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CPR, EPBD, DoPC: a plain-language guide to the rules making EPDs mandatory

Anni Oviir 6 min read

If you make construction products in Europe, a set of acronyms has started appearing in tender documents, industry newsletters, and conversations with customers: CPR, DoPC, EPBD. Behind each one sits a piece of EU law that changes what environmental data you must produce, where it must appear, and what happens if it is wrong. This is a plain-language map of the three, what they mean for EPDs, and the dates that matter.

CPR: the Construction Products Regulation

The CPR is the EU regulation that governs how construction products are placed on the European market — it is the law behind CE marking. The original version dates from 2011. A fully revised CPR, Regulation (EU) 2024/3110, entered into force in January 2025 and applies to most construction products from 8 January 2026.

For anyone working with EPDs, the revision changes one thing above all: environmental performance moves from the voluntary column into the mandatory one. Under the old CPR, an EPD was something you chose to produce, usually because a customer or a green building scheme asked for it. Under the revised CPR, environmental characteristics become part of the product’s legal declaration — starting with global warming potential (GWP), with further life-cycle indicators phased in over the coming years as product standards are updated, through to around 2032.

The data behind these declarations is, in practice, EPD data. The environmental indicators the CPR asks for are calculated the way EN 15804 EPDs already calculate them. If your products have EPDs, you already hold the raw material. What changes is the legal weight it carries.

The revised CPR also creates a digital product passport for construction products — a structured digital record that will carry performance data, environmental indicators, and installation and end-of-life information through the supply chain. The detailed requirements are still being worked out in delegated acts, but the direction is clear: your environmental data will travel further, be machine-read more often, and be compared more automatically than ever before.

DoPC: the Declaration of Performance and Conformity

Under the old CPR, a product carried a Declaration of Performance (DoP) — the legal document behind the CE mark. The revised CPR replaces it with the Declaration of Performance and Conformity (DoPC), a single document that now also covers environmental and climate characteristics.

This is the detail worth pausing on. An EPD has always been a verified public document, but not a legal declaration in this sense. When environmental data moves into the DoPC, a wrong number is no longer just an embarrassment or a rework cost — it sits in a legally binding declaration. From 8 January 2027, Member States can penalise faulty environmental declarations.

That deadline is closer than it looks. The EPDs being produced and verified today are the ones whose numbers will flow into DoPCs. If the underlying EPD contains errors — and our experience reviewing published EPDs suggests errors are the norm rather than the exception — those errors inherit legal weight.

EPBD: the Energy Performance of Buildings Directive

The EPBD, Directive (EU) 2024/1275, works from the other end: the building. Its recast version, in force since 2024, extends the familiar energy performance certificate to cover whole-life carbon.

The dates: from 1 January 2028, every new building over 1,000 m² of useful floor area must have its life-cycle global warming potential calculated and disclosed in its energy performance certificate. From 1 January 2030, that applies to all new buildings. The calculation follows EN 15978 and the EU Level(s) framework, and Member States must publish roadmaps for introducing binding whole-life carbon limit values, with targets from 2030.

Why does a building directive matter to a product manufacturer? Because a building’s life-cycle carbon is assembled from the carbon of its products. When every new building needs a whole-life carbon figure, every specifier, architect, and developer needs product-level carbon data to build it from — and the product data they will reach for is EPD data. The EPBD is what turns EPDs from a marketing document into an input that building projects cannot proceed without.

The dates, side by side

  • January 2025 — revised CPR enters into force
  • 8 January 2026 — revised CPR applies to most construction products
  • 8 January 2027 — Member States can penalise faulty environmental declarations in the DoPC
  • 2027 — Member States publish roadmaps for whole-life carbon limit values under the EPBD
  • 1 January 2028 — life-cycle GWP disclosure mandatory for new buildings over 1,000 m² (EPBD)
  • 1 January 2030 — life-cycle GWP disclosure mandatory for all new buildings (EPBD); first carbon limit values expected
  • Through 2030–2032 — further CPR environmental indicators phase in, product family by product family

What this means in practice

Three regulations, one direction: environmental data about construction products is becoming mandatory, legally binding, and machine-readable. The demand side (EPBD) and the supply side (CPR and DoPC) are being wired together, with EPDs as the connecting data format.

The uncomfortable part is quality. Mandatory demand produces volume, and volume without visible quality produces a race to the lowest acceptable bar. Meanwhile the cost of a wrong number is going up — from rework, toward liability. The manufacturers who will be comfortable in 2027 are the ones treating EPD quality as a supply-chain risk today, not a formality.

If you want to know where your EPDs actually stand before their numbers acquire legal weight, that is exactly what Lodestellar was built to check.