Cement is among the first construction products to face DPP obligations under CPR 2024/3110 and ESPR 2024/1781. Here is why the hEN pathway applies, what data the DPP must contain, and when compliance becomes mandatory.
Why cement needs a DPP
Cement sold in the EU is CE marked under CPR, referencing the harmonised standard EN 197 series. CE marking means the product is already within the CPR/ESPR regulatory scope. Once the European Commission issues a delegated act updating the EN 197 hEN to reference DPP data requirements, all CE-marked cement will require a valid DPP.
This is not optional and cannot be avoided by switching to a different conformity route. The only path to CE marking for cement is via the EN 197 hEN, which will incorporate the DPP obligation.
Cement is also the largest single source of embodied carbon in most construction projects, making it a priority for ESPR's environmental performance objectives. The industry average GWP for CEM I is approximately 720–870 kg CO2e/tonne, representing roughly 8% of global anthropogenic CO2 emissions.
Cement is CE marked under EN 197. The hEN will be updated to include DPP data requirements.
The Commission adopts a delegated act under CPR 2024/3110, triggering the 18-month countdown. Est. Q4 2026.
From ~Q2 2028, placing CE-marked cement on the EU market without a valid DPP is non-compliant.
GWP benchmarks
GWP A1–A3 in kg CO2e per tonne of cement. Values are indicative ranges based on published EPDs and industry averages. Actual product GWP depends on clinker factor, SCM source, and kiln energy mix. The DPP contains the verified product-specific value.
Ranges indicative only. Actual values vary by geography, fuel mix, and production technology. Source: published EN 16908 EPD data.
PCR reference
All cement EPDs produced for CE marking must follow EN 16908:2017, the Product Category Rules for cement and building lime supplementary to EN 15804. EN 16908 defines the system boundary, the declared unit (1 tonne at factory gate), treatment of co-products (GGBFS, fly ash), and cement-specific reporting rules.
EPDs from different manufacturers produced to EN 16908 are directly comparable — the PCR ensures the same methodology was followed. The DPP must include a reference to the PCR (EN 16908:2017) used for the underlying LCA.
EN 16908 is currently under revision to align with EN 15804+A2:2019. Manufacturers should ensure their EPD programme operator is using the current version.
1 tonne of cement at factory gate
Minimum A1–A3 (cradle-to-gate). A4 and D (recycling potential) recommended.
GGBFS receives a low allocation of embodied carbon from blast-furnace production — this is why CEM III cements have dramatically lower GWP than CEM I.
Cement FAQ
CEM III/C (81–95% GGBFS) has the lowest GWP of the standardised cement types, typically 100–180 kg CO2e/tonne. CEM III/B is the most widely available low-carbon option at 180–280 kg CO2e/tonne — down from ~720 kg for CEM I. The reduction comes from replacing clinker with GGBFS, a co-product of blast-furnace iron production that carries minimal embodied carbon.
GGBFS availability depends on continued blast-furnace iron production. As the steel industry decarbonises via electric arc furnace (EAF) routes, GGBFS supply will decline over time. The construction industry is actively developing alternative SCMs (calcined clays, natural pozzolans) as long-term replacements. DPP data tracks the SCM composition of each cement batch, enabling downstream monitoring of this transition.
Per EN 16908:2017, the declared unit for cement EPDs (and by extension, DPPs) is 1 tonne of cement at the factory gate. Environmental indicator values in the DPP are expressed per tonne, including GWP A1–A3, A4 (transport), and where declared, modules B–D.
The CPR/ESPR delegated act for cement (referencing the EN 197 hEN) is estimated for Q4 2026. Once the delegated act is published, an 18-month transition period begins. Mandatory DPP compliance for CE-marked cement placed on the EU market is therefore estimated from approximately Q2 2028.
EN 16908 and EN 15804+A2 require declaration of at minimum modules A1–A3. Additional modules (A4, A5, B1–B7, C1–C4, D) should be declared where the data is available and material. For cement, A4 (transport to ready-mix plant) and D (GGBFS credits) are often declared. The DPP must clearly state which modules are declared and which are not.
Find cement EPDs
The Terrave Atlas indexes cement EPDs from manufacturers across Europe and North America. Filter by cement type, GWP, country of production, and EPD programme.