you already have in a digital format and filling a few specific gaps.
Think of your EPD as a research paper sitting in a library. The DPP turns it into a searchable database entry that architects, contractors, and inspectors can access the moment they need it.
The chain
Strip away the abbreviations and the logic is simple:
CPR is the regulation. It says: building products must declare their environmental performance.
GWP is the metric. It answers: how much CO2 does your product generate?
EPD is the report. It packages your GWP data (and more) in a format the market trusts.
DPP is the digital wrapper. It takes your EPD data, adds circularity and regulatory information, and makes everything scannable and machine-readable.
Each builds on the one before. You can’t skip steps, and you don’t need to. If you’ve done the LCA and published an EPD, the foundation for your DPP is already in place.
What to do now
If you have EPDs: Compare what’s in them against what DPP requires. Your GWP and material composition data are covered. Recycled content percentages? Probably not there yet. End-of-life instructions? Almost certainly missing. Identify these gaps now so you can fill them at your next EPD renewal rather than starting from scratch later. Also, look at where your product data actually lives. If it’s scattered across ERP, PIM, and spreadsheets, consolidation is your first real task.
If you don’t have EPDs: Check whether your products fall under Annex II (a-d). If they do, GWP disclosure in your Declaration of Performance is already required. For concrete, steel, or insulation, starting the EPD process now is worth it. Plan for 8-12 months from first consultation to registration.
Either way: Find your products in the Annex VII families from the Commission’s December 2025 Working Plan. That document shows when your specific product family’s harmonized standards are scheduled for revision. That’s your timeline.
Need help preparing your building products for DPP? DPPA builds the digital infrastructure for construction product manufacturers. We’re members of Standard Norge’s DPP standardization committee (SN/K 624) and work directly with Norwegian building product companies to turn EPD data into DPP-ready formats. Get in touch to discuss your timeline.