capinorium · Article · Construction & real estate

The new Construction Products Regulation: environmental data, product passport and what AI can realistically do

By Rudy WinklhoferPublished 18 May 20265 min read

Pencil illustration: inspector scanning labels on brick, concrete and insulation samples

The new EU Construction Products Regulation requires manufacturers to state the global warming potential of their products in the declaration of performance and conformity, formally since 8 January 2026. In practice, however, this obligation only takes effect once a new harmonised technical specification becomes binding for the product family concerned. According to the available sources, this had not happened for any family by October 2026. The delegated act needed for the digital product passport is still outstanding. AI mainly helps to collect and structure manufacturers' data. It does not replace the prescribed calculation or verification.

For mid-sized construction product manufacturers, this is an uncomfortable position. Regulation (EU) 2024/3110 applies and the deadlines are in the text, but the actual date for a company's own range is open. Those who wait risk bottlenecks in data and verifiers. Those who invest in tools too early may build for the wrong format. The following assessment separates applicable law from pending legal acts. It is not a substitute for legal advice.

The obligation is in the law; the date depends on the standard

Article 15 of the regulation sets out a phased plan. The declaration of performance and conformity (DoPC) must contain environmental information over the life cycle: global warming potential (GWP) from 8 January 2026, further indicators such as acidification or resource use from 9 January 2030, and characteristics such as particulate matter or human toxicity from 9 January 2032. Annex II lists 19 characteristics in total. They are calculated with free software provided by the European Commission.

The German Institute for Building Technology (DIBt) makes clear that the GWP declaration is only mandatory when an assessment basis under the new law exists. It does not apply to products under old harmonised standards. Under Article 5(8), new standards only become binding by implementing act one year after their adoption.

The Commission's working plan of December 2025 gives indicative dates: precast concrete and structural steel products first, cement at the end of 2027, windows, doors, insulation, glass and structural timber in 2029. According to the consultancy intep (as of October 2026), the Commission has not yet made any standard binding. Even if things go to plan, the GWP obligation for cement would therefore only arise towards the end of 2028. The relevant question is thus not when the regulation applies, but when the standard for your own product family becomes binding.

In 2026, the product passport is an architecture question

Article 22(7) only requires the digital product passport 18 months after a delegated act enters into force. This act was not available in October 2026. Intep gives the second quarter of 2027 as an indicative date, which would mean an obligation at the end of 2028 at the earliest. This date is not confirmed by a primary Commission source.

The legal framework, however, already reveals what is required technically. The passport is to contain the DoPC including environmental information, technical documentation and instructions – machine-readable, structured and not tied to any one provider. It builds on the product passport of the Ecodesign Regulation and is to remain interoperable with Building Information Modelling (BIM). Anyone whose master data, test reports and environmental data are scattered across documents today therefore faces a task that arises regardless of the exact date.

The bottleneck is manufacturers' data

Because the Commission provides the calculation software, the problem is not the calculation but the data situation in the plant: formulations, energy consumption, supplier information. According to the working plan, European background data are deliberately set conservatively. Manufacturers that do not supply their own primary data are therefore likely to come off worse.

There is also pressure from the building side. According to REHVA, the EU Energy Performance of Buildings Directive requires a life-cycle greenhouse gas assessment for large new buildings from 2028 and for all new buildings from 2030. Planners need manufacturer-specific values for this. Environmental product declarations (EPDs) are expensive: at the German Institut Bauen und Umwelt (IBU), the verification of a first EPD alone costs 2,700 euros and a tool-generated EPD 450 euros, with consultancy on top. According to IBU, demand for verification across Europe exceeds the number of verifiers.

The industry's response is divided. A letter from industry associations in August 2026 warns, based on the associations' own estimate, of price increases of up to 15 per cent for windows and doors and calls for software-based procedures instead of repeated external verification. Behind the criticism lies above all the effort per product variant – and that is essentially a data problem.

Where AI helps and where its limits lie

The realistic place for AI is before the calculation. Language models can extract information from safety data sheets, supplier EPDs and bills of materials, map raw materials to datasets in the German ÖKOBAUDAT database and prepare plausibility checks ahead of verification. A study on building life-cycle assessment estimates 80 to 90 per cent less time for text-based material capture, but cites inconsistent terminology as a limitation. The vendor Emidat states that it reduces EPD effort by over 70 per cent. That is a vendor claim; an independent evaluation is lacking.

The limit is drawn by regulation. The values for the DoPC are produced with the prescribed Commission software and assessed by a notified body. Generated substitute data do not replace primary data; the vendor One Click LCA also labels them as generated. AI can therefore speed up preparatory work, but responsibility for the declaration remains with the manufacturer.

This gives a project testable questions: which product family will become binding first? Which of the 19 indicators can be filled from existing data? How high is the error rate of an extraction, measured against expert-checked samples? If you would like to clarify these questions for one product family in a feasibility assessment, capinori can support you as an R&D partner.

Frequently asked questions about the new Construction Products Regulation

From when must manufacturers declare the global warming potential of their construction products?

Regulation (EU) 2024/3110 specifies 8 January 2026 for global warming potential. According to the German Institute for Building Technology (DIBt), however, the declaration only becomes mandatory once a harmonised technical specification under the new law applies to the product family. According to consultancy sources, this was not the case for any family by October 2026.

Which environmental indicators does the new Construction Products Regulation require?

Annex II of Regulation (EU) 2024/3110 lists 19 characteristics. Global warming potential applies in the first stage from 2026, indicators such as acidification, eutrophication and water use from 9 January 2030, and characteristics such as particulate matter and human toxicity from 9 January 2032. Each stage requires a binding harmonised technical specification.

When will the digital product passport for construction products become mandatory?

The digital product passport for construction products becomes mandatory 18 months after a delegated act enters into force. This act was not yet available in October 2026. The consultancy intep gives the second quarter of 2027 as an indicative date; the obligation would then be expected at the end of 2028 at the earliest.

Do manufacturers need an environmental product declaration for the Construction Products Regulation?

According to DIBt, an environmental product declaration (EPD) is not strictly required for harmonised construction products. The environmental values are produced with free software from the European Commission. For building life-cycle assessments and funding programmes, however, planners are already asking for manufacturer-specific environmental data, often in the form of an EPD.

Can AI calculate the environmental information in the declaration of performance and conformity?

No, AI replaces neither the prescribed calculation nor the verification. The values for the declaration of performance and conformity (DoPC) are produced with the European Commission's software and assessed by a notified body. Upstream, AI can extract data from documents, map materials and prepare plausibility checks.

How much effort does AI save on environmental product declarations?

Robust independent figures are lacking. A study on building life-cycle assessment estimates 80 to 90 per cent less time for material capture. The vendor Emidat cites over 70 per cent less effort for environmental product declarations (EPDs); this is a vendor claim that has not been independently verified.

Sources (11)

Rudy Winklhofer is Owner and Director R&D of capinori GmbH.

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