Sustainability requirements for construction products

The Green Deal is a strategy that is intended to help EU member states become climate-neutral by 2050. It was launched by the European Commission in 2019 and comprises various initiatives for a wide range of policy areas, such as climate, transport, industry, agriculture, and finance. The included initiatives aim to reduce greenhouse gases and create a sustainable society. All individual measures are available on the Legislative train schedule. The most important regulations for construction product manufacturers within the Green Deal can be found below.

The EU taxonomy is a classification system that was created to define the framework conditions for sustainable and environmentally friendly business. It specifies which criteria entrepreneurial activities and products must meet in order for a company or construction project to be considered environmentally friendly. With this information, companies and investors can consciously channel their investments into sustainable projects and at the same time support the Green Deal. There is currently a Investment volume of around 500 billion euros, which is intended exclusively for sustainable topics. Construction projects must meet the requirements of the EU taxonomy in order to be able to receive investments from these money pots.

The EU Construction Products Regulation (Construction Products Regulation, CPR) sets rules for placing construction products on the market in the EU. While in the past only technical requirements had to be proven, in the new version of the regulation, which came into force on January 7, 2025, the disclosure of the carbon footprint will become mandatory step-by-step for each product. The CPR therefore ensures that reliable information about the environmental impact of products is available.

The carbon footprint must currently be stated as part of an Environmental Product Declaration (EPD). For all products that fall under the harmonization of the CPR, the content of an EPD must be published in the future. If the required information is not available, the products may not be placed on the market. In the future, it is expected that the requirements for products will continue to expand to other product categories.

The Ecodesign for Sustainable Products Regulation (ESPR) is part of the European Green Deal and sets precise requirements for various product categories in terms of sustainability. The regulation is intended to strengthen the circular economy and aims to extend the life of products. As part of ESPR, digital product passports (DPP) will be introduced. These make information about the sustainability and environmental impact of products (including the content of the CPR) digitally available and processable. The DPPs are to be introduced in 2026.

The Corporate Sustainability Reporting Directive (CSRD) is an EU directive that regulates companies' sustainability reporting. It came into force on January 5, 2023, and expands the scope of reporting compared to previous regulations. For large companies that are already subject to the non-financial declaration requirement, the CSRD applies for financial years beginning on or after January 1, 2024. From January 1, 2025, other large companies will also be included, while capital market-oriented small and medium-sized companies must prepare for an application from January 1, 2026.

This Directive requires construction product manufacturers to transparently disclose their sustainability practices. This includes analyzing the materiality of their activities and taking into account the principle of double materiality to ensure that both the impact on sustainability and the impact of sustainability on the company are recorded. For the manufacturing industry, the categories ESRS E1 and E5 are particularly essential. In it, companies must provide specific information on their CO2 emissions, climate protection measures, as well as the use of resources and measures to promote the circular economy. In addition, disclosure requirements for pollutant content (E2) and water consumption (E3) may apply.

Since July 1, 2021, the BEG provides buildings with subsidies, provided that they can prove their sustainability over the entire life cycle. Funding is given to projects that meet the criteria of climate-friendly new building (KFN) . There is greater support for buildings that also have a Sustainable Building Quality Label (QNG) .

A prerequisite for BEG funding is always a life cycle assessment (LCA) of the entire building. In this LCA, the CO2 footprints of all construction products used are summed up. The building's CO2 footprint must meet a limit in order to be eligible for funding. In order to achieve the highest level of funding, the building must comply with additional pollutant requirements and other criteria.

To meet these requirements, planners must select building products that publish EPDs with low CO2 footprints and that have met the pollutant requirements.

GRPs play an important role in construction. They show potential buyers and users which raw materials and products are used in a building and provide information about their recyclability, for example. Circularity data is required for all products in order to create building resource passes. Still In 2025, GRPs will become part of the QNG certification and therefore a prerequisite for receiving funding.

To meet these requirements, planners must select construction products whose circularity data has been published.

All these regulations are based on the market's many years of experience with voluntary green building certifications. This includes systems such as DGNB, BNB, LEED or BREEAM. These systems evaluate buildings or construction projects based on various criteria. In order to obtain these certifications, projects must comply with certain CO2 limits, pollutant requirements and circularity indicators, among other things. Green building certifications are currently voluntary, but they already represent an investment volume of around 11 billion euros in Germany.

An essential component of all of the above regulations is the life cycle analysis/life cycle assessment (LCA). EPDs form the basis for this life cycle assessment. It is therefore foreseeable that an EPD will be one of the most important foundations for all construction products in the medium term. Since January 7, 2025, manufacturers have also been gradually required to publish EPD data via CPR.

EPDs will be particularly important for volume-relevant products that are produced more ecologically. Products for which no EPDs are available will gradually no longer be used in projects that want to receive funding for sustainable investments.

By providing product-specific EPDs, manufacturers can already set themselves apart from the competition and prepare for the emerging CPR obligations.

EPEA is happy to help you create EPDs or EPD tools with which you can publish an unlimited number of specific EPDs for all your products, locations and projects in just a few minutes.

So that building products can also be used in sustainable construction projects, it is becoming increasingly important that all installed products comply with the various pollutant limits. These vary greatly depending on requirements and are complex. Manufacturers should prove whether appropriate requirements are met by means of compliance declarations. These are documents in which the manufacturer confirms compliance with the requirements.

Due to the complexity of these requirements, planners are currently very uncertain about this issue. Products that do not clearly demonstrate compliance with these requirements are quickly discarded. The pollutant content of products has played a major role so far, particularly in EU taxonomy, QNG and green building certifications. Products that do not meet the requirements must not be installed. It should be noted that if a single installed product does not meet the pollutant content requirements, the entire building does not meet the requirements. Smaller products, auxiliary materials, and construction chemicals in particular are subject to high requirements.

In order to alleviate this uncertainty for planners, EPEA has developed ProCA: An automated evaluation service that demonstrates compliance with sustainability requirements based on product characteristics and creates compliance declarations.

Current regulatory developments show that all players in the construction industry must adapt to constantly new sustainability and circular economy requirements. One way to prepare yourself for this in a future-proof way is to optimize your own products using the Cradle to Cradle® design principle. This provides a framework for making products completely recyclable and thus sustainable in the long term. Thanks to the holistic approach, optimization in accordance with Cradle to Cradle® has a positive effect on all of the above requirements.

EPEA helps you to optimize and certify your products according to the Cradle to Cradle® principle. Our over 30 years of experience helps you to leave a positive footprint on the environment and society and to develop products that are recyclable.