Since January 2026, Europe’s construction sector has been operating under a fundamentally revised regulatory framework for construction products. The new Construction Products Regulation (CPR), Regulation (EU) 2024/3110, entered into force in January 2025 and began applying to manufacturers and the market from 8 January 2026. For companies working in repair, reinforcement and structural protection, this is one of the most consequential regulatory changes in years.
The new CPR replaces the 2011 Regulation (EU) 305/2011 and introduces a significantly broader set of requirements — covering not just the technical performance of products, but their environmental footprint, digital traceability, and compliance with sustainability criteria aligned with the European Green Deal.
What Has Changed?
The core logic of the CPR — that construction products incorporated permanently into buildings or civil engineering works must carry a CE marking based on a Declaration of Performance — remains in place. But the scope of what that Declaration must contain has expanded substantially.
The most immediate change for 2026 is the introduction of mandatory environmental reporting. From January 2026, manufacturers of products falling within the first tranche of updated harmonised standards must declare the Global Warming Potential (GWP) of their products — the carbon footprint across the product’s life cycle, calculated in accordance with EN 15804. Concrete, steel and insulation materials are among the priority product families, given their high environmental impact and their central role in construction activity.
This is a phased implementation. A broader set of environmental indicators will become mandatory from January 2030, with full life-cycle environmental reporting required by January 2032. However, companies that wait for 2030 to begin preparing their data infrastructure will find the transition considerably harder.
Digital Product Passports
The revised CPR establishes an explicit legal basis for Digital Product Passports (DPPs) for construction products. A DPP is a digital record accompanying each product and containing its technical performance data, Declaration of Performance, safety information, environmental profile and carbon footprint. The full technical requirements for DPPs will be defined through delegated acts to be published after 2026, but manufacturers are advised to begin building the data management systems that will underpin compliance.
The logic behind the DPP is transparency across the supply chain. In a sector where product performance data is often buried in paper documentation, scannable codes linking to standardised digital records will allow asset owners, specifiers, contractors and regulators to verify product compliance instantly — and will enable the integration of product-level data into building-level carbon reporting under the Energy Performance of Buildings Directive.
What It Means for Repair and Reinforcement Products
The repair and reinforcement sector uses a wide range of products that are permanently incorporated into structures: repair mortars, injection resins, surface protection systems, structural adhesives, carbon fibre and glass fibre reinforcement systems, corrosion inhibitors, cathodic protection components, and more.
For manufacturers of these products, the implications are clear:
- Environmental data collection: calculating and documenting GWP and other life-cycle indicators requires reliable data on raw materials, manufacturing processes and product composition. Environmental Product Declarations (EPDs), prepared in accordance with EN 15804, are the preferred tool.
- Harmonised standards: compliance under the CPR depends on the availability of updated harmonised standards for each product family. The 2026–2029 Work Plan for harmonised standards has been published, but the pace of standard development means that some product categories will enter scope progressively. Manufacturers should monitor the publication of relevant standards closely.
- Declaration of Performance: the DoP template has been updated to accommodate the new environmental characteristics. Existing DoPs must be revised as applicable harmonised standards come into force.
- Digital readiness: even before DPP requirements become binding, companies that invest in digital product data management now will be better positioned to comply as requirements tighten.
Alignment with Other EU Legislation
The new CPR does not exist in isolation. It is designed to feed into the broader EU sustainability and transparency framework. Product-level environmental data declared under the CPR will be used in building-level GWP calculations required under the EPBD. It aligns with the EU Taxonomy Regulation’s criteria for sustainable construction activities. And it connects with the Corporate Sustainability Reporting Directive (CSRD), which requires large companies to report on the environmental performance of their supply chains.
For companies in the repair and reinforcement sector — many of which supply products that are specifically chosen for their ability to extend the service life of existing structures and avoid the much higher environmental cost of demolition and reconstruction — the CPR framework offers an opportunity to demonstrate the sustainability credentials of the work the sector does. Repair is, by its nature, a low-carbon choice. The data required by the new CPR is the means to prove it.
ACRP’s Role
ACRP is following the implementation of the new CPR closely and is engaged in discussions at European level on the development of harmonised standards relevant to repair, reinforcement and protection products. Members with questions about how the new requirements apply to their specific product categories are encouraged to reach out to the association or to raise the topic in the relevant working groups.