Construction Products Regulation (CPR)
The Construction Products Regulation (CPR) sets out the conditions under which construction products may be traded on the European market, and what information manufacturers must provide in doing so. This page is intended for producers, LCA practitioners and advisers who want to know what the revised CPR means for the environmental information of construction products.
The Construction Products Regulation has been revised: CPR 2024/3110 replaces the earlier CPR from 2011. The revision adds an eighth basic requirement, aimed at sustainable use of natural resources, and is being introduced in phases. Manufacturers record product performances in a declaration of performance, referred to as DoP. With the revision, it becomes possible to also link limit values to this, which is one of the reasons why the DoP is extended to the DoPC. Stichting NMD closely follows this development and maps out how these European requirements relate to the existing environmental impact categories within the Environmental Performance Assessment Method for Construction Works.
From CPR 2011 to CPR 2024
The CPR has been revised. CPR 2024 (Regulation (EU) 2024/3110) replaces the earlier CPR from 2011 and has meanwhile entered into force. Reasons for the revision included, among other things, shortcomings in existing harmonised standards and a prolonged stagnation in the publication of new standards since 2018.
Eighth basic requirement: sustainable use of natural resources
The revised CPR reorders the structure of Annex I, creating an eighth specific stand-alone basic requirement for construction works: sustainable use of natural resources. This requirement has been elaborated in predetermined essential environmental characteristics.
Phased introduction
The CPR 2024/3110 has 2 important timelines. The first timeline concerns the order in which the product families receive new standards. The second timeline is about the environmental indicators under the revised CPR. These become mandatory in phases: a part (focus on CO2) immediately upon entry into force of the CPR, a part after four years, and the last part after six years. Full implementation across all product families is expected around 2031.
Declaration of Performance: DoP and DoPC
Manufacturers record the performances of a construction product in a Declaration of Performance (DoP). A DoP describes the performances a purchaser of the product may expect, whether or not under limiting conditions. With the revised CPR, the DoPC emerges (DoP supplemented with a Declaration of Conformity, DoC): this also makes it possible to link limit values to these performances. The DoPC is mainly aimed at the purchaser of a product, so that they can assess whether the product is suitable for the intended purpose, for example achieving a limit value at building level. The responsibility for a correct DoPC lies with the producer.
AVCP level
The AVCP system (Assessment and Verification of Constancy of Performance) has been replaced by AVS (Assessment and Verification Systems). This shows many similarities with the AVCP system in which the roles have been established: who determines the performances of a product and who confirms them. Under the revised CPR, more responsibility lies with the producer. For environmental data, a system 3+ applies. This means that the environmental data must be validated by a notified body (Notified Body). An exception is when values are published by a decision of the EC (Commission Decision) that require no further investigation. This is currently not yet the case.
What does this mean for the NMD system?
The environmental indicators from the revised CPR (Annex II) correspond well in terms of subject matter to the nineteen environmental impact categories that the Environmental Performance Assessment Method for Construction Works already applies via environmental data set A2. The requirements under the CPR do not yet offer the same consistency and therefore the same comparability of products based on the DoPC. Stichting NMD is investigating how this European development further relates to the Dutch system, and keeps the sector informed of relevant changes.
Veelgestelde vragen
A DoP only describes the performances of a product. A DoPC adds to this that, on the basis of the product standard, mandatory limit values must be substantiated for those performances.
The DoPC is relevant for producers and for purchasers of construction products throughout the entire construction chain. The DoPC is used when making product choices in relation to the design, and by purchasers (contractors and buyers) as proof of required performances. LCA practitioners are service-providing suppliers to the producer and do not themselves bear responsibility for the correctness of the DoPC.
The CPR 2024 is in force, but as long as no new harmonised standards under the CPR 2024 yet exist for a product family, the rules from the CPR 2011 remain applicable for that product family. For the most up-to-date status per product family, we refer to Contactpunt Bouwproducten (Construction Products Contact Point).