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EU construction compliance 2026: Navigating Digital Product Passports, EPDs, and Scope 3 decarbonisation
21 January 2026 4 minute read

EU construction compliance 2026: Navigating Digital Product Passports, EPDs, and Scope 3 decarbonisation

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Caroline Peyer
Caroline Peyer Senior Managing Consultant, Environmental Impact Accounting
Leen Labeeuw
Leen Labeeuw Senior Managing Consultant, Environmental Impact Accounting
Pieter Flamand
Pieter Flamand Lead, Real Estate

The EU construction industry is standing on the brink of its most significant regulatory transformation in decades.

Driven by the revised Construction Products Regulation (CPR) and the introduction of the Digital Product Passport (DPP), the rules of the game are changing. These aren't just incremental tweaks to existing policies; they are a fundamental shift in how products are designed, manufactured, and tracked.

If you are a manufacturer or developer, the clock is already ticking. With gradual implementation starting in 2026, the transition from voluntary "green" initiatives to mandatory, verified environmental reporting is no longer a distant prospect; it is a business imperative.

The challenge: A fog of terminology and tightening timelines

In boardrooms across Europe, there is a palpable sense of urgency, yet it is often clouded by confusion. Many in the construction industry understand that sustainability is the goal, but the roadmap is cluttered with acronyms that are frequently used interchangeably.

We see it every day: a producer believes their internal Product Carbon Footprint (PCF) is enough to win a contract, only to find the developer requires a third-party verified Environmental Product Declaration (EPD). Or a builder assumes that Life Cycle Assessment (LCA) is just another word for carbon footprinting.

This confusion is more than a linguistic slip; it is a commercial risk. Without a clear grasp of these tools, businesses could face:

  • Loss of market access: Failing to meet the strict transparency requirements of the EU's Article 6 and the revised CPR.
  • Supply chain friction: Inability to provide the data that clients need for their Scope 3 reporting.
  • Inaccurate decarbonisation claims: Risking "greenwashing" accusations due to lack of verified data.

What this means for you: The end of "business as usual"

For construction companies, providing detailed, verified data is transitioning from a "nice-to-have" marketing edge to a regulatory "must-have."

If you are in the built environment sector, such as a developer, a major contractor, or an infrastructure investor, your world is becoming data-driven. You are now being held accountable for the Global Warming Potential (GWP) of your entire project. To meet your own decarbonisation targets and comply with the Energy Performance of Buildings Directive (EPBD), you need granular, verifiable data from every link in your supply chain.

Without verified data (EPDs) from your suppliers, calculating the life-cycle environmental impact of a new building becomes impossible. Investors and regulators are no longer accepting estimates; they demand supply chain transparency and carbon disclosure that stands up to scrutiny.

Demystifying the assessment toolkit

To prepare for 2026, we must first clear the air. While these four terms are related, they serve very different purposes in the journey toward sustainable construction products.

Assessment

What it is

What it covers

Primary use

Life Cycle Assessment (LCA)

The scientific methodology.

Broad: Acidification, water use, ozone depletion, and carbon, among others.

Internal R&D, foundation for EPDs, and can be communicated externally (with third-party verification).

Product Carbon Footprint (PCF)

A subset of the LCA.

Narrow: Specifically focuses on climate change or GWP.

Internal benchmarking of carbon impact.

Environmental Product Declaration (EPD)

The verified "Passport".

Full LCA results, standardised and third-party verified.

B2B transparency, EU compliance, and project tenders.

Digital Product Passport (DPP)

The digital system to store, carry, and communicate data throughout the product's life cycle.

EPD data and the circularity information (i.e., repair, disposal, chemicals, material origin).

Regulatory compliance, such as EU Ecodesign for Sustainable Products Regulation (ESPR), consumer transparency, and end-of-life recycling.

The Life Cycle Assessment (LCA) & Product Carbon Footprint (PCF)

An LCA is a comprehensive evaluation of a product's environmental impact across its entire lifespan, from raw material extraction to end-of-life disposal (cradle-to-grave). Meanwhile, the PCF is essentially the "climate change" chapter of that assessment. While the PCF is vital for understanding your carbon footprint, an LCA is broader, looking at how a product affects water quality, soil acidity, and resource depletion, among others.

The Environmental Product Declaration (EPD) & Digital Product Passport (DPP)

Think of the EPD as the "nutrition label" for building materials. It is a transparent, standardised document that has been verified by an independent third party, and does not include confidential information. The EPD provides the specific environmental performance data (such as carbon footprint), which, along with additional information such as material composition and recyclability populates the environmental sections of the DPP. The DPP effectively makes the EPD data accessible to actors along the value chain, from supply chain businesses to consumers and recyclers.

In the eyes of the EU and major contractors, the EPD is the only "currency" that counts. It enables:

  1. Downstream comparison: Architects and engineers can compare the environmental performance of "Material A" vs "Material B" with confidence.
  2. Upstream optimisation: Manufacturers can identify "hotspots" in their production line to reduce costs and impact.
  3. Digital integration: The data within an EPD will be the lifeblood of the DPP, allowing for seamless data flow across the supply chain.

Three steps to future-proof your business

The transition to green building and mandatory compliance doesn't have to be overwhelming. Success lies in a proactive, three-pronged strategy.

1. Align with the new regulatory reality

1. Align with the new regulatory reality

The revised CPR and Article 6 are reshaping the industry. As a product manufacturer, you must move beyond viewing sustainability as a corporate social responsibility (CSR) task and start viewing it as a core compliance function.

2. Prioritera kvalitet och transparens

2. Prioritera kvalitet och transparens

I en värld med obligatorisk rapportering är data som är "tillräckligt bra" inte längre tillräckligt. Ett åtagande för högkvalitativ datainsamling via EPD:er bygger ett djupt förtroende hos dina kunder. När en utvecklare vill minska sina Scope 3-utsläpp, kommer de att söka sig till den leverantör som kan tillhandahålla en verifierad, digitalt redo EPD snarare än en som erbjuder vaga "miljövänliga" påståenden.

3. Leverage digital tools for data management

3. Leverage digital tools for data management

The sheer volume of data required for sustainable materials management is too vast for spreadsheets. You need to assess digital platforms that can streamline the calculation of LCAs and the management of your EPD portfolio. Digital tools are the backbone of the Digital Product Passport, ensuring that your building materials data is accessible, accurate, and ready for the 2026 deadline.

Final thoughts: From compliance to competitive advantage

The 2026 deadline for verified product carbon footprints and environmental data is not just a hurdle to clear, it is an opportunity to lead. By embracing EPDs and understanding the nuances of the Digital Product Passport, you aren't just ticking a box for EU compliance; you are securing your place in a future where transparency is the primary driver of value in the construction industry.

The shift toward sustainable construction products is accelerating. The question is: will your business be providing the data the market demands, or will you be left behind in the search for supply chain transparency?

Ready to navigate the complexities of the new regulatory landscape?
Caroline Peyer, Senior Managing Consultant, Environmental Impact Accounting

Ready to navigate the complexities of the new regulatory landscape?

Our experts can help match the right tools, such as LCAs, PCFs, and third-party verified EPDs, to your product portfolio and decarbonisation objectives.

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