No, GWP has not been mandatory in the declaration of performance since January 2026. The Construction Products Regulation (EU) 2024/3110 has applied since 8 January 2026, but the carbon footprint only becomes mandatory family by family, one year after the act that makes the harmonised standard mandatory. For cement, the first family concerned, this act is planned for the end of 2027, so the obligation would fall at the end of 2028.
Many websites say the opposite. This mismatch leads manufacturers into two mirror-image mistakes: panicking for nothing, or thinking they are safe until 2030. This guide puts the dates back in order.
What Regulation 2024/3110 says
Regulation (EU) 2024/3110 replaces Regulation 305/2011. Its core has applied since 8 January 2026 (article 96). Article 94 repeals the old text on that date, except for a series of articles maintained until 8 January 2040. These apply only to products still covered by old standards or old assessment documents (article 95, paragraph 8).
The new element that matters for EPDs is in Annex II. It lists the environmental characteristics to be declared, starting with four climate change indicators: total, fossil, biogenic and land use GWP. This information goes into the declaration of performance and conformity (DoPC), which replaces the current DoP.
Why GWP is not yet mandatory
The regulation sets the list of indicators, not the date on which each product must declare them. An obligation only applies to a family one year after the implementing act that makes its harmonised standard mandatory, unless the act sets a later date (article 5, paragraph 8, and article 95, paragraph 9). Before that, a manufacturer may apply the standard voluntarily.
As of 2 November 2026, the Commission's page states that existing standards remain those cited under the old regulation until they are replaced, and that the first to become mandatory will probably be those for cement, in 2027. No family therefore has a GWP obligation yet: nothing requires you to declare one in a DoPC.
The real timeline, family by family
On 16 December 2025 the Commission adopted its 2026-2029 working plan, reference COM(2025) 772. It gives the order of work and indicative dates by family. Precast concrete and structural metal products come first, but their standards are planned initially under the old regulation. Cement is thus the first family expected under the new one.
| Stage | Families or content | Deadline |
|---|---|---|
| Application of the core CPR | All products covered | 8 January 2026 (article 96) |
| Citation under the old regulation | Precast concrete; structural metal products | Planned Q4 2025 and Q2 2026 (working plan) |
| First standard made mandatory under the CPR 2024 | Cement, lime, binders | Act planned Q4 2027 (working plan), obligation one year later |
| Following families | Chimneys in 2028; windows, doors, reinforcing steel, insulation, flat glass, structural timber in 2029 | Date of the act, obligation one year later |
| National penalties | All Member States | Rules to be notified to the Commission before 8 December 2026, article 92 applicable on 8 January 2027 |
| Annex II indicators e to m | Ozone, acidification, eutrophication, resources, water | 9 January 2030 (article 15) |
| Indicators n to s, so the complete set | Particulate matter, radiation, toxicity, ecotoxicity, land use | 9 January 2032 (article 15) |
| Construction digital passport | Delegated act under article 75 | No date in the regulation, passport due 18 months after the act enters into force |
The Commission remains cautious: it writes that the first mandatory standards will "probably" be those for cement, in 2027. That date refers to the act, not yet to the manufacturers' obligation. Its first annual progress report is expected at the end of 2026 and will give real visibility for 2027. The 2030 and 2032 dates come on top of this family-by-family timeline.
How GWP will be calculated
The regulation does not simply refer to EN 15804+A2. Its article 15 requires a life cycle calculation, packaging included, using the Commission's free software, whose updates become mandatory one year after publication. Recital 7 links this software to the characterisation factors of EN 15804 or of future applicable standards.
Verification goes through System 3+, created for environmental sustainability (Annex IX, point 4). The manufacturer carries out the assessment. The notified body validates the input data, the assumptions, the calculation and the use of the software, inspects the factory for company-specific data, then issues a validation report.
For a manufacturer, a verified A2 EPD or FDES (fiche de déclaration environnementale et sanitaire, the French environmental and health declaration for construction products) remains a solid basis: the factory data and the life cycle assessment (LCA) model can be reused. That does not mean you can simply carry the figure over. The working plan also provides for c-PCRs and European background data, to be used when company data is missing. Our article on the EN 15804 standard goes through the modules and indicators.
Conversely, an FDES still prepared under A1 no longer offers much. INIES, France's national database of environmental declarations, withdrew these declarations under a timetable that ended on 1 July 2026 for those verified in 2021 and 2022 (INIES notice).
What changes for a manufacturer that already has an FDES or EPD
If your declaration complies with A2, is verified and is up to date, you are ahead. Three points remain to check before your family switches over.
- The validity date. An EPD or FDES is valid for 5 years. If your family is among the first and yours expires in 2028 or 2029, its renewal will fall just as GWP becomes mandatory. You may as well align them.
- The scope. The DoPC will relate to a specific product. A collective declaration or a range average may not cover every reference sold.
- Other programmes. If you export, your EPD must be recognised in the target countries. An FDES is not accepted as it stands everywhere, see our export guide.
If you have no declaration, the CPR is not your only deadline. In France, RE2020, the environmental regulation for new buildings, already applies inflated default data to products with no FDES, which rules them out of clients' calculations. Our article on the gap between default data and FDES puts a figure on this cost.
Decree 2026-17: notified bodies
The CPR is a European regulation and applies directly without transposition. France published Decree No. 2026-17 of 19 January 2026, in force since 21 January. It adds to the Construction Code the procedures for notifying notified bodies, including for System 3+, and the designation of technical assessment bodies.
This decree sets neither penalties nor a DoPC supervisory authority. On this point, article 92 of the regulation asks each State to notify its rules to the Commission before 8 December 2026, for application on 8 January 2027. For a manufacturer, the practical effect of the decree lies elsewhere: it organises the pool of bodies that will validate GWP tomorrow.
The digital passport for construction products
The CPR also provides for a digital product passport, already under way in other sectors through the Ecodesign Regulation (ESPR). For construction, the system will be created by a delegated act (article 75), and the manufacturer will then have 18 months to make the passport available. The regulation sets no date for this act.
This passport will include the product's essential characteristics, including GWP once it is mandatory. A digital, structured EPD will make this transition easier. ECO Platform, which brings together EPD programme operators, is devoting its conference of 17 and 18 November 2026 in Brussels to the CPR, the EPBD and digital passports.
Misconceptions to correct
Several claims about the CPR are circulating, often repeated from one website to another. Here are the most frequent, and the facts.
"GWP has been mandatory in the DoP since January 2026." False. The regulation has applied since that date, but GWP only becomes mandatory one year after the act that makes each family's standard mandatory. As of 2 November 2026, no such act has been adopted, according to the Commission.
"The CPR replaces RE2020." False. The CPR concerns the declaration of products placed on the European market. RE2020 concerns the calculation of new buildings in France. The two meet through data, not through law.
"An FDES will automatically be enough." Not quite. Both rest on EN 15804, but the figure will have to come from the Commission's software, pass validation by a notified body, appear in the DoPC and cover the declared product.
"We have until 2032." Yes for the complete set of indicators, on 9 January 2032. For the four climate indicators, the obligation follows each family's standard: the end of 2028 for cement if the plan holds.
Questions to ask your trade association
Trade federations follow standardisation work at CEN. They are often the first to learn the content of harmonised specifications.
Three useful questions to ask them: on what date does the working plan place your family? Is a collective FDES for the sector planned or up to date? Do the calculation rules of the future harmonised standard differ from the PCR you use today?
The answers will tell you whether your current declaration will pass unchanged or whether to plan a recalculation at the next renewal.
What to do now
The right timeline calls for neither panic nor waiting. It tells you to prepare according to your product family.
| Your situation | Recommended action | Horizon |
|---|---|---|
| Cement, lime, binders | Check that the EPD is A2, up to date and covers each reference, identify a notified body | Before the end of 2027 |
| Precast concrete, structural metal products | Keep the EPD up to date and follow the standards cited under the old regulation, then their move to the new one | 2027 |
| Windows, doors, insulation, flat glass | Update the declaration at its next renewal | Before 2029 |
| Other families | Read the progress report expected at the end of 2026 | End of 2026 |
| No FDES or EPD | Launch a first declaration for RE2020 and public contracts | Now |
For the families affected first, you need to plan ahead: a first EPD takes several months between data collection, LCA and third-party verification. Costs are set out in our article EPD and FDES cost.
The EPD remains the foundation
The CPR does not create a new document: it brings the environmental footprint into the DoPC. The A2 EPD remains the best starting point, since it relies on the same reference standard and the same factory data. To go back over what an EPD is, its framework and its French version, see our guide EPD: definition, framework and the FDES in France.
Releaf Carbon supports construction product manufacturers with their FDES and EPDs, from LCA to publication. To find out where your product family stands and what it means for your declarations, tell us about your project.
Frequently asked questions
No. Regulation (EU) 2024/3110 has applied since 8 January 2026 and lists GWP in its Annex II, but the obligations only take effect for a product family one year after the act that makes its harmonised standard mandatory. As of 2 November 2026, no standard has yet been made mandatory on this basis, according to the Commission.
Cement, lime and binders are the first family expected under the new regulation: the act making their standards mandatory is planned for the end of 2027, and the obligation follows one year later. Precast concrete and structural metal products go through the old regulation first. Windows, doors and insulation are announced for 2029.
The CPR refers to methods derived from standardisation and its recital 7 cites EN 15804, the standard for EPDs and FDES. A verified A2 EPD therefore provides the data and the LCA model. However, the calculation will have to go through the Commission's software and be validated by a notified body before it enters the declaration of performance and conformity.
No. In France, RE2020 already penalises products with no FDES through inflated default data, and public contracts have required an environmental criterion since August 2026. The CPR will add a European obligation, but the commercial need exists today.