LCA and CE Marking:

The provision of environmental data on construction products is shifting from a voluntary practice to a legislative requirement. The updated Construction Products Regulation (CPR) significantly impacts how environmental performance data is managed and communicated for products requiring CE marking.

Under the updated CPR, products requiring CE marking must now include verified environmental performance data obtained from a Life Cycle Assessment (LCA). Notably, Global Warming Potential (GWP) will become a mandatory part of product declarations whereas other environmental impact indicators will be gradually introduced. The update introduces stricter verification through the Assessment and Verification of Constancy of Performance (AVCP) System 3+, supported by a Declaration of Performance (DoP).

LCA is a systematic approach to quantifying environmental impacts throughout a product’s life cycle, from raw material extraction to disposal. Manufacturers must include LCA data, initially focusing on climate change indicators, in their DoP. This transparency enables stakeholders to objectively compare products based on their environmental performance. Independent third-party verification is required in the AVCP System 3+ and must be conducted by Notified Bodies, which will be independent organisations authorised and recognised by EU Member States.

Starting from January 2026, manufacturers must report total, fossil-based, and biogenic climate change indicators. By January 2030, additional impact categories such as ozone depletion, acidification, and eutrophication potential will become mandatory. Finally, from January 2032, assessments will expand further to include indicators such as human toxicity, particulate matter, and land use.

Consider these key aspects:

• Cover the full life cycle and use relevant data: LCA calculations must capture the entire life cycle of a product, from raw material extraction to end-of-life treatment. The input data should be reliable, representative, and up to date.
• Follow the product-specific standard: Each construction product will have a harmonised European standard specifying the requirements for environmental performance data. When conducting an LCA, ensure compliance with the applicable standard for your product category.
• Align with Circular Economy principles: LCA should assess product durability, recyclability, and potential for reuse. Be sure to include how the expected lifespan is calculated, possible repair and maintenance scenarios, and the relevant end-of-life scenarios. Additionally, for reused products the deinstallation and dismantling processes before their second life cycle should be covered too.
• Prepare for expanded LCA indicators: Beyond climate change impacts, future regulations will phase in additional environmental indicators. The commonly used Product Category Rules (PCR) for construction products, EN 15804+A2, already allows for assessing these impact categories.
• Integrate with Digital Product Passports (DPPs): Environmental performance data will be incorporated into Digital Product Passports (DPPs), creating a transparent, digital record of a product’s environmental footprint. Preparing your data for this integration early will help streamline future compliance.

If you want to proactively prepare for the CPR, fill in our contact form or schedule a call with one of our experts. We regularly work with construction products such as steel and aluminium door and window frames, float glass windowpanes, door systems, flooring systems, roofing solutions, and many more. With over 10-years of experience in this sector we can efficiently help you by conducting the LCA study for the environmental performance data you need for your CE marking.