Building Materials: DPP Readiness under ESPR and CPR
Building materials are not part of the first ESPR working-plan product wave. However, the sector is not in a pure monitoring mode: mandatory GWP (Global Warming Potential) reporting for priority construction products has applied since 8 January 2026 under the revised CPR (Regulation (EU) 2024/3110). In parallel, the CPR Working Plan 2026–2029 includes planned delegated work around DPP for construction products. A practical approach is to ensure GWP compliance now, structure broader product data, and monitor both the ESPR review signal around 2028 and the parallel CPR path.
Practical Timeline
ESPR enters into force
Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation — enters into force, establishing the legal framework for Digital Product Passports across multiple product categories.
Revised CPR adopted
Regulation (EU) 2024/3110 — the revised Construction Products Regulation — is adopted, creating the sector-specific CPR framework for later DPP-related delegated work on construction products, separate from the ESPR track.
CPR GWP reporting mandatory (confirmed law)
Mandatory Global Warming Potential (GWP) declarations for priority construction products take effect under CPR 2024/3110. This is the first live environmental reporting obligation for the sector — confirmed law, not a planning signal. Further environmental indicators follow in 2030 and full LCA reporting in 2032.
ESPR Working Plan 2025–2030 published
The Commission publishes its first Working Plan (COM(2025) 187 final), setting priority product groups. Building materials are not included in the first wave but remain on the broader ESPR radar.
CPR Working Plan 2026–2029 published
The Commission publishes the CPR Working Plan 2026–2029, explicitly mentioning horizontal delegated acts including DPP for construction products. This creates a formal, parallel regulatory path for the sector.
CPR delegated acts in progress
The CPR Working Plan opens a multi-year regulatory path for construction products. This is the period to structure composition, carbon, recycled-content, and supplier-evidence data for both the ESPR and CPR frameworks.
ESPR mid-term review and CPR milestones converge
The Commission plans a mid-term review of the ESPR Working Plan. CPR delegated work should also be well underway. Both signals converge, making 2028 the natural readiness checkpoint for building materials.
Data Areas Worth Preparing Early
Composition and declared substances
Bill of materials, substance declarations, and links to safety data sheets or technical documentation per product variant.
Carbon footprint and environmental evidence
Product carbon data, EPD-related inputs, and evidence supporting environmental or sustainability claims.
Batch and supplier traceability
Lot-level information, supplier declarations, plant-of-origin records, and source-document retention.
End-of-life and circularity
Disassembly instructions, recycled content share, recovery routes, and installation-to-removal data continuity.
Product identification and variant mapping
Clean mapping of product families, dimensional variants, commercial references, and identifiers that can later connect to a digital product layer.
Installation, durability and performance records
Supporting data that links specification sheets, expected use context, durability ratings, and downstream handling instructions to the correct product record.
Who Should Act First?
Even without a confirmed delegated act, the readiness burden is already meaningful for:
- manufacturers of insulation, panels, boards, sealants, composites, coatings, and other documented construction products
- importers and distributors that already collect technical files and declarations from non-EU suppliers
- brands with product portfolios that depend on carbon, durability, or recycled-content evidence
- teams preparing data for CPR-related delegated acts before the formal text is final
- compliance and sustainability officers who need to track both ESPR and CPR developments in parallel