ESPR 2024/1781 and CPR 2024/3110 are in force. Product-specific DPP obligations arrive through harmonised standard delegated acts. Cement, structural steel, and precast concrete are the first wave — estimated Q4 2026 for the trigger, Q2 2028 for mandatory compliance.
Milestones
Recast of the original CPR, establishing the legal basis for DPP requirements on CE-marked construction products. Aligns with ESPR's DPP framework. CE marking obligations begin transitioning over 36-month implementation period.
ESPR replaces the Ecodesign Directive and establishes the EU-wide DPP framework. It does not impose immediate DPP obligations — those arrive through product-specific delegated acts. Construction products are in scope.
CBAM full enforcement covers steel, cement, aluminium, fertilisers, electricity, and hydrogen. Importers must purchase CBAM certificates. Embedded carbon documentation — closely related to EPD/PCF data — becomes a commercial necessity for non-EU suppliers.
California's Buy Clean Act requires EPD-backed GWP limits for public procurement of structural steel, flat glass, mineral wool, and carbon steel rebar. Further product expansion anticipated for 2026 procurement cycles, driving North American EPD demand.
The harmonised standard (hEN) for cement under EN 197 series is expected to reference DPP data requirements via a CPR/ESPR delegated act. Once the delegated act is published, an 18-month transition period begins before DPPs become mandatory for CE-marked cement.
The EN 10025 series hEN delegated act is expected to trigger DPP obligations for structural steel sections, plates, and hollow sections. The same 18-month transition window applies.
EN 13369 (general precast) and related product-specific precast hENs are expected to trigger DPP obligations simultaneously with cement, given shared supply chain and CE marking base.
EN 13162–13171 cover mineral wool, EPS, XPS, PUR/PIR, and other insulation product types. The delegated act is expected approximately one quarter after the structural products wave.
Assuming a Q4 2026 delegated act for cement, the mandatory DPP obligation for CE-marked cement placed on the EU market becomes active approximately Q2 2028. Products without a valid DPP cannot carry CE marking.
Same 18-month transition window as cement applies. From this date, structural steel sections and precast concrete products marketed in the EU require a valid DPP to carry CE marking.
Assuming Q1 2027 delegated act for insulation, the mandatory DPP obligation becomes active approximately Q3 2028. Applies to all insulation product types covered by the EN 13162–13171 series.
How it works
ESPR does not impose DPP obligations directly on construction products. Instead, it establishes the framework and delegates the product-specific trigger to the European Commission through delegated acts, which reference harmonised standards (hENs) already used for CE marking under CPR.
The European Commission instructs a standards body (CEN) to update a harmonised standard to include DPP data requirements. For cement, this is the EN 197 series. For structural steel, EN 10025.
The Commission adopts a delegated act under ESPR/CPR citing the updated hEN. This triggers the 18-month countdown. From this moment, manufacturers should begin preparing DPP systems.
18 months after the delegated act, placing a product on the EU market without a valid DPP means the product cannot carry CE marking. CE marking is required for legal sale in the EU.
Explore more
Each DPP mandate references specific standards for data format, EPD methodology, and digital identification. See the full reference list.