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Building Materials

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.

Regulatory note: this page does not treat building materials as a confirmed first-wave ESPR DPP category. It reflects a dual regulatory context: ESPR watchlist logic plus a separate formal CPR track under Regulation (EU) 2024/3110. Important: mandatory GWP declarations for priority construction products are already in force since 8 January 2026 — this is confirmed law, not a planning signal.

Practical Timeline

18 Jul 2024

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.

28 Nov 2024

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.

8 Jan 2026

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.

Apr 2025

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.

15 Dec 2025

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.

2026–2029

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.

2028

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
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