Support contract for inclusion of climate aspects in the revision of the Construction Products Regulation acquis : final report on the outcomes of Work Package 1 : assessment of pros and cons of methodological approaches for climate relevant product information in the CPR acquis.
Date: 2025-04-29
Institutions: Directorate-General for Climate Action
Subjects: EU Emissions Trading Scheme, building performance, building regulations, construction policy, ecological footprint, environmental impact, product life, quality label, regulation (EU), report, sustainable development

Support contract for inclusion of 
climate aspects in the revision of 
the Construction Products 
Regulation acquis
Assessment of pros and cons of methodological 
approaches for climate relevant product information in 
the CPR acquis 

April – 2025 

EUROPEAN COMMISSION 

Directorate-General for Climate Action  
Directorate A - Strategy, Analysis & Planning 
Unit  C1 - Low carbon solutions (I): Montreal protocol, clean cooling and heating, digital transition 

Contact: Sven DAMMANN 
E-mail:  Sven.DAMMANN@ec.europa.eu

CLIMA-C01-ARES@ec.europa.eu

European Commission 
B-1049 Brussels

LEGAL NOTICE 

Printed by OIB in Belgium 

Manuscript completed in April 2024 

This document has been prepared for the European Commission however it reflects the views only of the 
authors, and the Commission cannot be held responsible for any use which may be made of the information 
contained therein. 

More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2025 

PDF 

ISBN 978-92-68-26846-9 

doi: 10.2834/2241079 

 ML-01-25-024-EN-N 

© European Union, 2025 

The reuse policy of European Commission documents is implemented by Commission Decision 2011/833/EU of 
12 December 2011 on the reuse of Commission documents (OJ L 330, 14.12.2011, p. 39). Unless otherwise 
noted, the reuse of this document is authorised under a Creative Commons Attribution 4.0 International (CC BY 
4.0) licence (https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed provided 
appropriate credit is given and any changes are indicated. 

For any use or reproduction of photos or other material that is not under the copyright of the European Union 
(*), permission must be sought directly from the copyright holders. 

Support contract for inclusion of climate 
aspects in the revision of the Construction 
Products Regulation acquis 

Final report on the outcomes of Work Package 1: Assessment of pros and cons of 
methodological approaches for climate relevant product information in the CPR 
acquis 

Prepared for: 

European Commission - DG Climate Action 

Supervising Commission Policy Officer: Sven Dammann, PhD 

Submitted by: 

Guidehouse Germany GmbH 

Albrechtstraße 10 c 

10117 Berlin, Germany 

+49 30 7262 1410 

Service request No. 2023/16 

Reference No. 225125 

28 February 2025 

This deliverable was prepared by Guidehouse for the sole use and benefit of, and pursuant to a client relationship exclusively with 
European Commission. The work presented in this deliverable represents Guidehouse’s professional judgement based on the 
information available at the time this report was prepared. Guidehouse is not responsible for a third-party’s use of, or reliance upon, 
the deliverable, nor any decisions based on the report. Readers of the report are advised that they assume all liabilities incurred by 
them, or third parties, as a result of their reliance on the report, or the data, information, findings and opinions contained in the 
report. 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table of Contents 

List of Abbreviations ................................................................................................. 6 

Executive summary ................................................................................................... 7 

1. Introduction ............................................................................................................ 9 

1.1 Objective and structure of this report ....................................................................... 9 

1.2 Overview of the most relevant EU policies, legislation, and standards ................... 10 

1.3 Selected methodological approaches .................................................................... 17 

1.4 Overview of product families .................................................................................. 22 

2. Assessment aspects ........................................................................................... 37 

2.1 GHG & product coverage [Aspects 1a, 1b, 1c, 1d, 1e, 1f] ...................................... 38 

2.2 Data quality [Aspects 2a, 2b, 2c] ............................................................................ 41 

2.3 Feasibility of implementation [Aspect 3a, 3b] ......................................................... 43 

2.4 Compatibility [Aspect 4a, 4b] ................................................................................. 44 

2.5 Additional aspects [Aspect 5a, 5b, 5c] ................................................................... 45 

3. Analysis of the different approaches ................................................................. 48 

3.1 PEF ....................................................................................................................... 48 

3.2 EN 15804+A2 EPDs (type III EPD) ........................................................................ 59 

3.3 EU ETS ................................................................................................................. 70 

3.4 CBAM .................................................................................................................... 78 

3.5 Innovation Fund methodology ................................................................................ 85 

3.6 PCF for intermediate products ............................................................................... 92 

3.7 Fit-for-purpose hybrid approach ............................................................................. 92 

3.8 Comparative overview ........................................................................................... 94 

4. Conclusion ......................................................................................................... 103 

5. Appendix ............................................................................................................ 106 

5.1 Overview of international and European standards for LCA in buildings and 

construction products ........................................................................................ 106 

5.2 List of PCR documents published and under development .................................. 107 

5.3 List of national EPD requirements in Europe ........................................................ 109 

5.4 EU ETS emission factors overview ...................................................................... 110 

5.5 Common databases for EPDs ............................................................................. 112 

5.6 RFNBO Delegated Acts ....................................................................................... 113 

Confidential information for the sole benefit and use of the European Commission. 

Page 2 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

List of Tables 

Table 1. Overview of product families addressed in this study .............................................. 22 

Table 2. Percentage share of fossil GHG emissions in each module (excl. stage B and D) for 
an example EPD of M100 product family based on Consolis Parma precast concrete beam 
pre-stressed (HUB-1635) (absolute values rounded). ........................................................... 24 

Table 3. Percentage share of fossil GHG emissions in each module for an example EPD of 
M120 product family based on Galvanized Structural Steel (absolute values rounded). ....... 25 

Table 4. Overview of cement types and their clinker contents .............................................. 27 

Table 5. Percentage share of fossil GHG emissions in each module for an example EPD of 
M114 product family based on White Portland-slag cement (absolute values rounded)........ 27 

Table 6. Percentage share of fossil GHG emissions in each module for an example EPD of 
M103 product family based on mineral wool insulation, (absolute values rounded). ............. 29 

Table 7. Percentage share of fossil GHG emissions in each module for an example EPD of 
M103 product family based on Loose fill cellulose insulation51 (absolute values rounded). . 30 

Table 8. Percentage share of fossil GHG emissions in each module for an example EPD of 
M103 product family based on HT/ArmaFlex insulation (Foam insulation) (absolute values 
rounded). .............................................................................................................................. 31 

Table 9. Percentage share of fossil GHG emissions in each module for an example EPD of 
M135 product family based on thermally toughened safety glass (absolute values rounded)
 ............................................................................................................................................. 33 

Table 10. Percentage share of fossil GHG emissions in each module for an example EPD of 
M113 product family based on multi-layer parquet (absolute values rounded) ...................... 34 

Table 11. Percentage share of fossil GHG emissions in each module for an example EPD of 
M112 product family based on strength-graded and finger-jointed structural timber. (absolute 
values rounded).................................................................................................................... 36 

Table 12. Overview of assessment aspects .......................................................................... 37 

Table 13. Factors under the aspect of data quality assurance .............................................. 42 

Table 14. Factors under assessment aspect “measures against fraud” ................................ 43 

Table 15. Factors under assessment aspect “feasibility of implementation for manufacturers 
& customers” ........................................................................................................................ 43 

Table 16. Factors under assessment aspect “feasibility of implementation for authorities” ... 44 

Table 17. Components under assessment aspect “compatibility with EPBD” ....................... 45 

Table 18. Factors under assessment aspect “Consideration of energy system aspects ” ..... 47 

Table 19. Overview of PEF methodology ............................................................................. 48 

Table 20. Analysis of the PEF methodology ......................................................................... 50 

Table 21. Coverage of the analysed product families under PEFCR .................................... 58 

Table 22. Overview of EN 15804+A2 EPDs ......................................................................... 59 

Table 23: EN 15804+A2 (EPD) methodology analysis and key findings. .............................. 61 

Table 24. Coverage of the analysed product families under EN 15804 ................................. 70 

Confidential information for the sole benefit and use of the European Commission. 

Page 3 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 25. Overview of EU ETS ............................................................................................. 71 

Table 26. EU ETS methodology analysis and key findings ................................................... 73 

Table 27. Coverage of the analysed product families under EU ETS .................................... 78 

Table 28. Overview of CBAM ............................................................................................... 79 

Table 29. CBAM analysis and key findings ........................................................................... 81 

Table 30. Coverage of the analysed product families under CBAM ...................................... 85 

Table 31. Overview of Innovation Fund (IF) GHG avoidance calculation methodology ......... 86 

Table 32. Analysis of the Innovation fund methodology based on the pre-defined assessment 
aspects. ................................................................................................................................ 88 

Table 33. Coverage of the analysed product families under Innovation Fund methodology .. 91 

Table 34. Key environmental performance categories for comparative assessment of 
construction products ........................................................................................................... 93 

Table 35. System boundaries (Scope 1/2/3) in the different methods ................................... 96 

Table 36. Comparative overview of the components for a fraud resilient implementation ..... 99 

Table 37. Overview of international and European standards related to the assessment of the 
life cycle-related environmental performance of buildings and construction products ......... 106 

Table 38. National EPD requirements ................................................................................ 109 

Table 39. Emission Factors Benchmarks across different products .................................... 110 

Table 40. List of common databases for EPD and embodied emission factors of construction 
materials ............................................................................................................................ 112 

Table 41. Overview of Renewable Fuels of Non-Biological Origin (RFNBO) Delegated Act 114 

Confidential information for the sole benefit and use of the European Commission. 

Page 4 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

List of Figures 

Figure 1: Overview of the most relevant EU policies, legislation, and standards for the 
inclusion of climate aspects in the CPR acquis (own illustration) .......................................... 14 

Figure 2. Overview of relevant methodological approaches (own illustration) ....................... 18 

Figure 3. Life-cycle stages of a construction product within in a building life cycle (adopted 
from EN 15804+A2).............................................................................................................. 19 

Figure 4. Life cycle assessment framework according to ISO ............................................... 20 

Figure 5. Overview of GHG protocol scopes and emissions across the value-chain ............. 21 

Figure 6: Figure 7. Illustration of different GHG emission (EU ETS and LCA) accounting 
scopes in relation to a product life cycle ............................................................................... 22 

Figure 8. Exemplary supply chain and (cradle-to-gate) for reinforced precast concrete, the 
major emitting steps are circled by a black box. ................................................................... 23 

Figure 9. Exemplary supply chain and (cradle-to-gate) for structural metallic products 
(adapted from Technical Secretariat (2019)), main GHG emissions are circled by a black 
box. ...................................................................................................................................... 25 

Figure 10. Exemplary supply chain of cement production (cradle-to-gate), main GHG 
emissions are circled by a black box. ................................................................................... 26 

Figure 11. Exemplary supply chain of mineral wool production (cradle-to-gate), adapted from 
Knauf Insulation Ltd (2024), main GHG emissions are circled by a black box. ..................... 28 

Figure 12. Exemplary supply chain of cellulose fibre insulation material (cradle-to-gate), main 
GHG emissions are circled by a black box. .......................................................................... 30 

Figure 13. Exemplary supply chain of polystyrene foam-based insulation material (cradle-to-
gate), main GHG emissions are circled by a black box. ........................................................ 31 

Figure 14. Exemplary supply chain for flat glass flat glass adopted from Hartwell et al., main 
GHG emissions are circled by a black box. .......................................................................... 32 

Figure 15. Exemplary supply chain for wood panels (cradle-to-gate), adapted from Raute and 
Yalong, main GHG emissions are circled by a black box. ..................................................... 34 

Figure 16. Exemplary supply chain for structural timber (cradle-to-gate), , main GHG 
emissions are circled by a black box. ................................................................................... 35 

Figure 17. Coverage of products by considered methodologies from high to low.................. 96 

Confidential information for the sole benefit and use of the European Commission. 

Page 5 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

List of Abbreviations 

Abbreviation   Details 
B2B 
B2C 
CPR 
CBAM 
CCS 
CCU 
CDW 

Business-to-Business 
Business-to-Consumer 
Construction Products Regulation 
Carbon Border Adjustment Mechanism 
Carbon capture and storage 
Carbon capture and utilisation 
Construction and Demolition Waste 
European Committee for Standardization (Comité Européen de 
Normalisation) 
Carbon Removals and Carbon Farming 
Energy Efficiency Directive 
Energy-intensive industries 
End of Life 
Energy Performance of Buildings Directive 
Environmental Product Declaration 
Ecodesign for Sustainable Products Regulation 
EU Emissions Trading System 

Greenhouse gas emissions 

Global Warming Potential 
Innovation Fund 
Joint Research Centre 
Life Cycle Assessment 
Life Cycle Inventory 
Life Cycle Impact Assessment 
Land use, land use change and forestry 
Monitoring and Reporting Regulation 
Non-renewable secondary fuels  
Organisation Environmental Footprint Sector Rules 
Product Carbon Footprint 
Product Category Rules 
Product Environmental Footprint 
Product Environmental Footprint Category Rules 
Polyethylene terephthalate 
Recycled carbon fuels 
Renewable Energy Directive 
Renewable liquid and gaseous transport fuels of non-biological origin 
Renewable secondary fuels 
Reference Service Level 
Secondary materials 

CEN 

CRCF 
EED 
EII 
EoL 
EPBD 
EPD 
ESPR 
EU ETS 
GHG 
emissions 
GWP 
IF 
JRC 
LCA 
LCI 
LCIA 
LULUCF 
MRR 
NRSF 
OEFSRs 
PCF 
PCR 
PEF 
PEFCRs 
PET 
RCF 
RED 
RFNBO 
RSF 
RSL 
SM 

Confidential information for the sole benefit and use of the European Commission. 

Page 6 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Executive summary 

The inclusion of climate relevant information in the revised CPR can be seen as a paradigm 
shift, with a potential transformative impact across the whole construction industry. Additionally, 
there is a strong link to the revised EPBD, which requires building level LCAs for new buildings 
following the EN 15798 and Level(s) framework across every lifecycle stage. The basis for this 
building level assessment is formed by climate information on construction product level. 
Different methodologies could be considered to include climate relevant information into the 
CPR acquis. In its current considerations, the CPR acquis builds strongly on EN 15804+A2, 
which is a commonly used framework in this industry. However, concerns on data quality issues 
and flexible rules for carbon footprint assessment pertain. Voluntary EPDs based EN 
15804+A2 interpretation and data quality assurance show to be very versatile in different 
contexts and countries. Other frameworks, which are currently deployed within EU regulation 
like the product environmental footprint (PEF) and the EU Emissions Trading System (EU ETS) 
may offer solutions to these concerns. 

In this work package, a systemic assessment of advantages and disadvantages (“pros” 
and “cons”) of different potential approaches for the inclusion of product carbon 
footprint information in the CPR acquis is provided. The methodologies are analyzed along 
a set of pre-defined assessment aspects that focus on both methodological and procedural 
factors that are pivotal for a robust implementation under the CPR acquis. The assessment 
shows that all considered approaches have certain strength but also weaknesses when 
considering their application for this specific use case in the CPR acquis. None of the 
approaches appears to be a perfect “fit for purpose” approach. While the EN 15804+A2 and 
PEF provide the most comprehensive and product-system-adapted approach to assess 
construction products along their life cycle, uncertainties on primary and secondary data as well 
as slow development of datasets and product specific rules need to be overcome to allow for a 
speedy implementation of a high-quality approach. On the other hand, the well-established EU 
ETS is a readily available regulatory system that requires reporting of highly monitored and 
specific data on GHG emissions for installations covered under the scheme. While the 
installation level data is robust, a direct implementation of EU ETS data into the CPR acquis is 
not possible: calculation steps are needed to convert the climate information from the 
installation level to product level. Furthermore, EU ETS does not cover all construction products 
and requirements under the CPR on different GWP categories cannot directly be fulfilled, since 
biogenic and LULUCF GWP is not directly reported under EU ETS. Product families such as 
wood-based construction products can therefore not adequately be represented under this 
approach. While these findings may hamper the potential for implementation of the data into the 
CPR acquis, the application potential may be particularly relevant for high emitting industries 
such as cement and steel. As these product families emit a large share of their fossil GHG 
emissions at the production stage, an accurate representation of these emitters is of particular 
importance.  

In this report we conclude that a hybrid approach should be developed which allows for the use 
of EU ETS specific emission values under the CPR acquis. The EU ETS installation 
emissions data would need to be proportionally allocated to the product level and could replace 
A1-A3 assessment under CPR. WP 2 will therefore focus on developing case studies for the 

Confidential information for the sole benefit and use of the European Commission. 

Page 7 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

implementation of EU ETS data into the CPR acquis, as well as assessing other relevant 
aspects relevant for a robust inclusion of climate relevant information.  

Confidential information for the sole benefit and use of the European Commission. 

Page 8 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1. Introduction 

1.1 Objective and structure of this report 

In its proposal for the revision of the Construction Products Regulation (CPR), the European 
Commission states that the current CPR is unable to deliver on broader policy priorities 
such as the green transition. To change this and help stimulate demand for low carbon and 
carbon-storing construction products, coherent and transparent information on the climate, 
environmental and sustainability performance of construction products is needed.1  

This study aims to support the inclusion of carbon footprint information into the CPR 
acquis process for harmonised product group standards. The study will particularly support 
the work of Subgroup 5 - Environmental sustainability of construction products.2 The study will 
perform a two-stage analysis of potential methodologies both from a high-level methodological 
point of view, as well as in product specific application. 

The objective of the first study stage, Work Package 1 (WP 1), is to develop a clear 
understanding and provide an overview of the advantages and disadvantages (“pros” 
and “cons”) of different approaches for the inclusion of product carbon footprint 
information in the CPR acquis. Methodologies analysed are approaches based on Life Cycle 
Assessment (LCA) / Product Environmental Footprint (PEF) approaches based on the EU 
Emissions Trading System (EU ETS) and the carbon border adjustment mechanism (CBAM), as 
well as hybrids of the approaches.  

This report on the outcomes of WP 1 is structured as follows: 

•  Chapter 1 starts with an introduction to the objective of the report (section 1.1). 

Section 1.2provides an overview of the legislations on climate relevant information in the 
building and construction sector. This is especially relevant, as climate information of 
construction products is not only relevant to the CPR but to a series of other legislation too, 
foremost the Energy Performance of Buildings Directive (EPBD), where it is needed to 
assess the Global Warming Potential (GWP) of buildings. Section 1.3 lists the selected 
methodological approaches analysed in this study. An overview of the seven analysed 
product families and their GHG emissions along the product life cycles is given in section 
1.4. This overview is important to understand key commonalities and differences between 
the assessed product families and derive further points to note from it. 

1 European Commission (EUR-Lex) (2022): Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND 
OF THE COUNCIL laying down harmonised conditions for the marketing of construction products, amending 
Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011. Available online at https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52022PC0144., checked on 4/15/2024. 

2 Two mandates for technical specifications of construction products have been finalised in the technical acquis 
working group (they have not yet been handed to CEN working groups for implementation; currently Member States 
are commenting on them, whereupon the Commission will finalise them): 1) precast concrete and 2) metallic 
products. Further mandates on reinforcing steel, doors or window shutters, cement, lime, thermal insulating products 
and kits are being prepared in the year ahead. If mandates need be adopted to changing requirements for 
standardizations a fallback process is in place. 

Confidential information for the sole benefit and use of the European Commission. 

Page 9 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  Chapter 2 presents the assessment aspects considered for this analysis. The 

assessment aspects build the basis for the analysis and for the evaluation of pros and cons 
of the different approaches. The assessment aspects are designed to reflect the core 
requirements that the inclusion of climate aspects in the CPR acquis needs to fulfil. Of 
special importance is, e.g., that the used data is robust while at the same time the approach 
to be used is applicable with minimum effort and without larger disruption to the daily 
business of the construction industry. 

• 

In chapter 3, each methodological approach considered for this assessment are 
described and the analysis of each approach against the defined assessment aspects is 
conducted. Key findings on the pros and cons as well as product family specific aspects are 
represented in a table format to allow for better readability.  

• 

In chapter 4, a conclusion and an outlook for Work Package 2 are drawn. 

1.2 Overview of the most relevant EU policies, legislation, and 

standards  

Climate footprint information is becoming increasingly relevant to numerous policies affecting 
the construction and buildings sector. Disclosure of Global Warming Potential (GWP)l3 related 
data for construction products may increasingly influence commercial decision-making and 
public procurement and may create lead markets for construction products with a reduced 
carbon footprint. Future market transformation might additionally be fostered by potential 
inclusion of requirements and binding aspects on carbon emission limitations into regulations, 
influencing what kind of products will come to the European market. The carbon footprint 
information required and included in such regulatory frameworks therefore needs to be 
verifiable, climate-scientifically robust, and fraud-resilient. 

As a regulatory centrepiece, the CPR and the CPR acquis lay down harmonized rules for the 
marketing of construction products in the EU. The Commission’s proposal for the revised CPR 
introduces disclosure of climate relevant information as a mandatory requirement for EU 
construction products. The trilogue negotiations on the CPR revision have recently been 
finalised with the mandate for product declaration of climate change effects (synonym to GWP) 
remaining unchanged (exact text to be published). As such, the CPR would be the first 
regulation to institutionalise this binding disclosure aspect for construction products and may 
therefore serve as a pilot for what and how information is provided in such context.  

Under the adopted CPR, climate relevant information is covered in the predetermined 
environmental essential characteristics in Annex II, through 4 impact categories4: 

(a)  climate change effects – total; 

3 ‘Life cycle Global Warming Potential (GWP)’ means an indicator which quantifies the global warming potential 
contributions of a building along its full life cycle. GWP is defined in the Energy Performance of Buildings Directive 
(EPBD). 

4EC (2024): New Regulation on Construction Products, adopted Wednesday, 10 April 2024 
https://www.europarl.europa.eu/doceo/document/TA-9-2024-0188_EN.html#title1  

Confidential information for the sole benefit and use of the European Commission. 

Page 10 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

(b)  climate change effects – fossil fuels; 

(c)  climate change effects – biogenic; 

(d)  climate change effects – land use and land use change; 

The list is complemented by 15 additional environmental impact categories5. Article 15 (3) 
defines at a product's performance declaration shall cover at least the essential characteristics 
listed in point (a) to (d) of Annex II. This applies from the date of application of this Regulation]; 
As defined under Article 5(2) and in Article 6(1) those essential characteristics and the list of 
predetermined environmental essential characteristics set out in Annex II shall constitute the 
basis for the preparation of the standardization requests and their implementation. As specified 
under definition (111) the essential characteristics of construction products and their 
assessment methods can only be determined by harmonized technical specifications to be 
developed for the various product. Therefore, the mandatory implementation of climate relevant 
information into product declarations follows a relative timeline pursuant to the development of 
the respective standardization requests and harmonized technical specifications per product 
family. 

Additional provisions regarding carbon footprinting are included under Article 22. Article 22 
specifies that the manufacturer shall provide a calculation of environmental essential 
characteristics as referred to in Article 15(2)., as the basis for the declaration of performance 
and conformity. In accordance with article 22 (1) and as described under Annex I 4. the 
manufacturer shall carry out the assessment of the performance of the product on the basis of 
data collection for input values, assumptions and modelling following the 3+ system.6; a 
software will also be made available for free use on the website of the European Commission to 
help facilitate assessing the environmental product characteristics. The system is based on the 
list of product families in Annex IV of the current CPR. The list may be extended or existing 
product families may be split into single groups over the course of the ongoing CPR acquis 
revision process. 7Article 83 furthermore strengthens the “Green public procurement” ambitions 
of the European Commission. It gives the Commission the authority to adopt delegated acts for 
the public procurement of construction products. This delegated act shall supplement the CPR 
by specifying mandatory minimum environmental sustainability requirements for construction 
products.  

5 (e)  ozone depletion; (f)  acidification potential; (g)  eutrophication aquatic freshwater; (h)  eutrophication aquatic 
marine; (i)  eutrophication terrestrial; (j)  photochemical ozone; (k)  abiotic depletion – minerals, metals; (l)  abiotic 
depletion – fossil fuels; (m)  water use; (n)  particulate matter; (o)  ionising radiation, human health; (q)  eco-toxicity, 
freshwater; (p)  human toxicity, cancer; (r)  human toxicity, non-cancer; (s)  land use related impacts. 

6 The Assessment and Verification of Constancy of Performance (AVCP) is the harmonized system defining how to 
assess products for their Declaration of Performance under the Construction Product Regulation. It is planned to 
introduce a AVCP 3+ System that includes the essential characteristic on environmental sustainability. Further 
information can be found under 
https://www.eota.eu/sites/default/files/files/20240129_EOTA_Position_AVCP_3plus.pdf  

7 European Commission (2020): Product families and priorities for the CPR Technical Acquis management. Available 
online at https://ec.europa.eu/docsroom/documents/42129, checked on 10/4/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 11 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Under the current CPR acquis a dedicates horizontal sub-group, Subgroup 5, is working on 
overarching requirements to be implemented under the product category specific 
standardization requests regarding the inclusion of climate relevant information into product 
declarations. Overall, the aim of the sub-groups is to ensure a coherent integration of the 
assessment methodology. As of now, the predominant methodology considered under the work 
of this sub-group is the life-cycle assessment laid out by the standard EN 15804+A2.  

The EN 15804+A28  provides core product category rules (PCR) for Type III environmental 
declarations for any construction product and construction service. Both approaches are based 
on life cycle assessment approaches and are embedded into a set of European standards 
governing the methodologies and assessment procedures of LCAs. A direct mention of the EN 
15804+A2 was made in the previous CPR but has been excluded under the revised CPR. 
Evidentially, the close relation between the EN 15804+A2 and the CPR acquis remains high 
and direct connections may be drawn within the harmonised technical specifications. Further 
details on the methodology can be found in section 3.2.  

The CPR acquis aims at supplementing the methodological basis of the EN 15804+A2 by 
additional provisions9. In principle, the adopted CPR establishes that the manufacturer assumes 
the responsibility of the performance of the product. The approach of subgroup 5 is to follow the 
manufacturing process for the production phase. For other modules such as transportation 
within the supply chain or end-of-life considerations, harmonized European scenarios are 
planned to be developed, following a parametric approach. EPDs that have already been issued 
in accordance with the EN 15804+A2 may henceforth function a toolbox to be integrated 
through the AVCP 3+ into a CPR conform assessment.  

Additional provisions regarding other methodologies can be included under the CPR in form of 
delegated acts. The delegated act could for instance define that other methodologies are 
accepted, under the condition that they are proven to be at least as reliable and comprehensive 
as the party-validated CPR assessments. If such delegated acts are adopted, manufacturers 
could choose if they want to repeat the assessment under the CPR or if they chose to use a 
different specified methodology. The climate relevant product information disclosed under the 
CPR can directly inform the environmental assessment at building level. The revised EPBD 
contains several provisions on the Whole Life Carbon performance of buildings.10 It further 
makes specific reference to the revised CPR regarding data for calculating the GWP of 
construction products. The main provisions of the EPBD relevant to this study include:  

•  By 1 January 2027 Member States shall publish and notify to the Commission a roadmap 
detailing the introduction of limit values on the total cumulative life cycle GWP of all new 
buildings and set targets for new buildings from 2030, considering a progressive downward 

8 EN 15804:2012+A2:2019 Sustainability of construction works - Environmental product declarations - Core rules for 
the product category of construction products. 

9 Information on this has been retrieved by conversations with GROW and supporting internal documents  

10 From a buildings perspective, the relative importance of embodied carbon compared to the GHG emissions 
released during the operational phase is expected to increase as a function of a) buildings becoming more energy 
efficient (especially new buildings), b) carbon intensity of energy generation used for the production of the 
construction product being progressively reduced. 

Confidential information for the sole benefit and use of the European Commission. 

Page 12 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

trend, as well as maximum limit values, detailed for different climatic zones and building 
typologies. (art. 7.5) 

•  Requirement to report the life cycle GWP of new buildings in accordance with art 7(2) Annex 
III: according to which “GWP is communicated as a numeric indicator for each life-cycle 
stage expressed as kgCO2e/m2 (of useful floor area) averaged for one year of a reference 
study period of 50 years. The data selection, scenario definition and calculations shall be 
carried out in accordance with EN 15978, a commonly used standard in the industry for 
the assessment of environmental performance of buildings11. The scope of building 
elements and technical equipment is as defined in the Level(s) common EU framework for 
indicator 1.2.”  

•  Disclosure through the Energy Performance Certificate of the building (EPC) 

o 

o 

(a) as of 1 January 2028, for all new buildings with a useful floor area larger than 1000 
square meters; and 
(b) as of 1 January 2030, for all new buildings. 

With direct reference to the Level(s) framework, this voluntary framework methodology to 
assess the sustainability of building project is becoming a relevant approach to assess Whole 
Life Carbon. With Level(s), the EU has established a framework that allows to calculate the life 
cycle emissions of residential and office buildings. The scope of building elements and technical 
equipment for the Whole Life Carbon aspects in the EPBD recast is defined under indicator 1.2 
life cycle GWP. Level(s) indicator 2.2 deals with Construction and Demolition Waste (CDW) and 
it facilitates separate reporting of different waste codes. This could inform separate recycling 
targets for different types of CDW in the future.12 Level(s) indicators rely on information about 
the construction products that align with the EN 15978 and are harmonized with the Product 
Environmental Footprint (PEF).  

The Product Environmental Footprint (PEF) methodology, referred to above, has been 
developed by the European Commission as the recommended tool for assessing and 
communicating the environmental impacts of products, and supporting various sustainability 
initiatives of the European Commission. The EN 15804+A2 has been aligned with PEF. 
Furthermore, PEF is used in EU Taxonomy (beyond the construction sector). EU. Additional 
details on the methodology can be found under section 3.1.  

Both EN 15978 as well as the EN 15804+A2 are embedded into a comprehensive framework of 
European standards, that define approaches to sustainability assessment of buildings, which 
are governed by the CEN/TC 350. EN 15978, EN 15804+A2 and the PEF are methodologically 
furthermore following the ground principles of life cycle assessment guidelines developed by the 
International Organization for Standardization (ISO) like the ISO 14044:200613. An overview 

11 EN 15978:2011. Sustainability of construction works. Assessment of environmental performance of buildings. 
Calculation method) 

12 Under the Waste Framework Directive, Construction and Demolition Waste is a priority waste stream and features 
dedicated provisions to incentivize circularity of construction and demolition. In the current context the CDW is not 
relevant, as it is prospective and thus uncertain to include info on recyclability of a product 

13 ISO 14040:2006 Environmental management, Life cycle assessment - Principles and framework 

Confidential information for the sole benefit and use of the European Commission. 

Page 13 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

table on European and international standards for the assessment of environmental 
performance ad climate relevant information of buildings and construction products can be 
found in Appendix 5.1. 

Figure 1 provides a simplified overview of the most relevant legal acts and methodologies and 
their connection to the climate relevant provisions under the revised CPR, the CPR acquis 
harmonized product (group) standards and the correlations between each. Policies and 
methodologies that have a direct connection to each other are marked by full lines, dotted lines 
indicate an indirect connection or relevance.  

Figure 1: Overview of the most relevant EU policies, legislation, and standards for the inclusion 
of climate aspects in the CPR acquis (own illustration) 

Confidential information for the sole benefit and use of the European Commission. 

Page 14 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

In addition to the mention in the revised EPBD, another direct relation to the Level(s) framework 
is drawn under the provisions on GWP under the EU Taxonomy Climate Delegated Act and 
the Taxonomy Environmental Delegated Act. Under section 3: Construction and real estate 
activities of the Environmental Delegated Act (June 2023) the screening criteria require life cycle 
GWP to be calculated for each stage in the life cycle and disclosure to investors and clients on 
demand. The scope of building elements is as defined in the Level(s) indicator 1.2. Under the 
Climate Delegated Act (June 2023) section 7: Construction and real estate activities, the 
technical screening criteria require GWP calculation of buildings larger than 5000 m2, also in 
accordance with Level(s) indicator 1.2 Furthermore, direct provisions are made regarding 
Level(s) indicator 2.1, 2.3. and 2.4 regarding primary raw material use and design for 
deconstruction. As such the Taxonomy is also relating to provisions under the Waste 
Framework Directive. 

The Ecodesign for Sustainable Products Regulation (ESPR) is the other major legal act to 
shape the sustainability requirements for products marketed in the EU. In an effort to “make 
sustainable products the norm and boost Europe's resource independence”, the Commission 
presented the proposal for the ESPR revision as part of its Sustainable Products Initiative in 
March 2022, which was strongly endorsed by the European parliament in April 202214. The 
adoption of the ESPR is expected by end of May, entering into force in June 2024. Energy 
related products are covered by the current Ecodesign and will be covered by the new ESPR.  
First and foremost, the ESPR applies to energy-related products. However, over time the 
regulation intends to cover the majority of physical goods placed on the European single 
market, including selected intermediate products such as iron, steel and aluminum. At this point 
it cannot be ruled out that also construction products will be included in delegated acts under 
the ESPR. The scopes of both regulations may henceforth overlap regarding construction 
products and other products that may be covered by one, the other or both. Like under the CPR, 
it is planned to introduce a Digital Product Passport to provide information about products’ 
sustainability. 15 

Regarding the methodologies for preparatory studies, the ESPR makes reference to both the 
Methodology for Ecodesign of Energy-related Products (MEErP) and PEF16. For the 
preparatory studies under the MEErP a simplified LCA tool, the Ecoreport Tool, exists. The tool 
is an Excel based tool providing harmonised calculation approaches and boundary conditions 

14 European Commission (2022a): Proposal for Ecodesign for Sustainable Products Regulation, Available online at 
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52022PC0142  

15 Regarding the broader scope of product sustainability, the new Batteries Regulation, adopted in July 2023 
Regulation EU 2023/1542) and the expected regulation on solar photovoltaics modules include provisions on carbon 
footprints: https://publications.jrc.ec.europa.eu/repository/handle/JRC132547  

16 Continuing efforts to develop and improve science-based assessment tools, such as the update of the 
methodology for ecodesign of energy-related products, and the Product Environmental Footprint method are set out 
in Commission Recommendation (EU) 2021/2279 of 15 December 2021 “Environmental Footprint methods to 
measure and communicate the life cycle environmental performance of products and organisations”. https://eur-
lex.europa.eu/legal-content/ET/TXT/PDF/?uri=CELEX:02021H2279-20211230&qid=1725024042583  

Confidential information for the sole benefit and use of the European Commission. 

Page 15 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

for different impact categories, system boundaries considered parameter. Under the current 
revision of the MEErP, JRC has published a number of proposed adaptations to the tool17. 

In the framework of the ESPR, the possible Delegated Act on steel and the related preparatory 
work commissioned by DG GROW and carried out by the Joint Research Centre (JRC) will be 
of particular methodological relevance to this study, given that JRC is developing a carbon 
footprint (CF) method based on GHG values of ETS and CBAM, adding other GHG emissions 
for taking into account a life cycle approach.18 

At installation level, another major EU instrument to mitigate climate change in a cost-effective 
manner is the EU ETS. It regulates carbon emissions in manufacturing and energy generation, 
including installations for the production of construction (pre-)products such as steel, cement, 
lime, bricks, glass, aluminum, and mineral wool (see more information under section ) following 
a cap and trade system (additional information of the regulation can be found under section 3.3. 
Under the EU ETS direct emissions are reported from the registered installations. There is no 
direct connection of the provisions under the CPR to the EU ETS. However, manufacturers of 
(pre)-construction products that are covered under the EU ETS are familiar with the emission 
calculation and reporting required under for the covered the related EU Monitoring and 
Reporting Regulation (MRR)19. The data and reporting obligations under the EU ETS could be 
highly relevant to include climate relevant information in the CPR. Both installation specific 
energy and emission data as well as EU ETS benchmarks could be linked to the work under the 
CPR acquis.  

CBAM is closely linked to the EU ETS and operates at the product level. The regulation 
introduces carbon pricing for imports into the EU, including for imported construction (pre-) 
products, by assessing their carbon intensity. Although the obligation to submit verified CBAM 
declarations only starts from 2027, reporting of embedded emissions in relevant imported goods 
is already in force since 1 October 2023 as part of the CBAM transitional period20. As the scope 
of CBAM expands to the product level, data reported and used under CBAM reporting 
obligations could equally be linked to the CPR acquis standardization requests for including 
climate relevant information. 

In the framework of the Renewable Energy Directive (RED), a Delegated Act establishes a 
methodology setting out detailed rules for the production of renewable liquid and gaseous 
transport fuels of non-biological origin (RFNBOs) and recycled carbon fuels (RCFs)21. The 

17 Joint Research Center (2024): Review of the MEErP - Methodology for Ecodesign of Energy-related Products, 
2024-05-15, Available online at https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/521/documents  

18 Results are expected end of 2024 or early 2025, while the next Commission will decide the exact timing of the 
delegated act. 

19 European Commission, Monitoring and Reporting Regulation (MRR) - (2012): Commission Regulation (EU) No 
601/2012 of 21 June 2012 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 
2003/87/EC of the European Parliament and of the Council, 2012, EU/601/2012. Available online at https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:181:0030:0104:en:PDF , checked on 4/15/2024. 

20 European Commission (EUR-Lex) (2023d): REGULATION (EU) 2023/956 OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL of 10 May 2023 establishing a carbon border adjustment mechanism. Available online at 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0956 , checked on 4/15/2024.  

21 I.e. fuels derived from non-renewable waste streams e.g. fossil waste (plastic, rubber, gaseous wastes etc.).  

Confidential information for the sole benefit and use of the European Commission. 

Page 16 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Delegated Act describes a detailed approach to accounting for the energy mix used for the 
production of the fuel. RFNBO’s must achieve a 70% emission reduction relative to a fossil 
comparator of 94g CO2 eq/MJ during a period of at most one calendar month. This approach 
could be further assessed regarding provisions on the allocation of green energy to a product 
system22.  

The recently revised Energy Efficiency Directive (EED) encourages member states to 
provide necessary support to public bodies in the use of green public procurement, carrying out 
the assessment of life cycle costs, and environment impacts (recital (39)). In particular it states 
that contracting authorities should purchase new buildings that address GWP over the full life 
cycle (recital (40)). Under recital 42, the EED provides direct reference to the EN 15978 and the 
indicator 1.2 of the Level(s) common Union framework. 23 

The Carbon Removals and Carbon Farming (CRCF) Regulation proposal sets out a 
voluntary EU-wide framework to certify carbon removals generated in Europe. The regulation 
establishes EU quality criteria and outlines monitoring and reporting processes in order to 
facilitate investment in innovative carbon removal technologies, as well as sustainable carbon 
farming solutions, while addressing greenwashing. This could potentially be used to provide 
guidance on Carbon capture and utilisation /Carbon capture and storage (CCU/CCS) 
considerations within construction product value chains.24  

In addition, the Innovation Fund methodology for GHG avoidance calculation is providing an 
approach to calculate the GHG emission avoidance of a project in terms of absolute GHG 
emission avoidance, and relative GHG emission avoidance. The methodology provides 
methodological guidance for projects intended for energy supply to buildings, as well as to 
produce innovative construction materials.  

1.3 Selected methodological approaches 

Out of the above provided overview of potentially relevant approaches, a set of methodologies 
in line with the terms of reference (ToR) of the study were chosen for further detailed 
assessment.  

22 European Commission (2024b): Certification of permanent carbon removals, carbon farming and carbon storage in 
products. Available online at https://climate.ec.europa.eu/eu-action/certification-permanent-carbon-removals-carbon-
farming-and-carbon-storage-products/certification-permanent-carbon-removals-carbon-farming-and-carbon-storage-
products_en,  checked on 4/15/2024. 

23 Energy Efficiency Directive (recast): COMPROMISE AMENDMENT 1. With assistance of Supported by: EPP, S&D, 
RE, Greens/EFA. Available online at 
https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/ITRE/DV/2022/07-
13/EED_FinalCompromiseAmendment_EN.pdf, checked on 4/15/2024. 

24 European Commission (2024a): Certification of permanent carbon removals, carbon farming and carbon storage in 
products. Available online at https://climate.ec.europa.eu/eu-action/certification-permanent-carbon-removals-carbon-
farming-and-carbon-storage-products/certification-permanent-carbon-removals-carbon-farming-and-carbon-storage-
products_en#documentation, checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 17 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Figure 2 provides an overview of the methodological approaches that this study considers. 
Details on the individual approaches are provided under chapter 3.25 

Figure 2. Overview of relevant methodological approaches (own illustration) 

To set the scene and basic scope for the different approaches, two concepts will be further 
described followingly: life cycle assessments and carbon accounting under the framework of 
three different scopes.  

Under the category LCA the study considers two approaches, the PEF and the EN 15804+A2. 
Both approaches provide a multi-factor approach, on multiple impact categories such as 
climate, energy, water, and material use. The assessment of environmental impacts is 

25 The representation of the approaches is not intended to frame them as competing approaches, but rather 
showcase their differences in terms of system boundaries and environmental characteristics covered. 

Confidential information for the sole benefit and use of the European Commission. 

Page 18 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

conducted throughout the whole lifecycle of a product, from cradle to grave/cradle. A schematic 
overview of the different life-cycle stages of a construction product are shown in Figure 3, based 
on EN 15804+A2. 

Regarding construction products, the life cycle of a product typically consists of a product phase 
(A), followed by a construction (B) and use phase and ending with the end-of life (C) and 
recycling/reuse phase (D). Carbon emissions of inert construction products occur mainly in 
stage A of the product life cycle. The emissions along the life cycle depend on both usage and 
end-of life scenarios.  

Figure 3. Life-cycle stages of a construction product within in a building life cycle 
(adopted from EN 15804+A2) 

In general, the LCA framework follows a structured approach for the assessment of 
environmental impacts, typically consisting of four phases according to the ISO 14040:2006 
guidelines (Figure 4) 26. They are as follows: 

•  Goal and scope definition aims to determine the extent of the product's life cycle that 
will be assessed, along with the purpose of the assessment. This stage establishes 
the criteria for comparing systems and specifies the relevant time frames. 

•  The Life  Cycle  Inventory (LCI)  involves  describing  the  material  and  energy  flows 
within the product system, as well as its interactions with the environment. It includes 
identifying  the  raw  materials  consumed  and  the  emissions  released  into  the 
environment.  All  significant  processes  and  related  energy  and  material  flows  are 
documented.  

•  Using the information from the inventory analysis, the Life Cycle Impact Assessment 
(LCIA) is conducted. In this phase results from the LCI phase are associated to the 

26 EN ISO 14040 (2009): EN ISO 14040 Environmental management - LCA - Principles and framework. 

Confidential information for the sole benefit and use of the European Commission. 

Page 19 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

respective  environmental  impact  categories27  and  indicators.  This  is  achieved  by 
following LCIA methods starting with classification of emissions into impact categories 
followed  by  characterization  into  common  units  to  allow  for  comparison.  The  LCIA 
includes  additional  sub-steps,  normalization  and  weighting.  Normalization  is  where 
LCIA results are multiplied by a normalization factor to calculate the magnitude of their 
contributions to the impact categories, to allow comparison relatively to a reference 
unit. The weighting sub-step reflects the perceived relative importance of the life cycle 
impact categories considered.  

•  The interpretation stage  involves  a  critical  review  of  the  LCA  study,  assessing  the 
completeness  and  sensitivity  of  the  data,  conducting  consistency  checks  and 
presenting the results. This step provides a comprehensive understanding of the life 
cycle  assessment,  including  any  uncertainties  and  limitations.  While  this  step  is 
presented  separately,  it  is  considered  part  of  all  other  steps  as  it  is  performed  in 
parallel with each of them. 

Figure 4. Life cycle assessment framework according to ISO28 

The EU ETS system is focusing on measuring and reporting installation-based data, which is 
purely focused on GHG emissions. A common approach to describe different boundaries for 
emission accounting is the differentiation into emission scopes in accordance with the GHG 
protocol29, highlighted in Figure 5 

27 Environmental impact assessed parameters include: Global warming potential (GWP), Ozone depletion potential 
(ODP), Acidification potential (AP), Eutrophication potential (EP), Formation potential of tropospheric ozone 
photochemical oxidants (POCP), Abiotic depletion potential for non-fossil resources (ADPE) and Abiotic depletion 
potential for fossil resources (ADPF) and various others as available through LCIA  

28 EN ISO 14040 (2009): EN ISO 14040 Environmental management - LCA - Principles and framework. 

29 Diagram of scopes and emissions across the value chain.pdf (ghgprotocol.org) 

Confidential information for the sole benefit and use of the European Commission. 

Page 20 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  Scope 1 – All direct emissions from the activities of the production of a product including 

fuel combustion on site such as gas boilers and air-conditioning leaks. 

•  Scope  2  -  Indirect  emissions  from  the  consumption  of  purchased  electricity,  heat,  or 

steam. 

•  Scope  3  –  All  other  indirect  emissions:  scope  3  upstream  emissions  cover  other 
indirect emissions such as outsourced activities. Scope 3 downstream emissions cover 
other  indirect  emissions  related  to  downstream  activities  in  the  value  chain,  such  as 
transportation,  distribution,  processing  or  use  of  sold  products,  leased  assets  or 
investments. 

Figure 5. Overview of GHG protocol scopes and emissions across the value-chain 

The EU ETS system is focusing on measuring and reporting installation-based data, which is 
considered primarily scope 1. CBAM considers scope 1, 2 and some additional scope 3 
emissions on the product level. The IF methodology is consistent with the ETS and the CBAM 
approach, which are used as reference. In relation to the LCA concept, where all scope 1,2 and 
3 emissions are measured, the following graphic illustrates how the assessments under EU ETS 
and LCA can be related:  

Confidential information for the sole benefit and use of the European Commission. 

Page 21 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Figure 6: Figure 7. Illustration of different GHG emission (EU ETS and LCA) accounting scopes in 
relation to a product life cycle 

1.4 Overview of product families 

As described in chapter 1.1, the suitability of the different methodological approaches for carbon 
emissions accounting may differ for different product families. Therefore, an assessment of 
seven product families is conducted in the scope of the study, comprised of the following 
product families, as shown in Table 1. The following section describes the basic characteristics 
of these product families regarding their product group specifications, supply chains and GHG 
emissions.  

Table 1. Overview of product families addressed in this study  

#  Mandate  Product family 

1. 

 M100 

2. 
3. 
4. 

 M120 
 M114 
 M103 

Precast concrete (including the reinforcing steel  
contained in it) 
Structural metallic products 
Cement 
Thermal insulating products 

(a)  examples of energy intensive ones like mineral 

wool and glass wool 

(b)  examples of low carbon ones 
(c)  examples of foam-based insulation products 

5. 
6. 
7. 

 M135 
 M113 
 M112 

Flat glass, profiled glass, and glass block products 
Wood based panels 
Structural timber 

Confidential information for the sole benefit and use of the European Commission. 

Page 22 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

M100 Precast concrete (including reinforcing steel) 

M100 precast concrete includes reinforced or prestressed normal weight or lightweight 
concrete, used for the construction of buildings as well as for the use in buildings such as roof 
elements, stairs, foundation as well as wall and floor elements. Precast concrete is prepared, 
cast, and cured offsite, usually in a controlled factory environment, using reusable molds30. 
Figure 8 provides an overview of an exemplary supply chain for precast concrete with reinforced 
steel elements and its related GHG emissions (cradle-to-gate) adapted from Sphera (2022b)31 
and Hormipresa (2023) 32. 

Figure 8. Exemplary supply chain and (cradle-to-gate) for reinforced precast concrete, the major 
emitting steps are circled by a black box. 

Curing is a significant part of the manufacturing process for concrete and reinforced-concrete 
products and is connected to high energy consumption33. The GHG emissions from concrete 
production are however most directly proportional to the cement content used in the concrete 
mix, accounting for the majority of emissions associated with a ton of average concrete mix34. 

30 Converge (2023): Precast Concrete: The Complete Guide - Converge. Available online at 
https://www.converge.io/blog/precast-concrete-the-complete-guide , checked on 10.04.2022,  

31 Sphera (2022b): Process Data set: Precast concrete slab, ceiling, thickness 20cm; 504 kg/m2. ÖKOBAUDAT. 
Available online at https://oekobaudat.de/OEKOBAU.DAT/datasetdetail/process.xhtml?uuid=6575f9dd-8a50-440c-
90df-30608167c739&version=20.23.050&stock=OBD_2023_I&lang=en , checked on 4/10/2022. 

32 Hormipresa (2023): Environmental Product Declaration. Precast concrete product – Linear structural elements. 
Available online at https://api.environdec.com/api/v1/EPDLibrary/Files/86a9f68e-f639-4152-8e0e-08dc0c71a3ba/Data 
, checked on 4/10/2024. 

33 BFT (2015): Increasing energy efficiency in precast concrete products production. Available online at 
https://www.bft-
international.com/en/artikel/bft_Increasing_energy_efficiency_in_precast_concrete_products_production-
2469630.html , checked on 4/10/2024. 

34 Mahasenan, Natesan; Steve Smith; Kenneth Humphreys; Y. Kaya (2003): The Cement Industry and Global 
Climate Change: Current and Potential Future Cement Industry CO2 Emissions. Available online at 
https://www.sciencedirect.com/science/article/abs/pii/B9780080442761501574?via%3Dihub, checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 23 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

The assessment of GHG emissions along the product life cycle is based on an sample EPD for 
the M100 product family based on Consolis Parma precast concrete beam pre-stressed (HUB-
1635)35. As can be seen in Table 2, 80% of the of the carbon intensity is stemming from the 
manufacturing phase (A1). Stage B was excluded from the assessment, as the use phase is 
dependent on complex assumptions on building level. Emissions of module C equally rely on 
assumptions, regarding a standardized disposal scenario. In this case landfilling was assumed. 
For model D -2.08 (kg CO2e/t) of fossil GHG emission was indicated in the source, which is 
based on the assumption on recycling after the end of life. Regarding the impact categories of 
biogenic GWP and LULUCF GWP, impact categories appear to have a small impact, with below 
1kg (kg CO2e/t) for biogenics and LULUCF GWP. This however may change in the future, with 
adapting production processes. 

Table 2. Percentage share of fossil GHG emissions in each module (excl. stage B and D) for an 
example EPD of M100 product family based on Consolis Parma precast concrete beam pre-
stressed (HUB-1635)36 (absolute values rounded). 

Product 

Construction 

Use 
Stage 

End of life 

A1 

A2 

A3 

A4 

A5 

B1-B7 

C1 

C2 

C3 

C4 

Beyond 
life 
cycle  
D 

155 

8 

10 

8 

0 

%  

80% 

4% 

5% 

4% 

0% 

- 

- 

3 

4 

5 

0.05 

-2 

9% 

11% 

13% 

0% 

LCA 
stages  

Module 
GWP 
Fossil 
(kg 
CO2e/t) 

M120 structural metallic products 

M120 structural metallic products include hot rolled, cold formed or otherwise produced sections 
in various shapes as well as finished metallic products, welding materials and structural 
connectors. Structural metallic products comprise materials such as steel of different 
composition (steel, metallic coated steel, stainless steel, organic coated steel, steely alloys), 
aluminum alloys and cast iron (European Commission 1998). The production of these products 
is a highly energy- and GHG-emission-intensive process. The steel sector alone is 
responsible for about 5% of the EU’s GHG emissions (JRC 2022). Figure 9 provides an 
overview of an exemplary supply chain for structural metallic products (cradle-to-gate) adapted 
from Technical Secretariat (2019)37. The energy intensive manufacturing process of steel is due 
to its reliance on the fossil fuel-intensive blast furnace process38. 

35 https://manage.epdhub.com/?sort=datePublishedUp# HUB-1635 

36 https://manage.epdhub.com/?sort=datePublishedUp# HUB-1635 

37 Technical Secretariat (2019): Product Environmental Footprint Category Rules(PEFCR) for Metal Sheets for 
Various Applications, checked on 4/10/2023. 

38 Somers, J. (2022): Technologies to decarbonise the EU steel industry (ISBN 978-92-76-47147-9, 
doi:10.2760/069150). Available online at https://publications.jrc.ec.europa.eu/repository/handle/JRC127468, checked 
on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 24 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Figure 9. Exemplary supply chain and (cradle-to-gate) for structural metallic products (adapted 
from Technical Secretariat (2019)), main GHG emissions are circled by a black box.  

The initial assessment of GHG emissions along the product life cycle presented below is based 
on two EPD for hot rolled steel sheets and serve as an example. As can be seen in Table 3, 
74% of the fossil GHG emissions stem from stage A1, which includes the blast furnace process.  
Stage B was excluded from the assessment, as the use phase is dependent on complex 
assumptions on building level. Emissions of module C equally rely on assumptions, regarding a 
standardized disposal scenario. In this case 5% of the product is assumed to be lost at 
recycling. For model D an average of -316 (kg CO2e/t) of fossil GHG emission was indicated in 
the sources, which is based on the assumption of a recycling after the end of life of the product. 
These savings appear to be highly relevant in the overall steel life cycle, when considering a 
circular use. Regarding the impact categories of biogenic GWP and LULUCF GWP, impact 
categories appear to have a small impact, with below 3kg biogenic CO2e /t being released in the 
manufacturing phase and LULUCF GWP below 1kg CO2e. 

Table 3. Percentage share of fossil GHG emissions in each module for an example EPD of M120 
product family based on Galvanized Structural Steel39 (absolute values rounded). 

Product 

Construction 

Use 
Stage 

End of life 

A1 

A2 

A3 

A4 

A5 

B1-B7 

C1 

C2 

C3 

C4 

Beyond 
life 
cycle 
D 

900 

22 

118 

8 

66 

%  

74% 

2% 

10% 

1% 

5% 

- 

- 

66 

8 

23 

0 

-316 

5% 

1% 

2% 

0% 

- 

LCA 
stages 

Module 
GWP 
Fossil 
(kg 
CO2e/t) 

39 EPD: https://epd-online.com/EmbeddedEpdList/Download?id=16708 

Confidential information for the sole benefit and use of the European Commission. 

Page 25 

 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

M114 Cement, building limes and other hydraulic binders 

M114 Cement, building limes and other hydraulic binders include common cement products 
such as Portland cements, Portland composite cement, Masonry cements and Calcium 
aluminate cements. Cement is made by firing cement clinkers, limestone, clay, and other 
materials (European Commission 1997b). The majority of CO2 is emitted from the energy used 
to sinter the material, and the chemical reactions occurring during the process. Clinker is the 
key intermediate product for cement and also the key GHG emission source (Gibbs et al. 2023). 
Figure 10 illustrates an exemplary supply chain process of cement production.  

Figure 10. Exemplary supply chain of cement production (cradle-to-gate)43, main GHG emissions 
are circled by a black box. 

The link between clinker and cement is very close. However, using cements with reduced 
clinker content is a key lever for the industrial transformation. Therefore, the link between clinker 
and cement will likely become weaker over time. And already today, cement types with reduced 
clinker content are widely used. 

Cement is an inorganic, finely ground, hydraulically active binder for mortar and concrete. When 
water is added, the cement paste that forms hardens through hydration to form water- and 
space-resistant cement stone. Due to the large number of types of cement, “normal cements” 
and “special cements” (cements with additional or special properties) are treated separately in 
the European and national cement standards.40 

40 VdZ (2017): Zement Merkblatt Betontechnik. Available online at https://www.vdz-
online.de/fileadmin/wissensportal/publikationen/basiswissen/zement-merkblaetter/B1.pdf, checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 26 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

The European cement standard EN 197-1 Cement – Part 1: “Composition, specifications and 
conformity criteria for common cements” defines 27 distinct common cement products and their 
constituents. These 27 products are grouped into five categories, depicted in Table 4 below41: 

Table 4. Overview of cement types and their clinker contents42 

Cement 
categories 

CEM I 

CEM II 

CEM III 

CEM IV 

CEM V 

Clinker content 

Portland cement 

% 

>95% 

Portland composite cement 

65-94% 

Blastfurnace cement 

Pozzolanic cement  

Composite cement 

5-64% 

45-89% 

20-64% 

The assessment of the share of GHG emissions per product stage is based on an example EPD 
on White Portland-slag cement 43. Since cement is an intermediate product, EPDs typically only 
include modules A1-A3. Therefore, the example EPD is also only based on A1-A3, not including 
the Stages B, C and D. Regarding the fossil CO2 emissions, as can be seen in Table 5, 95% of 
the fossil GHG emissions stem from stage A3, which includes the clinker production.  

Table 5. Percentage share of fossil GHG emissions in each module for an example EPD of M114 
product family based on White Portland-slag cement43 (absolute values rounded). 

LCA stages  
Module 

GWP Fossil 
(kg CO2e/t) 

%  

A1 

31 

3% 

Product 
A2 

13 

1% 

A3 

939 

96% 

M103 Thermal insulating product 

M103 Thermal insulating product can be largely divided into three categories:  

•  Mineral wool: Energy intensive insulation products such as rock wool & glass wool) 

•  Plant/animal derived insulation materials: Low carbon insulation materials such as 

cotton, sheet wool, cellulose etc. 

41 Cembureau (2024): Cement. Available online at https://cembureau.eu/about-our-industry/cement/, checked on 
4/10/2024 

42 Cembureau (2024): Cement. Available online at https://cembureau.eu/about-our-industry/cement/, checked on 
4/10/2024 

43 EPD: https://manage.epdhub.com/?epd=HUB-0913  

Confidential information for the sole benefit and use of the European Commission. 

Page 27 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  Foam insulation: Insulation material made out of polyurethane, polystyrene etc. 

These products are made of specially designed materials with the aim of minimising heat 
transfer between different environments and used in a variety of spaces ranging from walls and 
ceilings to pipes and ducts. The production process for the different categories varies quite 
vastly and are described briefly in the sections below.44 

Example of energy intensive insulation material 

Mineral wool mostly consists of either rock wool or glass wool insulation, the production process 
of which is quite similar in theory. Both insulation materials are based mainly on natural and/or 
reusable materials such as sand, dolomite, soda, stone, recycled glass, which are melted in 
furnaces and then go through various processes such as fiberizing, compressing and curing. 
The majority of GHG emissions occur during melting due to fossil fuel combustion as well as 
decomposition of carbonates in the raw material. An example supply chain of mineral wool 
production is shown in Figure 11 adapted from Knauf Insulation Ltd (2024)45.  

Figure 11. Exemplary supply chain of mineral wool production (cradle-to-gate), adapted from 
Knauf Insulation Ltd (2024)46, main GHG emissions are circled by a black box. 

Table 6 provides an overview of an exemplary supply chain for mineral wool and its related 
GHG emissions. The assessment is based on an EPD which serves as an example based on 
mineral wool insulation (low bulk density range). As can be seen in the table, around 93% of the 
life cycle GHG emissions can be attributed to the product stage. Across multiple EPDs no EPD 
could be found, that has shows a split out between the stages A1-A3. Therefore, the example 

44 ECOFYS (2009): Methodology for the free allocation of emission allowances in the EU ETS post 2012. Available 
online at https://climate.ec.europa.eu/system/files/2016-11/bm_study-mineral_wool_en.pdf, checked on 4/10/2024 

45 Knauf Insulation Ltd (2024): Manufacture of Mineral Wool. Available online at https://www.knaufinsulation-
ts.com/competences/production, checked on 4/10/2024. 

46 Knauf Insulation Ltd (2024): Manufacture of Mineral Wool. Available online at https://www.knaufinsulation-
ts.com/competences/production, checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 28 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

EPD only allows for an aggregated assessment. However, secondary literature indicates, that 
within stage A, the majority of GHG emissions falls under the manufacturing processes47. Stage 
B was excluded from the assessment, as the use phase is dependent on complex assumptions 
on building level. Emissions of module C equally rely on assumptions, regarding a standardized 
disposal scenario. In this case landfilling was assumed. Regarding the impact categories of 
biogenic GWP and LULUCF GWP, the impacts appear be relatively small, with below 1kg 
biogenic CO2e/t being released in the manufacturing phase and LULUCF GWP not considered 
in the EPD.48 

Table 6. Percentage share of fossil GHG emissions in each module for an example EPD of M103 
product family based on mineral wool insulation49, (absolute values rounded). 

LCA 
stages  
Module 

GWP 
Fossil (kg 
CO2e/m3) 

Product 

Construction 

A1-A3 

38 

A4 

1 

A5 

2 

%  

93% 

1% 

5% 

Use 
Stage 
B1-B7 

- 

- 

End of life 

C1 

- 

- 

C2 

0 

0% 

C3 

- 

- 

C4 

0 

1% 

Beyond 
life cycle  
D 

-1 

Examples of low carbon insulation material 

Low carbon insulation is generally made using organic plant & animal derived raw materials 
and/or innovative materials. These include cotton, hemp, cellulose, woodfibre, recycled 
Polyethylene terephthalate (PET) etc. Insulation materials from agricultural residues have a 
significantly lower embodied carbon content and some constitute a carbon sinks. Often, low 
carbon insulation products can also be a combination of different base materials such as for 
instance a mix of recycled PET and sheepwool50.  

An example of the life cycle stages of a loose fill cellulose fibre insulation product, commonly 
used in the construction sector can be seen in Figure 12. 

The input material (recycled or virgin) is transported to the cellulose insulation production plant. 
The impurities are separated, and the paper is shredded. Paper which still contains tiny 
amounts of impurities is recycled into the process. When milling the shredded paper, fire 
retardants are added. The final product is packed and transported to the construction site. The 
Transportation step to the construction site requires an assumption of km driven. In case of this 

47 Eurimea (2023): Mineral wool insulation and the road to a climate neutral Europe. Available online at 
https://www.eurima.org/uploads/files/modules/articles/1678707364_EURIMA_CN2050%20Roadmap_February%202
023.pdf, checked on 4/10/2024. 

48Verein Deutscher Zementwerke e. V. (2020): Process Data set: average cement D. Available online at 
https://oekobaudat.de/OEKOBAU.DAT/datasetdetail/process.xhtml?uuid=d368f4bb-ae22-4e33-b9e4-
22a7b27966c6&version=00.02.000&stock=OBD_2023_I&lang=en, checked on 4/10/2024. 

49 https://epd-online.com/EmbeddedEpdList/Download?id=18269 

50 EPD (2021): Environmental Product Declaration. Available online at 
https://api.environdec.com/api/v1/EPDLibrary/Files/78be8497-87dd-4c92-3a66-08d99c9745fc/Data, checked on 
4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 29 

 
 
 
 
 
 
  
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

EPD a distance of 380 km was assumed. The loose fill cellulose insulation in this example is 
applied into the construction by a machine, blowing or spraying it into the wall. Therefore, the 
energy consumption of the blowing or spraying machine needs to be considered in stage A4-5.  

Figure 12. Exemplary supply chain of cellulose fibre insulation material (cradle-to-gate), main GHG 
emissions are circled by a black box. 

Table 7 provides an overview of an exemplary supply chain for cellulose fibre-based insulation 
and its related GHG emissions. The assessment is based on an EPD of cellulose fiber blowing 
insulation material and only serves as an example51. No EPD could be found, that split out stage 
A1-A3 in more detail. As can be seen in the table, the majority of the fossil emissions can be 
attributed to the product stage. In the case of cellulose, the organic carbon content is of high 
importance. The bound carbon in the produce, constituting a carbon sink, can be up to 8-fold of 
the fossil carbon released in the production stage52. These are, however, released if the end of 
life is reached and an incineration scenario is applied. represent the major source for carbon 
emissions. In stage D potentially a recycling could be conducted with the cellulose. In case of 
the example EPD, stage D is considered as the avoided energy use from the incineration plant, 
with heat recovery of -64 kg CO2e/t. A density of 45 kg/m3 was stated in the example EPD.  

Table 7. Percentage share of fossil GHG emissions in each module for an example EPD of M103 
product family based on Loose fill cellulose insulation51 (absolute values rounded). 

LCA Stage 

Product 

Construction 

End of life 

Module 
GWP fossil 
(kg CO2e/t) 
% 

A1-A3 + A5 

175 

71% 

A4 

59 

24% 

C2 

12 

5% 

Examples of foam-based insulation products 

51 Environmental Product Declaration Loose Fill Cellulose (2018) https://www.biobasedbouwen.nl/wp-
content/uploads/2021/02/20180123-EPD_cellulose_ECIA-NL-version.pdf  

52 EPD: https://oekobaudat.de/OEKOBAU.DAT/datasetdetail/process.xhtml?uuid=e08642c5-4c81-4170-9130-
d7fa8fb6509f&version=20.23.050&stock=OBD_2023_I&lang=de  

Confidential information for the sole benefit and use of the European Commission. 

Page 30 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Foam insulation is typically made of a low-density elastomer or polymer in the form of a thermal 
insulating foam. These include phenolic foams, spray based polyurethane foams, polystyrene 
foams, Polyisocyanurate foams. The majority of the emissions in the foam life cycle come from 
the upstream value chain, i.e., at the level of chemical raw materials53. An exemplary life cycle 
flow of expanded polystyrene foam can be seen in Figure 13. 

Figure 13. Exemplary supply chain of polystyrene foam-based insulation material (cradle-to-gate) 
54, main GHG emissions are circled by a black box. 

Table 8 provides an overview of exemplary GHG emissions for foam insulation. The 
assessment is based on an average EPD of polystyrene foam insulation and only serves as an 
example. As can be seen in the table, 61% of the emissions can be attributed to the product 
stage (raw material supply here being the most carbon intensive), and 37% to the end-of-life 
stage. In the EPD, thermal incineration is assumed as the end-of-life scenario.55 

Regarding the impact categories of biogenic GWP and LULUCF GWP, in total 2 kg biogenic 
CO2e /t are released, which are stemming from accompanying packaging. The total LULUCF 
GWP below is below 1kg CO2e/m3. A density of 75 kg/m3 was stated in the example EPD.  

Table 8. Percentage share of fossil GHG emissions in each module for an example EPD of M103 
product family based on HT/ArmaFlex insulation (Foam insulation)55 (absolute values rounded). 

LCA stages  

Product 

Construction 

Module 

A1-A3 

A4 

A5 

Use 
Stage 

B1-B7 

End of life 

Beyond life 
cycle 

C1 

C2 

C3 

C4 

D 

53 EUROPUR (2023): EU FLEXIBLE PU FOAM INDUSTRY PAVES THE WAY FOR LOW CARBON FOAMS. 
Available online at https://europur.org/eu-flexible-pu-foam-industry-paves-the-way-for-low-carbon-foams/, checked on 
4/15/2024. 

54 EUMEPS (2011): Expanded Polystyrene (EPS) Foam Insulation. Available online at https://www.flatz.com/wp-
content/uploads/2021/05/ECO-EPS-00030201-1106.pdf, checked on 4/15/2024. 

55 EPD: https://epd-online.com/EmbeddedEpdList/Download?id=12629  

Confidential information for the sole benefit and use of the European Commission. 

Page 31 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

GWP Fossil 
(kgCO2e/m3) 

319 

5 

6 

%  

61% 

1% 

1% 

- 

- 

- 

- 

0 

195 

0% 

37% 

- 

- 

-54 

M135  Flat glass, profiled glass, and glass block products 

M135 Flat glass, profiled glass, and glass block products includes products such as windows, 
facades, balconies or balustrades. Raw materials used for the production comprise silica sand, 
soda ash, dolomite/limestone and cullet. On building level glass is always used as composite 
product in connection to a window frame. Therefore, the information on GHG emissions needs 
to be put into relation to the use case.  

Figure 14 provides an overview of an exemplary supply chain for flat glass adopted from 
Hartwell et al.56. 

Figure 14. Exemplary supply chain for flat glass flat glass adopted from Hartwell et al., main GHG 
emissions are circled by a black box. 

The highest share of emissions stems from the manufacturing phase which involves the melting 
of the raw materials in a furnace at high temperatures to form molten glass and the forming the 
molten glass into flat sheets through processes like floating, rolling, or drawing. These are 
energy intensive processes, primarily due to the high temperatures required for melting. 

The assessment of GHG emissions along the product life cycle is based on an sample EPD for 
the M135 product family based on thermally toughened safety glass. As can be seen in Table 9, 
91% of the of the carbon intensity is stemming from the production phase (A1-A3). Of multiple 
EPDs, no EPD could be found, for which stages A1-A3 were split out. Stage B was excluded in 
the EPD. Emissions of module C rely on assumptions, regarding a standardized disposal 
scenario. In this case landfilling was assumed, although 10% of toughened safety glass was 

56 Hartwell, Rebecca; Coult, Graham; Overend, Mauro (2023): Mapping the flat glass value-chain: a material flow 
analysis and energy balance of UK production. Available online at- https://link.springer.com/article/10.1007/s40940-
022-00195-9  checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 32 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

considered for used as downcycled container glass. For module D 0.3 (kg CO2e/1m2x1mm) of 
fossil GHG emission was indicated in the source. Regarding the impact categories of biogenic 
GWP and LULUCF GWP, these emissions appear to only be associated with packaging of the 
product. 

Table 9. Percentage share of fossil GHG emissions in each module for an example EPD of M135 
product family based on thermally toughened safety glass57 (absolute values rounded) 

LCA stages 

Product 

Construction 

Use Stage 

End of life 

Beyond life cycle 

Module 

A1-A3 

A4 

A5 

B1-B7 

C1 

C2 

C3 

C4 

GWP Fossil 
(kgCO2e/1m2x1mm) 

5 

0.3 

0.01 

- 

0 

0.03 

0.04 

0.03 

D 

-0.3 

% 

91% 

6% 

0% 

0% 

1% 

1% 

1% 

M113  Wood-based panels 

M113 wood-based panels are cross-laminated wood elements consisting of different oriented 
layers of wooden planks and/or beams, which are glued or dowelled together to large panels58. 
To produce solid wood panels, timber is harvested, debarked and produced to veneer panel. 
The panels are glued and pressed to form a layered panel. After pressing and hardening, the 
blank sanded and packaged. Wood is widely recognized as a renewable construction material 
with a comparable low carbon impact and low embodied energy. Wood constitutes a carbon 
sink by binding carbon as biogenic carbon. However, the bound carbon cycle is affected when 
wood-based construction materials are being processed. CO2 is released during harvesting and 
manufacturing of wood products and by the use and disposal of wood. Therefore, the modelling 
of biogenic carbon is important to be considered in the carbon footprint. An exemplary supply 
chain, adopted from Raute59 and Yalong60 for a wood panels is presented in Figure 15.  

57 EPD: https://www.kab-allglass.de/wp-content/uploads/2024/03/EPD-FEG_KAB-Allglass-ENG.pdf  

58 European Commission (1997a): Mandate M/113. Available online at 
https://law.resource.org/pub/eu/mandates/m113.pdf, checked on 4/10/2024.  

59 Raute (2024): LVL – the sturdy wooden component from new buildings to renovations and further industrial 
applications. Available online at https://www.raute.com/industries/lvl-production/, checked on 4/10/2024. 

60 Yalong (2021): Plywood Production Process. Available online at https://www.yalongwood.com/plywood-production-
process/ , checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 33 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Figure 15. Exemplary supply chain for wood panels (cradle-to-gate), adapted from Raute and 
Yalong, main GHG emissions are circled by a black box. 

Table 10 provides an overview of an exemplary supply chain for wood-based panels and its 
related GHG emissions. The assessment of GHG emissions along the product life cycle is 
based on a sample EPD for the M113 product family based on of multi-layer parquet, 
manufactured by Timberwise.62 As can be seen in Table 10, Around 72% of the of the carbon 
intensity is stemming from the production phase (A1-A3). Secondary literature indicates that in 
particular the veneer production and hot pressing consumes relevant quantities of energy, 
contributing to the fossil GHG emissions of A361. Stage B was excluded in the EPD. In this EPD, 
the wood panels are assumed to be incinerated for energy recovery. Regarding the impact 
categories of biogenic GWP and LULUCF GWP, considerable amounts of biogenic carbon are 
considered as negative emissions (carbon sink) in the product phase and are released in the 
end-of-life stage through incineration (more than 5-fold than the total fossil GWP). Overall, the 
balance of the biogenic carbon equals 0.  

Table 10. Percentage share of fossil GHG emissions in each module for an example EPD of M113 
product family based on multi-layer parquet62 (absolute values rounded) 

LCA stages 

Product 

Construction 

Use 
Stage 

End of lie 

Module 

A1 

A2 

A3 

A4 

A5 

B1-B7 

C1 

C2 

C3 

C4 

GWP Fossil 
(kgCO2e/1m2) 

6 

1 

9 

3 

2 

% 

29% 

4% 

43% 

13% 

9% 

- 

- 

0 

0 

0 

0 

0% 

1% 

1% 

0% 

Beyond 
life 
cycle 

D 

-9 

61 Puettmann et al. (2013): Cradle to Gate Life Cycle Assessment of Laminated Veneer Lumber Production from the 
Southeast https://corrim.org/wp-content/uploads/2018/06/SE-LVL-LCA-revised-July-2013-final.pdf, checked on 
4/12/2024. 

62 EPD: https://manage.epdhub.com/?epd=HUB-1629  

Confidential information for the sole benefit and use of the European Commission. 

Page 34 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

M112 Structural timber 

M112 Structural timber is an industrially manufactured product for load-bearing structures and 
comprises structural forms such as beams, poles, trusses elements, piles, columns, trusses, 
girders, and are used in building systems such as piles, deck members, frame elements for 
walls, roofs, floors, bridges63. Solid structural timber consists of kiln-dried squared timbers made 
of softwood that are force-fitted lengthways using finger-joint connections. The binders 
contained in the product are primarily based on melamine-urea-formaldehyde and polyurethane. 
The conventional sawn wood (kiln-dried sawn timber) dried to less than 18% wood moisture 
content is first pre-planned and sorted visually or mechanically according to strength (planed 
goods). Identified squared timber sections with strength-reducing areas are cut off depending on 
the desired strength class and the resulting squared timbers are, formed into long lamellas64. 
After sawing the plank is trying and sanded before packaging and transporting. Figure 16 
illustrates the supply chain processes supply chain for structural timber (cradle-to-gate) adopted 
from Nicholls and Bumgardner65. 

Figure 16. Exemplary supply chain for structural timber (cradle-to-gate), , main GHG emissions are 
circled by a black box. 

The assessment of GHG emissions along the product life cycle is based on a sample EPD for 
the M112 product family based on Strength-graded and finger-jointed structural timber (HUB-
1064)66. As can be seen in Table 11 around 40% of the of the carbon intensity is stemming from 
the production phase (in particular sorting and saw milling processes) and 37% from the 
transport to the construction stage (A4). Stage B was excluded by the EPD. In stage C 

63 European Commission (1996): M112. Available online at 
http://www.sgpstandard.cz/editor/files/stav_vyr/dok_es/mandat/mand_cen/m112.pdf, checked on 4/10/2024. 

64 Thünen-Institut für Holzforschung (2023b): Process Data set: KVH structural timber (German average). Available 
online at https://oekobaudat.de/OEKOBAU.DAT/datasetdetail/process.xhtml?uuid=7aba3603-0689-4da5-8d24-
fd92ae398d07&version=00.00.032, checked on 4/10/2024. 

65 Nicholls, David L.; Bumgardner, Matthew S. (2018): Challenges and Opportunities for North American Hardwood 
Manufacturers to Adopt Customization Strategies in an Era of Increased Competition". Forests 9, no. 4: 186. 
Available online at https://doi.org/10.3390/f9040186 

Confidential information for the sole benefit and use of the European Commission. 

Page 35 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

incineration of the timber was assumed for energy recovery. Regarding the impact categories of 
biogenic GWP and LULUCF GWP, considerable amounts of biogenic carbon are considered as 
negative emissions (carbon sink) in the product phase and are released in the end-of-life stage 
through incineration (more than 9-fold than the total fossil GWP). Overall, the balance of the 
biogenic carbon equals 0. 

Table 11. Percentage share of fossil GHG emissions in each module for an example EPD of M112 
product family based on strength-graded and finger-jointed structural timber.66 (absolute values 
rounded). 

LCA stages 

Product 

Construction 

Use 
Stage 

A1 

14 

A2 

0 

A3 

4 

A4 

11 

A5 

B1-B7 

C1 

5 

3 

End of lie 

C2 

1 

C3 

7 

C4 

0 

Beyon
d life 
cycle 
D 

-229 

30% 

0% 

9% 

25% 

12% 

10% 

3% 

21% 

0% 

Module 
GWP Fossil 
(kgCO2e/1m3
) 
% 

- 

- 

66 EPD: https://manage.epdhub.com/?epd=HUB-1064  

Confidential information for the sole benefit and use of the European Commission. 

Page 36 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2. Assessment aspects 

To evaluate the pros and cons of different methods for the implementation of climate information 
into the CPR acquis harmonized product (group) standards, a set of tangible assessment 
aspects need to be defined. The aspects are defined in such a way, that they are mutually 
exclusive, meaning that the content overlap is reduced to a minimum. The aspects consider 
various factors as well as trade-offs for each potential approach. The concrete scope of each 
aspect will be described in the following sub-chapters.To cluster the aspects, five 
overarching assessment categories are defined. Under each category, multiple assessment 
aspects are clustered. Table 12 provides an overview of the categories and assessment 
aspects. The nomenclature introduced as the ID will subsequently be used to refer to the 
different aspects. 

Table 12. Overview of assessment aspects  

Category 

1. GHG & product 
coverage 

2. Data quality 

3. Feasibility of 
implementation 

4. Compatibility with 
legislation 

ID 

1a 

1b 

1c 

1d 

1e 

1f 

2a 

2b 

2c 

3a 

3b 

4a 

4b 

5a 

5b 

Aspect 

GHG emission coverage and system boundaries (Scope 1/2/3) 

Coverage of product families in methodology  

Comparability & product specific rules  

Diversification of GWP impact category  

Rules for mass balance 

Rules for allocation67 

Data quality assurance of methodology 

Quality & availability of datasets 

Fraud resilience of methodology 

Ease of use for manufacturers & customers 

Feasibility for authorities 

Compatibility with EPBD  

Compatibility with other legislation 

Consideration of CCU, CCS emission (mitigation) impacts 

Consideration of recycled and re-used content 

67 Under rules for allocation, we assess how allocation of GHG emissions to byproducts and sub-systems is 
approached in the different methods. It is important that these are defined as clearly as possible for a hybrid 

Confidential information for the sole benefit and use of the European Commission. 

Page 37 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

5c 

Consideration of energy system aspects (Definition and 
allocation of scope 2 emissions)68)  

2.1 GHG & product coverage [Aspects 1a, 1b, 1c, 1d, 1e, 1f] 

The first category GHG & product coverage focuses on system boundaries applied in the 
methodologies. Furthermore, the set of products considered under the different approaches as 
well as the existence of product specific rules is considered.  

a)  GHG emissions coverage & system boundaries (scope 1,2,3) [1a] 

The CPR requires to “include the product’s environmental sustainability performance over its 
life cycle in respect of the predetermined environmental characteristics listed in Annex II […]” 
(Article 15 (2)). Here, life cycle means the consecutive and interlinked stages of a product’s life, 
from raw material acquisition or generation from natural resources, or in the case of products 
which have previously been incorporated in a construction work, from the latest de-installation 
from the construction work, to final disposal (Definition 59).69 

Depending on the standardization request, the required life cycle stages may differ per product 
family. However, for a method that shall comprehensively represent the GHG emissions of a 
construction product, the required life cycle stages of the standardization request ideally cover 
as much of the GHG emissions occurring along the whole life cycle of a product as possible. In 
terms of system boundaries this means that along a life cycle, both direct and indirect emissions 
(scope 1, scope 2 and scope 3) should be assessed.   

Aspect 1a assesses the share of GHG total emissions covered of a product life cycle. The 
reference for this is a comprehensive LCA considering a cradle to grave approach including the 
production (A1-A3) as well as end-of-life stage (C). The consideration of transportation in stage 
A2, A4 as well as C2 and use cases for stage B may not are all related to assumptions to be 
made in the specific product level. Also, stage C and D include an assumption on disposal and 
recycling cases. Therefore, the consideration of these stages needs to be assessed in more 
detail across the different approaches. 

b)  Coverage of product families in methodology [1b]  

Considering the wide scope of application the method will have across versatile construction 
products covered by the CPR, it is favorable for the method to cover as many of the potential 
construction product families as possible. On the other hand, for the most used and GHG 
intensive products in the construction sector, the method should also focus on the precision of 
the calculations and data quality for these product families. This aspect focusses on the extent 
to which the approach is applicable for the seven considered construction product families 

68 This aspect considers the allocation of renewable energy to the product system, i.e. the allocation of energy to the 
end-product when it is e.g. produced with a share of renewables throughout a fiscal year. 

69 Texts adopted: New Regulation on Construction Products - Wednesday, 10 April 2024, 
https://www.europarl.europa.eu/doceo/document/TA-9-2024-0188_EN.html#title2 

Confidential information for the sole benefit and use of the European Commission. 

Page 38 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

M100, M120, M114, M103, M135, M113, M112 assessed within the scope of this study. In the 
next aspect, the stringency of the approaches for these product families will be further 
assessed. Both aspects need to be considered in close conjunction when drawing conclusions.  

c)  Comparability & product specific rules [1c] 

As the climate relevant information of a product will be included in the product declaration, 
inevitably comparisons between products within one product family will take place. However, 
methods may be differently well suited for comparisons of construction products, meaning 
environmental claims regarding the superiority or equivalence of one product versus a 
competing product of the same group.  

If comparison within the same product family shall be made, the method used under the CPR 
need to ensure, that within one product family, clear calculation and measurement rules for 
GHG accounting exist e.g. in form of product category specific rules. These rules need to 
streamline the chosen system boundaries and calculation/measurement approaches, making 
them an important facilitator for development of a common calculation approach among one 
product family. Furthermore, if more than on approach to a calculation step is allowed or rules 
are loosely formulated, leaving room for alternatives, this can impact the robustness of the 
results. This aspect it is assessing to what degree comparisons are possible within one product 
family using the different approaches, how stringent the measurement and calculation 
approaches are formulated and if product specific rules are provided.  

Generally, direct comparisons between products across product families and their respective 
GWP can only be done properly, when considering their use case and application scenario. 70 

d)  Diversification of GHG impact categories [1d] 

Under the adopted CPR, climate relevant information is covered in the predetermined 
environmental essential characteristics (i.e. impact categories) in Annex II, through 4 impact 
categories71: 

(a)  climate change effects – total; 

(b)  climate change effects – fossil fuels; 

(c)  climate change effects – biogenic; 

(d)  climate change effects – land use and land use change (LULUCF); 

70 Comparative assertions between different product families should be derived from their ‘function’, specific purpose 
on building element or whole-building level to drive a holistic low carbon design in buildings and construction: The 
same purpose on a building (or building element) level can be achieved with different designs using different 
construction products. The amount of material needed to fulfil the purpose, expected lifetime and requirement of other 
composite products differs between construction products. Thus, e.g., comparing the specific GHG emissions per ton 
of construction products from different product families on product level won’t directly lead to meaningful results.  

71EC (2024): New Regulation on Construction Products, adopted Wednesday, 10 April 2024 
https://www.europarl.europa.eu/doceo/document/TA-9-2024-0188_EN.html#title1 

Confidential information for the sole benefit and use of the European Commission. 

Page 39 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Article 15 (3) defines at a product's performance declaration shall cover at least the essential 
characteristics listed in point (a) to (d) of Annex II, from the moment the regulation is adopted. 
The additional 15 impact categories shall progressively be considered in the future. Therefore, 
the mandatory provision of climate aspects (a) to (d) should be possible to be assessed by the 
method. As fossil GWP is a highly relevant impact category at least for high energy intensive 
construction products, the method should offer a highly robust approach for GWP fossil 
considerations. Biogenic and LULUCF climate change effects (or global warming potential 
(GWP) may differ in their relevance for different product families. Therefore, it should 
additionally be considered if sensible cut-off criteria for these impact categories could be 
chosen. However, as carbon removals will be instrumental in achieving the 2040 objective and 
climate neutrality, nature-based carbon removal solutions will play an essential role. Therefore, 
the biogenic and LULUCF portions of the product supply chains will need to be considered 
coherently.  

e)  Rules for mass balance [1e] 

The rules for mass balance define how to allocate different input or output flows for a 
manufacturing process to products. For flows with specific characteristics such as electricity 
from renewable sources, biobased materials, and recycling content as inputs, tracking the 
physical flow or and averaged physical flow may not be expedient for a correct representation of 
the “credit”. Therefore, different approaches to account for the mass balance throughout a 
product supply system is discussed. In the mass balance approach flows with specific 
characteristics are accounted for by using e.g. a “credit account” system. This could in theory 
also be applied to output flows, for example emissions for fossil or biogenic CO2. If multiple 
different mass balancing methods are allowed, comparability of results may be compromised. 
There is not yet consensus across different methodologies and experts, on if and how this 
method should be considered. Under this aspect, the current set of rules for mass balance and 
their specifications are therefore considered regarding their stringency and coherence. 72  

A limited application of mass balancing on production site level seems inevitable, e.g. in a case 
of a steel plant which formerly operated two blast furnaces and one second metallurgy line that 
processes the liquid steel of both furnaces and now replaces one of the blast furnaces with a 
H2-DRI plant. In such a case, the allocation and declaration of two production batches, which 
correlate to the production volume of the H2-DRI plat and the blast furnace respectively, with 
different GHG emission intensities should be allowed. However, the clear connection of the 
product declaration to an actual physical production is essential. Mass balancing beyond the 
allocation of production batches on site level is not favourable. 

72 To illustrate an example for these considerations the ECO EPD Platform follows this principle for guarantees of 
origin: If the Guarantee of Origin applies to a particular electricity or gas supply into the site with its own contract, then 
all products produced using that supply for energy must share in the use of the Guarantee of Origin. If Guarantee of 
Origin have been purchased, for example, for only a proportion of the particular supply into the site, then all products 
produced using that supply for energy must claim the same proportion of the Guarantee of Origin for the supply used, 
it cannot be allocated by an MBA to give different proportions to the products, for example some products using 
100% Guarantee of Origin and others using 0%. https://www.eco-
platform.org/files/download/statements/ECO_2023.12.12_revised-Statement_MBA%2BGOOs.pdf  

Confidential information for the sole benefit and use of the European Commission. 

Page 40 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

f)  Rules for allocation [1f] 

ISO 14044 defines allocation as partitioning the input and/or output flows of a process to the 
product system under study. Since the CPR requires a product level assessment, the rules for 
allocation need to be clearly defined. It is particularly relevant for such products, where 
multifunctional processes occur. In LCA terminology there are two basic rules for allocation of 
attributional aspects: physical and economic allocation73. ISO 14041 states that “where physical 
relationship (i.e. kg, m2, m3, etc.) cannot be established or used as the basis for allocation, the 
inputs should be allocated between the products and the functions in a way which reflects other 
relationships between them. For example, environmental input and output data might be 
allocated between co-products in proportion to the economic value of the products “. This 
degree of freedom has led to different approaches for allocation in carbon footprinting 
methodologies. For the application of a method under the CPR, this aspect needs to be as 
defined more thoroughly. Therefore, the aspect 1 f assesses how clear definitions are made by 
the different methodologies on a consistent allocation approach.  

2.2 Data quality [Aspects 2a, 2b, 2c] 

The second category for the aspect assessment is the data availability and quality. The aspects 
under this category are very relevant for the overall assessment of the method.  

a)  Data quality assurance of methodology [2a] 

The mandatory disclosure of climate relevant information in the product declarations of 
construction products pursuant to the CPR creates an unprecedented liability of this data being 
reported. To ensure a high scientific robustness of the data, data quality needs to be considered 
from multiple angles. Data used as input to the assessment and disclosure of GHG emissions of 
a construction product needs to be complete, consistent and specific. A set of additional factors 
to be consider is listed in the below Table 13. While data quality is assurance is important, it is 
also necessary to consider the trade-offs regarding assessment and measurement efforts. The 
methods applied under the CPR should be specific with regards to the data quality rules. This is 
relevant for both product specific data as well as potential secondary data. In first instance it 
needs to be assessed what defines the “primary”/activity data are.  

73 The consequential approach is an assessment of system level changes. It takes into consideration the market 
response on the production of a certain product. E.g. changes in buying behavior of costumers moving from 
conventional to greener products and the associated avoided GHG emissions. The outcome of a consequential 
assessment is highly dependent on the assumption what the market changes would be. This approach is therefore 
hard to convey to product level and would require a standard use case. Consequential approaches are not 
considered within the scope of this study, as they rely on assumptions regarding avoided burden scenarios.  

Confidential information for the sole benefit and use of the European Commission. 

Page 41 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 13. Factors under the aspect of data quality assurance 

Factor   

Details 

Specific/activity data required for 
mandatory modules 

Recency of data  

Representativeness of data 

Actual measurements are the most direct way of measuring 
GHG emissions. Requiring specific activity data is ensuring 
preciseness and accuracy of calculation results. Primary data 
should always be the first, if not only allowed choice for the 
foreground processes of a product 
Age of data impacts data validity. Provision of requirements 
regarding data age is increasing its potential validity. However, 
update cycles and renewal need to remain feasible for the 
producers to handle 
Data stemming from direct measurements, activity data and 
secondary data sources should be technologically, timely and 
geographically representative to accurately account for direct 
and indirect emissions. Therefore, provision of requirements 
regarding representativeness increases quality of used data 
sources.  

b)  Quality & availability of datasets [2b] 

Primary data should always be the first choice. In particular cases, for instance for small 
suppliers or scope 3 processes, the effort to retrieve primary data may not be proportionate. In 
these cases data gaps may need to be filled with secondary data sources. Regarding the 
datasets for secondary data, multiple aspects can be considered with regards to quality and 
accuracy. As the CPR is providing data, that may impact decision making and commercial 
impact, the methods for use of secondary data need to be highly specified. If secondary 
datasets is used availability of granular dataset ensure consistency for filling data gaps. The 
more data is available as fallback by specific to a process or a product, the higher will be the 
approximation potential of the specific emissions. Under this aspect, the provision of secondary 
datasets, their availability and rules for application are therefore assessed for the different 
methods. 

c)  Fraud resilience [2c] 

To ensure high transparency and validity of the climate information disclosed by construction 
products, effective measures to circumvent fraud should be implemented for the respective 
method. This may include measures reducing the risk for greenwashing both in and outside of 
the EU, such as third-party validation, monitoring systems and public reporting. Factors covered 
under this aspect are outlined in the below Table 14: While measures against fraud are 
important, it is also necessary to consider the trade-offs regarding reporting and monitoring 
efforts. Therefore, this aspect is also related to aspects under the feasibility of implementation 
category.  

Confidential information for the sole benefit and use of the European Commission. 

Page 42 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 14. Factors under assessment aspect “measures against fraud” 

Components   

Details 

Third-party verification system in 
place 

Requirements for third-party 
verifiers 

Validation monitoring system  

Reporting system in place 

A mandatory and independent verification system by third 
parties significantly increases assurance of calculated and 
reported information   
Requirements on the suitability of third-party verifiers exist and 
are stringently implemented 
An independent monitoring body is in place that validates the 
verification process and ensures high level of quality 
management to be implemented 
(Public) reporting increases the accountability of the claim 
towards external stakeholders  

2.3 Feasibility of implementation [Aspect 3a, 3b] 

The third category for the criteria assessment is the feasibility of implementation. The criteria 
under this category are very relevant for the overall assessment of the method and many of the 
trade-offs of the above-described criteria are connected to the feasibility assessment. The 
feasibility of implementation is both relevant for the producers and the consumers and will be 
further detailed under the work for WP2. 

a)  Ease of use for manufacturers & customers [3a] 

As climate relevant information is likely to become a mandatory disclosure requirement under 
the revised CPR, a vast majority of the construction industry will be impacted. This is ranging 
from the manufacturers of the construction products to the designers and planners to customers 
for construction products. For each stakeholder group, administrative feasibility may require 
different aspects to be considered. Therefore, the following Table 15 specifies the aspects per 
stakeholder. As these aspects will be further assessed in detail under work package 2, the 
aspect only provides a high-level directional assessment of the overall administrative feasibility. 

Table 15. Factors under assessment aspect “feasibility of implementation for manufacturers & 
customers” 

Stakeholder 

Details 

Manufacturer 

•  Efforts of calculation, data collection and reporting should be kept to 

•  Familiarity and common use of the method in the market 

a minimum 

Planner 

Customer 

Retrieving information in the desired format and level of granularity and 
focused on climate relevant information needed for the planning and design 
step should be easily readily available and easily accessible  

In addition to readily available and easily accessible data, the customer 
needs to be able to easily assess validity and constraints of the provided 

Confidential information for the sole benefit and use of the European Commission. 

Page 43 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

information and may be inclined to compare the data across different 
products 

b)  Feasibility of implementation for authorities [3b] 

Moving from a voluntary to a mandatory climate information disclosure scheme requires 
authorities to ensure the validity and reliability of the provided information from a legal 
standpoint. This can be ensured by a set of different aspects, which impact the overall 
administrative feasibility of a method to be implemented. Table 16 specifies these aspects. If a 
monitoring system is in place, which monitors the process, the administrative feasibility is higher 
than a monitoring system that needs to be. As these aspects will be further assessed in detail 
under work package 2, the aspect only provides a high-level directional assessment of the 
overall administrative feasibility. 

Table 16. Factors under assessment aspect “feasibility of implementation for authorities”  

Factor   

Details 

Internal monitoring 

In case of internal monitoring to be considered, an implemented available 
internal monitoring system should be used to create minimal effort for 
authorities    

External monitoring 

In case of external monitoring to be considered, a readily available external 
monitoring system can be used 

2.4 Compatibility [Aspect 4a, 4b] 

This assessment criteria category regroups three criteria regarding the regulatory compatibility 
of the different methods. The focus lies here on the compatibility both regarding regulation on 
construction products on building level and regulation regarding both product life cycle 
considerations and regulations concerning respective product families. 

a)  Compatibility with EPBD [4a] 

The compatibility of the methods to the current provisions under the EPBD are an important 
prerequisite for a successful implementation and use of the method. The aspect will therefore 
be focused on assessing the compatibility to the provision under the EPBD regarding whole life 
carbon. As the details for the provisions are currently further developed, this assessment will 
need to be further adapted along with further detailing of the building level requirements. The 
EPBD requires the following aspects see Table 17: 

Confidential information for the sole benefit and use of the European Commission. 

Page 44 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 17. Components under assessment aspect “compatibility with EPBD”   

Components   

Details 

Unit 

Scope 

 kgCO2e/m2 

Averaged for one year of a reference study period of 50 years. 

Reporting of Modules 

Reporting of all A, B, C and D modules separately 

Calculation basis  

Climate impact categories  

EN 15978, calculation approach for A1-A3 and D as defined under EN 
15804+A2 

Characterization factors of LCIA according to EN 15804. EN 15978  
requires one total GWP value. In the EN 15804+A2  the climate impact 
categories are split into four different reported categories:  

•  Climate Change Total;  
•  Climate Change Fossil;  
•  Climate Change Biogenic Removals and Emissions;  
•  Climate Change Land Use and Land Use Change 

b)  Compatibility to other legislation or other approaches [4b] 

Since the method applied under the CPR and the CPR acquis is embedded into a 
comprehensive set of regulations, the compatibility to other regulation is relevant in the broader 
scope. Section 1.2 provides an overview of regulation that may be considered regarding 
broader application of the method. Since each one of the methods may be compatible with 
different legislations, the overall aspect can only represent a high-level assessment of how well 
the methods fits into the current regulatory scope. In addition, there may be product specific 
regulations and approaches (see details under product families), which are to be considered in 
addition to the listed regulations.  

2.5 Additional aspects [Aspect 5a, 5b, 5c] 

1.  Consideration of CCU, CCS emission (mitigation) impacts [5a] 

Carbon Capture and Utilization (CCU) and Storage (CCS) technologies are increasingly 
becoming measures for the reduction of carbon emissions of products. While in many cases the 
technology is still in a pilot phase, it is likely that CCU and CCS technologies will have 
considerable impacts on the GHG emission balance of products, particularly energy intense 
products such as cement and steel. Therefore, the methodologies under the CPR should have a 
clear approach on how to attribute emission reductions or this should be under development. 
The consideration of CCU or CCS in the respective approach can contribute to a more future-
proof and technology open assessment of construction products.  

Confidential information for the sole benefit and use of the European Commission. 

Page 45 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2.  Consideration of recycled and re-used content [5b] 

The use of recycled and re-used content to produce construction products becomes an 
increasingly important measure not only for reducing the resource footprint of a product but also 
to decrease its carbon intensity. Therefore, the consideration and allocation of recycled and re-
used content in both the upstream and downstream supply chain of a product is a relevant 
aspect that should in the be considered by the respective method. As they can be different 
approaches to the attribution of recycled content, the method should clearly describe the 
approach to be taken.74 When considering the end of life of a product, however, it is important to 
note that the end-of-life scenario (C) and the beyond the life cycle scenario (D) can be highly 
uncertain as they may change over time, differ in different European contexts and with changing 
technologies.  

When reintroducing used products as secondary material, they are not excluded from the scope 
of application of the CPR. As soon as a product falls under the CPR definition of construction 
product (Article 2(1) of the CPR), compliance of the product with the performance requirements 
and conditions for placing them on the market has to be proven.  

Therefore, products that fall under the CPR, like for instance loadbearing bricks, will have to go 
through a new CPR assessment in order to prove their compliance both with regards to 
performance, but also e.g. regarding potential contamination limits. The relevance and nature of 
stage D appears may additionally differ per product family. For some products families, 
secondary products cannot as easily be reused for the same structural purpose. This is for 
instance the case for wood and metal products after a long lifespan. Therefore, the 
considerations of stage D may need to be assessed per product family.  

In general terms the end-of-life recycling should remain separate in the calculation of the bulk 
emissions of the production phase. Offsetting emissions based on reuse at the EoL may impact 
the overall emission result. However, they may also be reasons, why mass balance accounting 
principles may be appropriate (see for this aspect 1f).  

This aspect will therefore consider how end of life is treated in the methods with the focus on the 
use of secondary material as input to the production process.  

3.  Consideration of energy system aspects (definition & allocation of scope 2 

emissions) [5c] 

Regarding the evolving energy system, there are multiple aspects to be considered. The 
allocation of the energy inputs and evaluation of their sustainability can be a relevant factor for 
the carbon intensity of a construction product. Therefore, an elaborate consideration and 
allocation of these potential reducing and avoided emissions is a relevant aspect. Overall, the 
assessment approach can be divided into three approaches, as outlined in Table 18. 

74 Approaches may vary between cut-off of the recycled material as soon as it leaves the primary supply chain, 
closed loop or circular footprint formulas. 

Confidential information for the sole benefit and use of the European Commission. 

Page 46 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Under this aspect the methods are analyzed regarding their rules for scope 2 emission 
allocation75 and their consideration of requirements regarding power purchase agreements 
(PPA) or guarantees of origin. 

Table 18. Factors under assessment aspect “Consideration of energy system aspects ”  

Approach 

Details 

Market based 

Power purchase agreements from “clean” energy sources are seen as 
relevant measures to reduce direct emissions from the product 
production stage. The market-based approach allows for the 
consideration of individual power purchase agreements. Some methods 
however do not consider the market-based approach as favorable, as it 
may disincentivizes the decarbonization efforts to be focused on local 
grids and on the efficiency first principle. Some argue that market-based 
approach should only be allowed in the regional scope e.g., Europe and 
under very strict requirements regarding the certification of the “clean” 
energy. 

Location based 

Consideration of the local grid emission factor, provided by the utility, as 
regional or geographic average. This incentivizes the decarbonization 
efforts to be focused on local grids but also reduces potential for impact 
on decarbonization efforts by producers e.g., by buying green energy 
through power purchase agreements. 

Onsite energy generation 

Additionally, the onsite generation of renewable energy becomes an 
increasingly relevant measure for the decarbonization of the industrial 
sector. Here questions arise around which energy fuels are considered 
sustainable e.g., regarding biofuels and RFNBOs.  

75 Rules for allocation of e.g. shares of renewable energy over a fiscal year may also be closely 
connected to mass to comprehensive mass balance approach. 

Confidential information for the sole benefit and use of the European Commission. 

Page 47 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

3. Analysis of the different approaches 

This chapter presents the results of the core analytical work of WP 1. For each approach, we 
first present the criteria-based analysis and then we elaborate on the coverage of the seven 
product families in the respective approach. 

3.1 PEF  

The Product Environmental Footprint (PEF) methodology has been developed by the European 
Commission as the recommended tool for assessing and communicating the environmental 
impacts of products and supporting various sustainability initiatives of the European 
Commission76. For example, PEF can be used to support European policies as a methodology 
for product-related legislation. Its specified intended applications are to support product 
sustainability analyses as well as Business-to-Business (B2B) and Business-to-Consumer 
(B2C) communication. To enable the comparison of products’ and organizational environmental 
performance, Product Environmental Footprint Category Rules (PEFCRs) are developed by 
stakeholders together with sector experts.  

During the pilot phase (2013-2018), 19 PEFCRs (covering hot and cold-water supply pipe 
systems, metal sheets, thermal insulations, decorative paints, intermediate paper products, 
photovoltaic electricity production, uninterrupted power supply, rechargeable batteries, IT 
equipment, leather, t-shirts, household liquid laundry detergents, food and beverage products) 
have been established77. During the transition phase (2019-ongoing), some of the PEFCRs of 
the pilot phase are being updated. Furthermore, other PEFCRs are being developed (e.g. 
aircrafts, apparel and footwear, cut flowers and potted plants, marine fish, space products, 
synthetic turf, touristic accommodations). 

See Table 19 below for more details on the PEF methodology. 

Table 19. Overview of PEF methodology 

Component 

PEF 

Developers 

Status 

JRC 
- Current: Dec. 2021 
- Planned revision: to completed by end 2025 / early 2026 
- Following revision: approx. by 2030 

76 Damiani, M., Ferrara, N. and Ardente, F., Understanding Product Environmental Footprint and Organisation 
Environmental Footprint methods, EUR 31236 EN, Publications Office of the European Union, Luxembourg, 2022, 
ISBN 978-92-76-57214-5, doi:10.2760/11564, JRC129907. 
https://publications.jrc.ec.europa.eu/repository/handle/JRC129907  

77 European Commission (2022b): Results and deliverables of the Environmental Footprint pilot phase. Available 
online at https://wayback.archive-it.org/org-
1495/20221004164603/https:/ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm#final, checked on 
4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 48 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Component 

PEF 

Objective 

Method for regulatory application; usable by businesses for internal (value chain 
management) and external applications (environmental claims and comparative 
assertions to support consumers in decision making). 

Legally 
mandated 

LCA method recommended by the Commission; voluntary use unless required 
differently by specific legislation 

Audience 

B2B and B2C 

Products 

All goods and services 

Calculation 
basis 

Developed based on ISO 14040-44, International Life cycle Reference Database 
Handbook; ISO 14067, PAS 2050, GHG protocol and others 

Table 20 presents the analysis of the PEF methodology based on the pre-defined assessment 
aspects.  

Confidential information for the sole benefit and use of the European Commission. 

Page 49 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

ID  Aspect 

Analysis 

Key findings  

Table 20. Analysis of the PEF methodology 

1a 

GHG emission 
coverage and system 
boundaries (Scope 
1/2/3) 

All life cycle stages (cradle to grave) are mandatory 
in the assessment, for final products, requiring 
assumptions on scenarios of use and EoL For 
intermediate products a cradle to gate assessment is 
sufficient. All final products that are sold on the 
market and fall under the CPR therefore need to 
consider all life cycle stages. Within the assessment, 
scope 1, 2 and 3 emissions are considered.  

1b 

Coverage of product 
families in methodology  

Generalist method, under which all product families 
could be covered  

1c 

Comparability & product 
specific rules  

Product Environmental Footprint Category Rules 
(PEFCR) define clear guidelines for scope, 
calculation, use case and end-of-life scenarios. To 
date only very few product families have a readily 
available PEFCR as reported in Table 29. 

PEF is a comprehensive LCA-based method to assess 
the carbon emissions of a product along its life cycle. 
For final products covered under the CPR, each life 
cycle stage would have to be assessed and reported 
including stages B, C and D, which are based on future 
assumptions of use and disposal scenarios. On one 
hand this allows for the most comprehensive 
assessment of a product along its life cycle GHG 
emissions but also is connected to highly uncertain 
assumptions. The requirements of the PEF go beyond 
the requirements of the CPR regarding the use phase 
scenario. Regarding the EoL stage default 
disposal/recycling scenarios should be defined for each 
product category.  

Since all products could be covered under the PEF, a 
high level of harmonization would be created within the 
construction products but also beyond e.g. regarding 
products that are covered by the ESPR. 

Through a set of clear guidelines on data and 
methodological choices, comparisons within one 
PEFCR allow for a highly coherent assessment within 
one product family. If applied under the CPR, use case 
and end-of-llife scenarios could be defined coherently 
across all construction products, which would even 
enable comparative assertions across different product 
families regarding a similar function. However, the 
process of creating PEFCR is relatively complex and 
requires a lot of resources (both market experts but 
also within the regulatory bodies, as the Commissions 
review is required at multiple points): To date the 
construction sector has not been comprehensively 

Confidential information for the sole benefit and use of the European Commission. 

Page 50 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1d 

Diversification of (GWP) 
impact category  

Under PEF all three GWP impact categories (fossil, 
biogenic and LULUCF) are to be assessed. The 
characterization factors for biogenic CO2 uptakes 
and emissions within the impact assessment are set 
to zero. Regarding the LULUCF category, indirect 
land use changes are only to be considered when 
specified in the PEFCR. In addition to GWP, 15 
midpoint impact categories are furthermore 
mandatory. All impact categories can be aggregated 
into a single score to identify hotspots. 

1e  Rules for mass balance  

Rules for mass balance can be defined within 
PEFCRs. PEF does not allow for allocating 
(temporary) CO2 removals or other credits from 
biogenic sources within the supply chain. A circular 

addressed, as the EN 15804 is more commonly used. 
Product specific rules under the EN 15804+A2 could 
potentially be harmonized within a PEFCR approach, to 
reach this level of coverage. In case of introducing this 
method as default under the CPR, capacity for new 
PEFCRs development/adaptations is needed. 

The revised CPR requires an initial mandatory 
assessment only of the GWP impact categories. 
However, a mandatory declaration of the full list of PEF 
indicators by 2031 (and in some Member States 
potentially earlier) will be required. Therefore, an 
assessment in accordance with PEF provides the 
potential for future use, already today. According to 
different experts, however, robustness of the 
methodologies for many indicators is still only 
medium/low. Therefore, these impact categories will 
need to be further refined if they shall become binding 
under the CPR. 78 

Regarding the zero rating of biogenic uptake there are 
discussion in the practicing community, if this method is 
reducing the favorability of bio-based materials, when 
considering cradle-to-gate assessments.79 The zero 
rating is in line with the EU ETS approach but differs 
from the EN 15804.  

For the application under the CPR, rules for mass 
balance should be consistent at least within a product 
family but preferably across different product families to 

78 Robustness levels retrieved from: 
https://www.researchgate.net/publication/342827089_Definition_of_LCA_Guidelines_in_the_Geothermal_Sector_to_Enhance_Result_Comparability  

79 E.g. Cefic position on PEF: Towards an accurate accounting for carbon from biomass in the PEF. https://cefic.org/app/uploads/2022/09/Cefic-position-on-PEF-
Product-Environmental-Footprint-Towards-an-accurate-accounting-for-carbon-from-biomass-in-the-Product-Environmental-Footprint-PEF.pdf  

Confidential information for the sole benefit and use of the European Commission. 

Page 51 

 
 
 
 
 
 
 
 
1f  Rules for allocation 

2a 

Data quality assurance 
of methodology  

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

footprint formula, addresses the issue of multi-
functionality in recycling, reuse and energy recovery 
at the EoL. 

ensure coherency. If PEF is applied under the CPR, 
this needs to be considered. Further details to be 
specified under WP2. 

PEF recommends using a decision hierarchy, where 
subdivision or system expansion are favored, 
followed by allocation. Both physical and economic 
allocation are allowed. Rules for allocation can be 
specified within one PEFCR. 

Each PEFCR specifies for which processes primary 
data (specific data) or secondary data (average or 
proxy data) is used. As stated within the PEF 
methodology, a data need matrix helps to identify 
whether primary data (company specific data) or 
secondary data (average or proxy generic data) 
should be used. If communicated externally, use of 
primary data is required for relevant processes, while 
up to 10% of use of generic data is allowed. Data 
quality rating also provided to check 
representativeness of data and results. Most-relevant 
activity data are those processes, linked to sub-
processes accounting for at least 80% of the total 
environmental impact of the company-specific 
dataset. Company specific dataset in turn should be 
used, if it they are run by the company conducting 
the PEF study or when the process is not run by the 
company conducting the PEF study but that company 
has access to (company-) specific information.  

For the application under the CPR, rules for allocation 
should be consistent at least within a product family but 
preferably across different product families to ensure 
coherency. If PEF is applied under the CPR, this needs 
to be considered. Further details to be specified under 
WP2. 

Through the data need matrix a prioritization of relevant 
data can be conducted. Primary data is to be preferred. 
However, in accordance to a study by Finkbeiner et al. 
(2018)80 in many PEFCR, the use of secondary is 
required for relevant processes. As described in the 
needs matrix, secondary data should be used to 
determine environmental hotspots. When providing 
values that should serve a comparison, primary data 
should be required for all relevant processes in order to 
ensure comparability. 

On the other hand, some industrial stakeholders seem 
to see the data requirements as along the entire supply 
chain as relatively high and efforts to comply with the 
requirements of PEF disproportional. As generally only 
up to 10% use of generic data is allowed by the general 
PEF method, many of the current EPDs on the market 
could not fulfill the requirements.81 

As the the CPR will require third party data validation of 
company specific inputs, the PEF method provides the 

80 Finkbeinder et al (2018) Environmental Footprint: Der Umwelt-Fußabdruck von Produkten und Dienstleistungen, 
https://www.umweltbundesamt.de/sites/default/files/medien/1410/publikationen/2019-01-17_texte_76-2018_environmental-footprint_1.pdf  

81 Informal exchange with LCA praticioners (2024) 

Confidential information for the sole benefit and use of the European Commission. 

Page 52 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Under PEF company specific data is defined as 
directly measured or collected data from one or more 
facilities (site-specific 
data) that are representative for the activities of the 
company (company is used as synonym of 
organisation). It is synonymous to ‘primary data‘. To 
determine the level of representativeness a sampling 
procedure may be applied.  

Regarding company specific data PEF furthermore 
specifies that whenever the sector of the product is 
covered by EU ETS monitoring rules, the user of the 
PEF method should follow quantification 
requirements as set out in Regulation (EU) 
2018/2066 for the processes and GHGs covered 
therein. 
For certain datapoints such as recycling rates, PEF 
provides secondary datasets to be used.  
Furthermore, secondary datasets are to characterize 
by a data quality scoring system to determine their 
appropriateness. Secondary data to be used when 
implementing PEFCR are made available on 
provided Life cycle Data Network Nodes. The 
provision of such a database (current version EF3.1 
to expire in 2025, currently working on EF4.0 version) 
promotes consistency of results. However, the 
number of registered Nodes that provide Entry-Level 
compliant data is limited to 10 datasets. The 
database now merged with UNEP-GLAD (Life Cycle 
Initiative) is currently providing over 13.000 nodes, 
most of them from 2019.82 

right prerequisites for an implementation. It should 
however be further refined, which data needs to be as 
precise as possible and where potentially efforts for 
data collection could be reduced, e.g. by defining cut off 
criteria. 

PEF provides additional support to companies through 
a consistent database of generic datasets to use for 
PEF-LCAs. This is unique to the PEF method and 
provides the basis for practitioners to access similar 
data. Most of the datasets provided on the platform 
however are to be bought.  

Since the PEF method is a comprehensive method 
along the whole life cycle, the need for large amounts 
of potentially secondary data source is relatively high. 
However, the quality assurance parameters in place 
safeguard the use of secondary data. Nonetheless, this 
adds uncertainty to the assessment of the GWP. 

2b 

Quality & availability of 
datasets 

82 European Platform on LCA: https://eplca.jrc.ec.europa.eu/globalLCA.html and GLAD: https://www.globallcadataaccess.org/search  

Confidential information for the sole benefit and use of the European Commission. 

Page 53 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2c 

Fraud resilience of 
methodology 

Mandatory independent verification and validation 
both for internal and external communication 
purposes is prescribed. Minimum requirements for 
verifier(s) as well as the requirement for verification 
and validation are defined under the PEFCR 
guidance (p.147ff.)83 
The process to create a PEFCR in cooperation with 
the EC requires multiple review cycles and expert 
consultations. This ensures a high level of 
transparency, consistency, and consensus.  

3a 

Ease of use for 
manufacturers & 
customers 

LCA is increasingly used as a common methodology 
to assess products. The PEF approach is reducing 
arbitrariness of the different methodologies and 
streamlining their application. However, a relatively 
high level of technical expertise is necessary to 
conduct a PEF study. The method is not yet 
commonly used for the respective product families, 
as the EN 15804+A2 is the predominantly used 
method.  

A comprehensive third-party validation by an 
independent verifier is ensuring sufficient measures 
against fraud.  

An issue that was raised by industrial stakeholders was 
the question of data ownership. As the validation 
procedure requires and extensive reporting of 
background data, the data transfer of potentially 
sensitive data may disincentivizes the use of the 
method.84 

The costs for creating a PEF are still considerable for 
manufacturers and the interpretation capabilities of LCA 
results limited by costumers. However, growing 
regulatory considerations of LCA and growing pressure 
on the construction sector will increase the common 
use of LCAs and scaling will also drive down cost. For 
an implementation of PEF under the CPR the access to 
the methodology should be considered as high priority. 
It would be important to ensure expedient capacity 
building both along practitioners but also for 
independent third-party verifiers. This could for instance 
be increased through a common PEF software for 
construction products, which is programmed on the 
basis of the PEF methodology and potential new 
PEFCR for these products. For the short-term (phase in 
period) a simpler solution should be considered. Cost 
for creating an PEF can be a significant burden in 
particular to small scale companies, which do not only 
have to pay the price for the creation, but also have to 

83 PEFCR guidance_v6.3-2: https://eplca.jrc.ec.europa.eu/permalink/PEFCR_guidance_v6.3-2.pdf  

84 Informal exchange with LCA praticioners (2024) 

Confidential information for the sole benefit and use of the European Commission. 

Page 54 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

3b  Feasibility for authorities 

The creation of a PEF study can be conducted 
independently and has to be verified by an 
independent verification body. The development of 
PEFCR is an even more rigorous system, requiring 
the Commissions review and involvement. 

4a  Compatibility with EPBD  

Moderate/high compatibility with provisions under 
EPBD: Calculation approach for module A1-A3, D 
generally aligned with EN 15978 (and 15804),  

4b 

Compatibility with other 
legislation 

Close connection to the work under the ESPR 

5a 

Consideration of CCU, 
CCS emission 
(mitigation) impacts 

Credits associated with temporary (carbon) storage 
or delayed emissions shall not be considered. 
Emissions compensation can be listed separately 
under additional environmental information. 

invest resources into the internal capacity building and 
preparation of data. This needs to be considered if 
implemented under the CPR and expedient measures 
need to be defined. Proposals for this will be further 
assessed under WP2. 

PEF is increasingly implemented in regulation, such as 
for the carbon footprint of batteries, PV panels, CRM. 
There is no experience with regulatory considerations. 
The third-party validation is independent of the 
regulatory body. However, for the development of 
PEFCR, authorities have to be heavily involved. Since 
a large number of products fall under the CPR, in case 
of introducing this method as default under the CPR, 
capacity building within public authorities needs to be 
considered for expedient implementation. 

Regarding the EPBD provisions all requirements can 
be met. 

ESPR makes several references to PEF for the 
identification and setting of criteria. This is particularly 
relevant for products, that have the same list of 
materials, but are potentially used for different purposes 
e.g. glass or metal products. It is crucial that the 
methods for these product families are as aligned as 
possible to reduce discrepancies between product 
declaration for the producers.  

As CCU and CCS technologies will play a growing role 
in particular in the hard to abeit sectors, it will be 
relevant to consider a future proof concept for CCU, 
CCS credits. As PEF is currently not providing this, a 
more detailed assessment of potential ways would be 
needed. As this in an overarching topic, it will be further 
discussed under WP2. 

Confidential information for the sole benefit and use of the European Commission. 

Page 55 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

5b 

Consideration of 
recycled and re-used 
content 

5c 

Consideration of energy 
system aspects  

PEF provides a circular footprint formula, which 
addresses the issue of multi-functionality in recycling, 
reuse, and energy recovery. The formula is valid for 
all product categories and aims to standardize the 
allocation of credits and burdens in the EoL phase. 
Default data is provided for the quality of secondary 
materials. The formula splits the benefits and 
burdens of recycling (material recovery) between the 
producer using recycled input material and the 
producer of the product that was recycled 

PEF specifies the following: If possible, the 
purchased mix of inputs by the company carrying out 
the PEF study should be modelled (I) i.e. a Market-
based approaches 85. If this is not possible, the 
average mix of the provider should be modelled 
when contractual instruments give a valid basis for 
this (II). The calculation rules include a description of 
what is required from a valid contractual instrument 
(guarantees of origin). If the average mix of the 
provider cannot be determined, the country mix, 
where the company is located, should be modelled 
(III). Furthermore, it states that electricity from the 
grid shall be modelled as precisely as possible giving 
preference to supplier-specific data. If (part of) the 
electricity is renewable it is important that no double 
counting occurs. Therefore, the supplier shall 

As the end of life of a construction product is highly 
uncertain, an end-of-life formula with default values 
may allow for the most possible robust consideration of 
EoL within a product supply chain. However the formula 
creates a type of virtual supply chain, that may be 
representative to a standard case, but is reducing the 
connection to the actual product system. For the 
singular consideration of climate information, a more 
simplistic approach for considering secondary 
resources as input to a supply chain could be suitable. 
However, as soon as other impact categories will be 
considered under the CPR, this approach may become 
relevant again. 
The favoured option for electricity consideration under 
PEF it the use of inputs from the supplier. As these are 
the most specific values, this should be favoured also 
within an application under the CPR. However, concern 
has also been raised that the use of contractual 
instruments such as Guarantees of Origin entail a risk 
for greenwashing. A study by the Swedish Life cycle 
center found, that that key concept such as contractual 
instruments, Guarantees of Origin, tracking and 
tracking systems, residual mix. are not fully defined or 
sufficiently explained in the PEF methodology86 
If a manufacturer does not have access to emission 
data by their supplier, the current PEF approach 
requires to use the energy mix of the country. The study 
argues that this overestimates the significance of 
national borders between countries with interconnected 

85 Market-based approaches are approaches, considering the actual sources of purchased energy based on the direct arrangements an organization may have 
with its suppliers, e.g., in form PPAs 

86 Swedish Life Cycle Center: Modelling electricity in environmental footprints: https://www.life cyclecenter.se/publications/modelling-electricity-in-environmental-
footprints/ 

Confidential information for the sole benefit and use of the European Commission. 

Page 56 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

guarantee that the electricity supplied to the 
organisation to produce the product is effectively 
generated using renewable sources and is not 
available anymore for other consumers. 

electricity grids and henceforth reduces the ability for 
comparison of climate information on product level. A 
fallback or potential primary option to use the European 
electricity mix could be more favourable. However, this 
would have to be considered under certain exemptions, 
such as the production of on-site electricity. Another 
possibility to consider electricity mix would be through 
marginal data (i.e. a consequential approach)87. As 
described under section 2.1 aspect 1d however, 
marginal calculations are highly dependent on the 
assumptions. However an approximation of this has 
been done by Ecoinvent, which provides data for 40 
countries on marginal data from existing or new 
generated plans with projections on the future electricity 
production. 88 
Regardless of the approach for modelling electricity the 
study by the Swedish Life Cycle Center suggests that a 
database with electricity data would benefit the 
approach. 

87 This would mean that the data reflects how a change in the electricity demand affects the electricity production. 

88 Ecoinvent considers each unconstrained energy technology as part of the marginal mix in a country and its contribution to the projected future electricity 
production. https://support.ecoinvent.org/energy  

Confidential information for the sole benefit and use of the European Commission. 

Page 57 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 21 presents the coverage of the analysed product families under PEFCR. 

Table 21. Coverage of the analysed product families under PEFCR 

Product family 

Coverage under PEF 

M100 

M120 
M114 
M103 

Precast concrete (including the 
reinforcing steel)  
Structural metallic products 
Cement 
Thermal insulating product 

Yes, no PEFCR 

Yes, PEFCR exists for metal sheets  
Yes, no PEFCR 
Yes, PEFCR exists for Thermal insulation products (Cellulose 
insulation, EPS, PU and Cellular Glass insulation) 

M135 

Flat glass, profiled glass, and 
glass block products 
M113  Wood based panels 
M112 

Structural timber 

Yes, no PEFCR 

Yes. no PEFCR 
Yes, no PEFCR 

As described under aspect 1a and 1b, PEF is a generalist method, under which all of the 
considered product families could be covered. To date only few product families have a readily 
available PEFCR, which describes product specific footprinting rules. The development of 
PEFCR is described as a complex and long procedure by practitioners. However, as the PEF 
and EN 15804+A2 are further harmonized, existing product specific rules under the EN 
15804+A2 (c-PCR) can be a sufficient basis for the development of respective PEFCR, 
substantially reducing the effort.  

Confidential information for the sole benefit and use of the European Commission. 

Page 58 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

3.2 EN 15804+A2 EPDs (type III EPD)  

The Environmental Product Declaration (EPD) methodology has been developed by the 
CEN/TC 350 Sustainability of Construction works, which is a standardisation committee of the 
European standardisation organisation CEN consisting of industry experts and other 
stakeholders (LCA consultants. government experts, NGOs, etc.) developing standards for the 
EU and global market89. The general purpose of the EPD standard is to support B2B 
communication and regulations. The EPD data is also used for purpose of project-level life cycle 
assessment of construction works under the related EN 15978 and other standards. As of 
today, thousands of companies publish EPDs under the EPD standard. There are two main 
types of EPDs:  

• 

industry-wide EPDs: Industry-wide EPDs are developed for entire sectors, such as the 
cement industry or the steel industry, and provide an overview of the environmental 
performance of average product emissions based on sector wide statistics and averages 
e.g., for cement90.  

•  product specific EPDs: Product specific EPDs, on the other hand, are developed for 

individual products and provide detailed information about the environmental impact of a 
specific product, and therefore hold a higher degree of importance and accuracy when 
compared to industry-wide EPDs. 

See Table 22 below for an overview of EN 15804+A2 EPDs components. 

Table 22. Overview of EN 15804+A2 EPDs 

Component 

Developers 

Status 

Objective 

EN 15804+A2 

CEN/ TC 350, 

- Current: 03 2022 
- Revision: not yet defined 

Method for developing a Type III environmental declaration for external 
communication  

Legally mandated 

No, voluntary scheme 

Audience 

Calculation basis 

B2B and B2C* 
*Standard for B2C communication (EN 17672:2022) 
EN 15804+A2 is embedded into a comprehensive EN framework (see 
Appendix chapter 5.1). The calculation basis is built on ISO 14040-44.  

89 Note: There are also EPDs for construciton products on the market, that do not follow the 15804+A2. However, the 
EN 15804 is a guiding standard particularily fort he European market.  

90 Verein Deutscher Zementwerke e. V. (2020): Process Data set: average cement D. Available online at 
https://oekobaudat.de/OEKOBAU.DAT/datasetdetail/process.xhtml?uuid=d368f4bb-ae22-4e33-b9e4-
22a7b27966c6&version=00.02.000&stock=OBD_2023_I&lang=en, checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 59 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Component 

EN 15804+A2 

Products 

Construction products 

The following Error! Reference source not found. provides an overview of the methodology a
nalysis and the key findings for this method.  

Confidential information for the sole benefit and use of the European Commission. 

Page 60 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

ID  Aspect 

Analysis 

Key findings  

Table 23. EN 15804+A2 (EPD) methodology analysis and key findings. 

1a 

GHG emission coverage 
and system boundaries 
(Scope 1/2/3) 

Under the EN 15804+A2 cradle-to-gate and end-of-life 
modules A1–A3, C1- 4 and stage D are mandatory. The 
beyond life cycle stage is to be reported separately. 
Additional stages are optional. For B2C communication 
the aggregation of the results for Modules A1-C4 is 
allowed, D needs to be reported separately. 

An exemption is made for stage C1- 4: If the product is 
physically integrated with other products during 
installation since they are no longer identifiable at the 
end of life because of a physical or chemical 
transformation process, this stage becomes optional. 
This is for instance the case for cement, where no EPD 
could be found, that reports on stage C and D, as 
cement is usually integrated into final construction 
products like concrete. 

1b 

Coverage of product 
families in methodology  

Generic method for construction products which can be 
applied for all product families 

EN 15804+A2 is an elaborate method to assess 
the carbon emissions of a product along its life 
cycle, considering scope 1, 2 and 3. It does not 
require a use phase analysis, as this is done on 
building level. Considering the results on the 
research for the different product families under 
chapter 1.4, it can be seen, that the way of 
reporting these emissions can differ substantially 
between EPDs published in accordance with EN 
15804+A2. In many cases, stage A1-A3 are 
reported together, while the modules in C are 
reported separately. If the method is implemented 
under the CPR, a more stringent requirement on 
reporting format of the stages should be 
considered. As the specifications under the CPR 
acquis for the product families may differ for each 
product family, consistency within one product 
family would be of highest priority. As envisioned 
under the harmonized standard, speculative 
modules such as transport and end of life should 
be calculated based on default scenarios, which 
can then choose for the use case on building level. 

As this method is focused on construction 
products, adjacent products may be calculated 
based on a different method, e.g. under the ESPR. 
Harmonization of the standards should therefore 
be continued as much as possible to avoid 
discrepancies. 

Confidential information for the sole benefit and use of the European Commission. 

Page 61 

 
 
 
 
 
 
1c 

Comparability & product 
specific rules  

1d 

Diversification of GWP 
impact category  

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Comparisons of products under the EN 15804+A2 are 
possible between same product groups. Comparative 
assertions are only allowed on building level (i.e. 
comparison across product families with the same 
functional use case). Under the EN 15804, product 
category rules can be developed to harmonize 
assessments within one product family. For the 
considered product families 4 c-PCR already exist and 
another 3. are under development (also see Table 24 
and chapter 5.2. c-PCR are subject to consistency 
verification by CEN/TC 350 

Under PEF all three GWP impact categories (fossil, 
biogenic and LULUCF) are to be assessed. Regarding 
the biogenic GWP, the EN 15804+A2 require requires 
the biogenic carbon to be traceable throughout the life 
cycle. Removals of biogenic CO2 (biomass storage) 
biomass or transfers from previous product systems are 
characterized negative values. Emissions of biogenic 
CO2 from biomass or transfer into a new product 
system are characterized by positive values.  
The amount of CO2 uptake and output along the system 
therefore equal to net zero net zero. Biogenic carbon 
within biomass which is transferred through the life 
cycle of is to be reported as LULUCF GWP. Indirect 
land use changes not to be considered in current 
approach. Limitations to the carbon credits: Negative 
values only allowed if sustainable managed forest are 
used and the carbon stock is not reduced. 
In addition to GWP, 12 mandatory and 6 additional 
impact categories are to be assessed.  

c-PCR increases the comparability of construction 
products. However, the system in the first place is 
not designed for product comparison, but to feed 
building calculations. Therefore, while c-PCR are 
increasing consistency, within a c-PCR flexibility 
can remain for some elements, such as declared 
units, allocation procedures, and cut off rules. c-
PCR still allow for a choice of application. If 
applied under the CPR, this margin of choice 
should be minimized to the highest possible 
degree. For instance, a standard declared unit per 
product family should be defined. These 
considerations will be further elaborated under 
WP2. 

The revised CPR requires an initial mandatory 
assessment only of the GWP impact categories. 
However, a mandatory declaration of the full list of 
indicators by 2031 (and in some Member States 
potentially earlier) will be required. Therefore, an 
assessment in accordance with the EN 15804+A2 
provides the potential for future use, already today. 
According to different experts, however, 
robustness of the methodologies for many 
indicators is still only medium/low. Therefore, 
these impact categories will need to be further 
refined if they shall become binding under the 
CPR.  

Confidential information for the sole benefit and use of the European Commission. 

Page 62 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1e  Rules for mass balance  

The EN 15804+A2 does not clearly define rules for 
mass balances. However leading operating bodies, 
such as the ECO Platform, IBU EPD currently suspend 
the use of mass balance within their EPDs. 91 

For the application under the CPR, rules for mass 
balance should be consistent at least within a 
product family but preferably across different 
product families to ensure coherency. Further 
details to be specified under WP2. 

1f  Rules for allocation 

2a 

Data quality assurance of 
methodology  

As stated in clause 4.3.4, allocation procedures shall be 
according to ISO 14044+A1:201892. The basic  
procedures and assumptions used in ISO 
14044+A1:2018 have been refined for the scope of EN 
15804+A2. For multiple products (co-products), the 
materials, energy flows and associated emissions are 
allocated to the different products by process 
subdivision, appropriate physical property, or on the 
basis of revenue contribution, meaning that both 
physical and economic allocation is allowed. 

As stated under clause 6.3.7 specific data derived from 
specific production processes or average data derived 
from specific production processes shall be the first 
choice as a basis for calculating an EPD. An EPD 
describing a specific product shall furthermore be 
calculated using specific data for at least the 

processes the producer of the specific product has 
influence over. Generic data may be used for the 

For the application under the CPR, rules for 
allocation should be consistent at least within a 
product family but preferably across different 
product families to ensure coherency. Further 
details to be specified under WP2. 

The definition of “specific data” and when this data 
is to be used in an EN 15804 assessment is 
described within the standard. However, the 
provisions on particular requirements on what this 
specific data needs to adhere to, remain relatively 
vague. For generic data comprehensive 
requirements in line with the CEN/TR 15941 are 
stated.  

91 https://ibu-epd.com/en/mass-balance-approaches-at-ibu/ 

92 ISO 14044 established a multi-functionality hierarchy, according to which physical allocation should be preferred and only if physical relationships cannot be 
established or used as the basis for allocation, the inputs should be allocated between the products and functions in a way that reflects other relationships between 
them, e.g. economic allocation. According to Pelletier et. al. (2014), despite its current placement in the lowest tier of the ISO 14044 allocation hierarchy, economic 
allocation is one of the most widely applied multi-functionality solutions : https://link.springer.com/article/10.1007/s11367-014-0812-
4#:~:text=Following%20the%20ISO%2014044%20(2006a,In%20practice%2C%20allocation%20in%20proportion  

Confidential information for the sole benefit and use of the European Commission. 

Page 63 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

processes the producer cannot influence e.g. processes 
dealing with the production of input.  

Furthermore, a data quality matrix outlined in Annex E 
shall be applied for relevant data. The term “relevant 
data” is understood as data with a major contribution, 
contributing together to at least 80 % of the absolute 
impact of any core environmental indicators included in 
the EPD, considered over the full life cycle, excluding 
module D, or across those modules of the life cycle 
assessed in the EPD. 

EN 15804 furthermore makes statements on generic 
data quality requirements in accordance with CEN/TR 
15941. 93 

Several freely accessible online databases are in place 
(see 0 ), which provide “EN 15804”-compliant EPDs (in 
some cases a filter option needs to be applied). Some 
countries require EPDs to be used in national regulatory 
regimes, such as Belgium, the Netherlands and France 
(see detailed list Table 40). Data must be made 
available by the EPD issuers in International Reference 
Life Cycle Data System (ILCD) format. 

Additional provisions aiming at prescribing a more 
stringent requirements on selection of data and 
data quality requirements have been for instance 
introduced by the Dutch EN 15804+A2 
regulation.94 

Here requirements on selection, 
representativeness and generic data are provided. 
For further considerations of the application of EN 
15804+A2 this application case and potential 
lessons learned should be retrieved.95  

Data for benchmarking on EPD platforms is easily 
accessible. However, the quality and frequency of 
use of EPDs may differ per country and 
certification body. High risk for inconsistencies 
exists for EPDs, issued under different monitoring 
bodies. For instance, the format of EPDs is not 
unified, therefore each monitoring body has their 
own template of reporting. Mandatory national 
regimes appear to strongly drive the improvements 
of EPD information availability and common use. 
For the application under the CPR, a unified 
database should therefore be considered as is 

2b 

Quality & availability of 
datasets 

93 EN 15941:2024 - Sustainability of construction works - Data quality for environmental assessment of https://standards.iteh.ai/catalog/standards/cen/95f4bf84-
5e4b-4136-b6f9-6fc4ca959886/pren-15941.  

94 Bepalingsmethode milieuprestatie bouwwerken (2022), milieudatabase.nl)https://milieudatabase.nl/media/filer_public/89/42/8942d5dd-8d37-4867-859a-
0bbd6d9fb574/bepalingsmethode_milieuprestatie_bouwwerken_maart_2022_engels.pdf.  

95 We propose to set-up an interview with relevant experts under the work of WP2.  

Confidential information for the sole benefit and use of the European Commission. 

Page 64 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2c 

Fraud resilience of 
methodology 

Mandatory independent verification (according to EN 
14025 and 21930) is required if the results of the 
assessment are communicated externally. Verifiers 
themselves need to be approved by Program Operator. 
In most cases the manufacturer chooses the verification 
body, sometimes verifiers are appointed by the Program 
Operators. EPDs are published in multiple EPD formats 
required by different operators96.  

already under development with the digital product 
passport. 

The EN 15804 can build on a well-established 
monitoring and verification system. EPD program 
operators and verifiers are established in the 
current verification system for many years. 
However, concerns are raised, that although EPDs 
compliant with EN 15804 are required to be 
independently verified, the requirements under the 
EN 15804 are not always applied consistently. 
This can be the combination of two aspects: (1) 
due to EN 15804 design and (2) due to the way 
how scheme providers use the EN 15804. 
Regarding (1) the high flexibility in choices 
regarding assumptions and parameters (e.g., 
declared units and end-of-life scenarios, energy 
accounting methods) can lead to inconsistencies. 
Regarding the (2) a varying stringency on e.g. data 
quality data and/or requirements for validation by 
the verifiers seem to reduce the verifiability of the 
results. Based on a study by Moré et al. only 5% of 
the assessed EPD of one product family, that were 
created in accordance with 15804, included all 
mandatory information required97. Furthermore, it 
appears that quality levels of the licensing and 
monitoring of verifiers by the notifies bodies can 
range significantly. The process to become a 
verifier can range from an extensive assessment 

96 BPIE (2021): ADDRESSING THE HIDDEN EMISSIONS IN BUILDINGS STATUS QUO, GAPS, AND RECOMMENDATIONS FOR ENVIRONMENTAL 
PRODUCT DECLARATIONS AND WHOLE-LIFE CARBON. Available online at https://www.bpie.eu/wp-content/uploads/2021/12/EPD-Factsheet.pdf, checked on 
4/15/2024. 

97 Flávia Bittencourt Moré, Bruno Menezes Galindro, Sebastião Roberto Soares (2022): Assessing the completeness and comparability of environmental product 
declarations. Available online at https://www.sciencedirect.com/science/article/abs/pii/S0959652622035715, checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 65 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

to a simple 3 day course98. This enables a large 
access to verifiers, but quality of the verification 
may be reduced.  

As envisioned under the CPR, this verification 
system will be replaced by third party validation by 
notified bodies under the CPR. I will be of high 
importance to more thoroughly assess the 
Lessons Learned that can be drawn from the 
existing system and other monitoring systems, 
such as the PEF and EU ETS system to ensure a 
robust but feasible system to be implemented. 

EPDs are commonly used in the industry, 
therefore capacity building both on the 
manufacturer and verification side has already 
taken place and can be scaled. Cost for creating 
an EPD can be a significant burden in particular to 
small scale companies, which do not only have to 
pay the price for the creation, but also have to 
invest resources into the internal capacity building 
and preparation of data. This needs to be 
considered, if implemented under the CPR and 
expedient measures need to be defined. Proposals 
for this will be further assessed under WP2. 

Furthermore, for the ease of use for the customer, 
in this case e.g. building planners or architects 
should be further consider harmonization of EPD 
reporting formats and databases. 

3a 

Ease of use for 
manufacturers & 
customers 

EPD according to EN 15804+A2 (and A1) are heavily 
used for the product families. Nonetheless, the 
comprehensive methodology, mandatory independent 
verification of the report as well as preparation of results 
for publication (summary, scope of the study, 
assumptions, manufacturing diagram, EPD declaration, 
name of verifier) require producers to either acquire a 
high level of knowledge competency or to outsource the 
creation to an EPD. Costs for an EPD can range 
between 12,000 – 38,000 € including declaration fees 
for verification (1000-2000 €). Some software services 
offer pre-verified EPD processes potentially reducing 
this cost significantly.99 

98 Based in informal exchange with LCA practitioners as well as research across multiple course offerings. 

99 E.g. OneClick LCA offers pre-verified EPDs as a service: https://oneclicklca.com/software/manufacturing/pre-verified-epd-generator  

Confidential information for the sole benefit and use of the European Commission. 

Page 66 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

3b  Feasibility for authorities 

The voluntary EPD EN 15804+A2 system is set up with 
independent program operators. The methodological 
developments are closely coordinated with the 
CEN/CENELEC Technical Committees. Direct 
involvement in the monitoring by authorities is not 
required. EPDs and the EN 15804 are part of some 
regulations in European countries. A list of current 
implementations of EPDs in national law can be found 
under 5.3. In case of national implementation, program 
operators have become national authorities e.g. in 
Belgium and the Netherlands.  

4a  Compatibility with EPBD  

High compatibility to EPBD: EN 15978, cited in the 
EPBD directly refers to EN 15804 as calculation basis 
for stages A1-A3 and stage D. 

4b 

Compatibility with other 
legislation 

EN 15804 may be compatible to most provisions under 
the ESPR. 

5a 

Consideration of CCU, 
CCS emission (mitigation) 
impacts 

Credits associated with temporary (carbon) storage or 
delayed emissions shall not be considered. 

5b 

Consideration of recycled 
and re-used content 

The end-of-life phase is mandatory to be considered 
under the EN 15804. Reasonable assumption scenarios 
must be given, which will provide information on what 
could happen to the product at the end of life. 

While the voluntary verification and assessment of 
EPDs are following a well stablished system, the 
implementation of the EN 15804 into a regulation 
may require authorities to take over the role as 
program operators or introduce regulations for 
independent program operators. This may entail a 
more harmonized regulation on how the standard 
should be applied universally and across different 
operators. Lessons Learned from the PEF, EU 
ETS and national regulatory implementation 
should be taken into account.  

Regarding the EPBD provisions all requirements 
can be met. 

Since the revision of the EN 15804 in 2019 and 
ongoing efforts to harmonize with PEF, EN 15804 
can be compatible to provisions under the ESPR. 

As CCU and CCS technologies will play a growing 
role in particular in the hard to abate sectors, it will 
be relevant to consider a future proof concept for 
CCU, CCS credits. For the consideration of 
CCU/CCS the methodology could make reference 
to the provisions under the CRCF. CCU/CCS 
would then only be allowed to be used in the 
calculation of the EPD, if a certification according 
to CRCF is in place. This would be a divergence 
from the original EN 15804+A2 logic. Potential 
implications will be further assessed in WP2 

The actual end of life treatment of products may be 
different from how materials will be recovered, re-
used or disposed of at the end of the life of the 

Confidential information for the sole benefit and use of the European Commission. 

Page 67 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

built asset. end-of-life scenarios and practices post 
2050, when the EU plans to be net zero carbon, 
will be very different from today. For example, 
incineration of products containing fossil-derived 
carbon may not be allowable post 2050 without 
carbon capture. This implies that EPDs for 
products that will last for 30+ years will have to 
take these assumptions into account. As 
envisioned under the harmonized standard, 
speculative modules such as transport and end of 
life should be calculated based on default 
scenarios, which can then choose for the use case 
on building level 

Especially in the end-of-life stage as well as in the 
production stage, the EN 15804+A2 does not 
exactly rule the accounting method of the primary 
energy contained in SM, RSF and NRSF as well 
as energy supplied by the standard energy 
system.  For the application under the CPR, rules 
for electricity demand should be consistent at least 
within a product family but preferably across 
different product families to ensure coherency. If 
PEF is applied under the CPR, this needs to be 
considered. Further details to be specified under 
WP2. 

5c 

Consideration of energy 
system aspects  

Renewable and non-renewable primary 
energy employed for energy generation or material use 
is to be accounted for in each life cycle stage. 
Additionally, the inputs and outputs of secondary 
materials (SM), renewable secondary fuels (RSF) 
and non-renewable secondary fuels (NRSF) are to be 
reported. There are no provisions made on the specific 
use of location-based or market-based approaches 100. 
Particular provisions on the electricity grid use (location 
or market-based approach) are made by national EPD 

100 Achenbach, Hermann; Diederichs, Stefan K.; Wenker, Jan L.; Rüter, Sebastian (2016): Environmental product declarations in accordance with EN 15804 and 
EN 16485 — How to account for primary energy of secondary resources? Available online at 
https://www.sciencedirect.com/science/article/abs/pii/S0195925515300664, checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 68 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

program operators for instance by EPD norge101 or the 
UK BRE group102 

101 EPD Norway allows two approaches to be used for electricity, namely a physical national grid mix, or an electricity source with a guarantee of origin. 
https://www.epd-norge.no/getfile.php/1325854-
1664532225/PCRer/NPCR%20Part%20A%20for%20Construction%20products%20and%20services%20070417%20gyldighet%20utvidet%20til%20311222.pdf  

102 When calculating impacts associated with standard energy supply, national or regional average energy models shall be used. Theis requirement may be 
reassessed if evidence from a credible accreditation system can be provided. https://files.bregroup.com/bre-co-uk-file-library-copy/filelibrary/Materials/BRE-EN-
15804-PCR-PN514.rev-0.1.pdf  

Confidential information for the sole benefit and use of the European Commission. 

Page 69 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 24 presents the coverage of the analysed product families under EN 15804. 

Table 24. Coverage of the analysed product families under EN 15804 

Product 
family 

M100 

M120 

Coverage in EN 15804 

Precast concrete 
(including the reinforcing 
steel)  
Structural metallic 
products 

M114 

Cement 

M103 

M135 

M113 

Thermal insulating 
product 

Flat glass, profiled 
glass, and glass block 
products 
Wood based panels 

M112 

Structural timber 

Yes, c-PCR-003 “Concrete and concrete elements” (EN 
16757)103. 

Yes, c-PCR draft “Execution of steel and aluminum structural 
products, and other metal products, for use in construction 
works” (prEN 17662) expected to be published in Q2/2024 
Yes, c-PCR Cement and building lime – Environmental product 
declarations – Product category rules complementary to EN 
15804 [CEN/TC 51] EN (16908/A1) 
Yes, c-PCR-005 Thermal insulation products (EN 16783), 
currently updated prEN 16783:2022, expected publication 
2024 

Yes, c-PCR -009 Flat glass products used in buildings and 
other construction works (EN 17074) 

Ye, c-PCR Wood flooring including parquet (EN standard) is 
being developed by CEN/TC 175, estimated publication date is 
2025. 
c-PCR-006 Wood and wood-based products for use in 
construction (EN 16485:2014)  
Yes, c-PCR-006 Wood and wood-based products for use in 
construction (EN 16485:2014) 

As a generic method for construction products, all the considered product families can be 
covered by the method. Regarding product specific rules, 4 c-PCR already exist and another 3 
are under development (also chapter 5.2.) 

3.3 EU ETS 

The EU ETS covers around 10.000 stationary installations from the energy and industry sectors, 
including cement, steel, aluminum, fertiliser and chemicals. Each installation shall be registered 
under one of the 28 specific activities available reported under the Directive 2003/87/EU Annex 
I104. 

103 CEN (2022a): Sustainability of construction works - Environmental product declarations - Product Category Rules 
for concrete and concrete elements. Available online at https://standards.iteh.ai/catalog/standards/cen/50f0d48d-
b47c-4efd-8e44-80b114f50c63/en-16757-2022, checked on 4/10/2024. 

104 European Commission (EUR-Lex) (2003): Directive 2003/87/EC of the European Parliament and of the Council of 
13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and 
amending Council Directive 96/61/EC (Text with EEA relevance). Available online at https://eur-
lex.europa.eu/eli/dir/2003/87/oj, checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 70 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

The EU ETS focuses on direct emissions (Scope 1) resulting from activities linked to the 
production of industrial products. These emissions can then be allocated to specific products 
and form the basis for free allocations using product intensity benchmarks. EU ETS 
benchmarks for free allocation exist for 52 product categories, with two so-called fallback 
approaches for heat and fuel. Within the EU ETS, free allocation is based solely on the direct 
emissions component (Scope 1). Hence, the EU ETS benchmarks will not allow for the 
unambiguous allocation of embedded emissions for all the construction products in 
scope of this project. 

EU ETS determines the carbon content of products based on the emissions from the industrial 
activities required to produce the specific product. As such, annual emissions reporting under 
the EU ETS focuses on fuel use and process emissions released due to chemical reactions as 
part of the production process (e.g., the release of CO2 in the calcination stage as part of the 
clinker production process). 

The closest estimates to a PCF under the EU ETS are the product benchmarks used for 
calculating free allocations. Free allocations aim to mitigate the risk of carbon leakage by 
reducing the exposure to EU allowance prices for covered entities. They are primarily based on 
product benchmarks, calculated by taking the top 10% most efficient EU installations for each 
product for which a product benchmark is available105. For some sectors, like refineries and 
chemicals, the “product” benchmark does not allow to distinguish between products and uses 
an activity-based approach applied to groups of products (e.g., “refinery products”, “steam 
cracking”, “aromatics”). See Table 25 below for overview of EU ETS emission reporting and 
product benchmarks. 

Table 25. Overview of EU ETS 

Component 

Developers 

Status 

EU ETS 

EC 

EU ETS 1: 2021 
EU ETS 2: 2023 

Objective 

Market mechanism for CO2 pricing to create incentives for emission reduction  

Legally mandated 

Yes, DIRECTIVE 2003/87/EC on establishing a scheme for greenhouse gas 
emission allowance trading within the Community 

Audience 

Regulator and owners of covered installations 

Products 

Defined installations (29 activities and 52 product benchmarks) in energy 
sector and manufacturing industry, Since 2024, emissions from maritime 
transport and municipal waste incineration. 
Under The EU ETS 2 (operational by 2027) will cover GHG emissions from 
fuel combustion in buildings, road transport and other additional industry not 
covered by the existing EU ETS. 

105 There are 52 product benchmarks under the EU ETS, of which 14 consider the exchangeability of fuel and 
electricity. In addition, there are two energy based benchmarks applied to all other activities 

Confidential information for the sole benefit and use of the European Commission. 

Page 71 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Component 

EU ETS 

Calculation basis 

Calculations process and combustion or measurement (direct) 
Activity data multiplied by the relative given factors or directly measured 

Table 26 provides an overview of the analysis of the EU ETS methodology and outlines key 
findings. 

Confidential information for the sole benefit and use of the European Commission. 

Page 72 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

ID 

Aspect 

Analysis 

Key findings  

Table 26. EU ETS methodology analysis and key findings. 

1a 

GHG emission coverage 
and system boundaries 
(Scope 1/2/3) 

The EU ETS Monitoring and Reporting Regulation covers 
all direct GHG emissions (Scope 1) in scope of the EU 
ETS directive within the system boundary of the EU ETS 
installation. Thus, the coverage is limited to manufacturing 
(A3). Comprehensiveness depends on product family (see 
Table 27). 

The EU ETS provides clear rules on the 
emission calculation and measurements of 
energy intensive industrial processes in the 
EU.  

The EU ETS only covers direct emissions 
from manufacturing (scope 1) and a limited 
amount of indirect emissions (scope 2). 
Electricity used for manufacturing processes 
is not considered. Also not considered are 
indirect emissions that occur upstream or 
downstream of the manufacturing process 
(scope 3).  

1b 

Coverage of product 
families in methodology  

No good coverage of the seven product families. 
Essentially, EU ETS covers the production of input 
materials for construction products rather than the 
production of the construction products themselves. 
Although there can be big overlaps of these two 
production steps for some product families, it is not 
generally the case. 
One product family (flat glass, M135) is directly covered 
by an ETS benchmark (float glass). For thermal insulating 
products (M103), some product categories are covered 
(mineral wool, continuous filament glass fibre) while 
others are not (phenolic & spray foam, low carbon wool). 
M100, M120 and M114 are not directly covered in ETS, 
but there are benchmarks that are linked to their core 
input materials. Structural timber (M112) is not covered by 
ETS and neither are wood based panels (M113) covered 
by an ETS benchmark. However, the production facilities 
of M113 are covered by ETS because of their heating 

On process level, over 10,000 installations 
are covered under the EU ETS, of which 
7,500 received free allocation in 2021, 
making it a highly used system in the 
industrial sector, including GHG-emission-
intensive materials for construction 
products.  

Under the current EU ETS, not all of the 
considered product families are covered. EU 
ETS covers the production of input materials 
for construction products rather than the 
production of the construction products 
themself. Although there can be big 
overlaps of these two production steps for 
some product families, it is not generally the 
case. 

Confidential information for the sole benefit and use of the European Commission. 

Page 73 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1c 

Comparability & product 
specific rules  

demands. Thus, one could derive product carbon 
intensities from the GHG emissions of the installations. 
There are no specific rules for PCFs in EU ETS as ETS 
focuses on regulating the production. However, 
comparative assertion is possible on installation level and 
with that also between products of each benchmark since 
ETS have a very robust and elaborate MRV system. 

1d 

Diversification of GWP 
impact category  

Focus on GWP (GHG emissions; and there, even mainly 
focused solely on CO2) only  
Biogenic products are not covered under the current ETS 
scope. However, biogenic source streams are accounted 
for regarding their energy content but counted as zero 
regarding GHG emissions 

1e 

Rules for mass balance  

EU ETS allows for a mass balancing approach for GHG 
emission reporting.106 However, the mass balancing is 
restricted to the individual production facility. 

EU ETS system focuses solely on the 
assessment of GHG emissions and 
therefore only covers the GWP impact 
category. 

Regarding the reporting parameters, the EU 
ETS does not provide differentiated 
reporting of different GWP categories as 
required under Level(s) indicator 1.2. 
Furthermore, the EU ETS reporting does not 
allow for a differentiation of different life 
cycle stages beyond the cradle-to-gate 
scope. In particular, end-of-life 
considerations cannot be included in the 
assessment. 

For the application under the CPR, rules for 
mass balance should be consistent at least 
within a product family but preferably across 
different product families to ensure 
coherency. The EU ETS mass balance 
methodology could be considered for 

106 See Commission Implementing Regulation (EU) 2023/2122 in combination with Art. 25 - Calculation of emissions under the mass balance methodology of 
Implementing Regulation (EU) 2018/2066. 

Confidential information for the sole benefit and use of the European Commission. 

Page 74 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1f 

Rules for allocation 

EU ETS does not prescribe a single method but leaves 
choices.107 It can be measured or calculated.  

2a 

Data quality assurance of 
methodology  

Data quality is very high and all emissions are externally 
audited by independent accredited verifiers to achieve 
‘reasonable assurance’.  

‘Reasonable assurance’ means a high but not absolute 
level of assurance, expressed positively in the verification 
opinion, as to whether the operator's or aircraft operator's 
report subject to verification is free from material 
misstatement. 

2b 

Quality & availability of 
datasets 

The detailed individual emission reporting is not publicly 
available. However, aggregated emission values per 
installation are available as well as the benchmark values 
and average values per benchmark.  

application under COR acquis. Further 
details to be specified under WP2. 

For the application under the CPR, rules for 
allocation should be consistent at least 
within a product family but preferably across 
different product families to ensure 
coherency. If EU ETS is applied under the 
CPR, this needs to be considered. Further 
details to be specified under WP2. 

Since the ETS provides directly measured 
data no uncertainties through assumptions 
and general values occur.  

The EU ETS benchmark data is publicly 
available and updated on a regular basis (~ 
five years). This allows for an easily 
accessible database for manufacturers of 
construction products and ensures that data 
is regularly updated to the current market 
standard. 

107 In the EU ETS context, the terms “inherent CO2” and “transferred CO2” are used to describe the rules for allocation, see Art. 48 & 49 of Implementing 
Regulation (EU) 2018/2066). 

Confidential information for the sole benefit and use of the European Commission. 

Page 75 

 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2c 

Fraud resilience of 
methodology 

EU ETS has a very extensive and robust monitoring, 
reporting and verification system in place. In addition to 
monitoring by national bodies, all ETS emission reporting 
is externally verified by accredited verification bodies 
which are all regulated under the EU accreditation and 
verification regulation108. 

There are national emission trading 
authorities established in each European 
country, which have a long-standing 
expertise in monitoring emission reporting 
systems. The system has been developed 
and optimised in over 19 years of practice.  

The EU ETS Monitoring and Reporting Regulation is well 
established and regularly updated since 2005. It is applied 
by 10,000+ installation across Europe and ensure that 
carbon accounting is aligned across EU ETS sectors on 
an industrial installation level. It is not a direct fit for 
product carbon footprinting purposes. 

EU ETS monitoring and reporting is not feasible for 
product carbon footprinting of construction products, but 
for products that are produced under the EU ETS. ETS 
installations do have a very good understanding of the 
direct emissions resulting from production of their 
materials. Their customers, on the other hand, are 
typically not aware of EU ETS rules and won't understand 
the links between product and corporate (installation level) 
carbon footprinting. 
Basically, the same argument as for producers. 
Authorities, like national emissions authorities, are well 
aware of carbon accounting and could also play a role in 
regulating product specific accounting regulations. 

3a 

Ease of use for 
manufacturers & customers 

3b 

Feasibility for authorities 

Since many of the energy intensive 
construction products are falling under the 
EU ETS, many of these producers are 
familiar with the system and can easily 
extend its use case to other reporting 
obligations.  

108 European Commission (EUR-Lex) (2018): The new EU accreditation and verification regulation. Implementing Regulation (EU) 2018/2067 – verification of data 
and the accreditation of verifiers of operators’ emission reports. Available online at https://eur-lex.europa.eu/EN/legal-content/summary/the-new-eu-accreditation-
and-verification-regulation.html, checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 76 

 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Moderate compatibility: EU ETS does not split out 
different life-cycle stages and methodology is only 
considering direct emissions.  In ETS reporting the 
biogenic share of GHG emissions is reported, which may 
become relevant under EPBD provisions. However, this 
data is not publicly available. 
Limited. The CBAM approach is the bridge from the ETS 
installation perspective to a PCF perspective. 

4a 

Compatibility with EPBD  

Compatibility with other 
legislation 

4b 

5a 

Consideration of CCU, 
CCS emission (mitigation) 
impacts 

CCS is allowed under EU ETS. CCU is under revision and 
will have more detail in updated monitoring and reporting 
regulation to be published around mid-2025. 

The EU ETS acknowledges CCU and CCS 
and is further developed to also 
accommodate onsite electricity generation. 

5b 

Consideration of recycled 
and re-used content 

5c 

Consideration of energy 
system aspects  

The ETS system does not need additional allocation 
methods for recycled and re-used content as lower GHG 
emissions of secondary material is already accounted for 
in the emissions reporting logic of ETS, which works as 
input-output-balancing. 
Not really. Emissions from electricity as an energy source 
in industrial production is not reported under EU ETS 
(scope 2 emissions). [Note: Fossil fuel-based electricity 
production >20 MW itself is regulated under ETS next to 
industrial installations.] Hydrogen is included. 

Confidential information for the sole benefit and use of the European Commission. 

Page 77 

 
 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 27 presents the coverage of the analysed product families under EU ETS. 

Table 27. Coverage of the analysed product families under EU ETS 

Product family 

Coverage in EU ETS benchmarks 

M100 

M120 

Precast concrete 
(including the reinforcing 
steel)  
Structural metallic 
products 

M114 

Cement 

M103 

Thermal insulating 
product 

M135 

M113 

Flat glass, profiled 
glass, and glass block 
products 
Wood based panels 

M112 

Structural timber 

No direct coverage, but benchmarks as well a reporting of 
emissions at installation level for the key materials clinker and 
steel exist. 
No direct coverage, but benchmarks for the key materials hot 
metal, EAF carbon steel, EAF high alloy steel, primary 
aluminium exist. 
No direct coverage, but benchmarks for lime and clinker as key 
materials of cement and limes/binders exist. 
Coverage of some product categories (2/3).  

(a)  Benchmarks for mineral wool and continuous filament 
glass fibre exist and are covered under EU ETS under 
the NACE codes 26.82 and 26.14 respectively.  
(b)  No direct coverage of low carbon mineral wool, low 

carbon organic materials: Coverage of short fibre craft 
pulp and long fibre kraft pulp.  

(c)  Core processes for the production of foam insulation 
materials such as the production of phenol, styrene, 
aromatics are largely covered by phenol acetone and 
styrene.  

Covered by EU ETS benchmark for float glass 

Product family not covered by EU ETS benchmark. However, 
the production facilities of M113 are covered by ETS because of 
their heating demands. Thus, one could derive product carbon 
intensities from the GHG emissions of the installations.  
Not covered by EU ETS. The EU ETS has a zero-emissions 
rating for wood based biomass, although wood biomass needs 
to comply with the sustainability criteria and greenhouse gas 
emission saving criteria for the use of biomass in line with the 
cascading principle. 

3.4 CBAM 

CBAM is closely linked to EU ETS. CBAM is foreseen to replace the free allowances of ETS 
allowances as the main instrument to prevent carbon leakage. CBAM aims to ensure that 
imported products are subject to a regulatory system that applies carbon costs equivalent to 
those borne by EU domestic producers under the EU ETS, resulting in a carbon price that is 
equivalent for imports and domestic products. As opposed to EU ETS which regulates industrial 
production facilities and processes, the CBAM regulation applies to products/the product level. 
The scope of emissions covered is similar to the scope of EU ETS, but not identical. CBAM will 

Confidential information for the sole benefit and use of the European Commission. 

Page 78 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

cover direct emissions and in some cases also indirect emissions109. In focus are the specific 
actual embedded emissions of goods, which in the CBAM case refers to the installation’s 
emissions during the reporting period that are caused by the production process resulting in 
goods. 

CBAM will eventually replace free allocations and has a similar aim – protect European industry 
against the risk of carbon leakage by imposing costs on imported goods, like those faced under 
the EU ETS. At the same time, since it applies to foreign entities, the EU ETS approach has 
been simplified. Although the obligation to submit verified CBAM declarations only starts from 
2027, reporting of embedded emissions in relevant imported goods is already in force since 1 
October 2023 as part of the CBAM transitional period. Regulation (EU) 2023/1773110 lays out 
the approach to calculating embedded carbon for the purposes of CBAM. The principles for 
determining the embedded emissions aim at identifying the relevant production processes for 
goods categories, and to monitor the direct and indirect emissions of those production 
processes. The Regulation allows for an alternative method of calculating embedded emissions 
until July 2024 and further derogations until December 2024, however we will not consider these 
approaches in the assessment.  

The CBAM aims to ensure that the carbon content of imports is more accurately reflected in 
pricing, avoiding carbon leakage. See Table 28 below for the overview of CBAM and its 
components.  

Table 28. Overview of CBAM 

Component 

CBAM 

Developers 

EC 

Status 

2023, implementation until 2026 

Objective 

Market mechanism for CO2 pricing of imported products 

Legally 
mandated 

REGULATION (EU) 2023/956 establishing a carbon border adjustment mechanism 

Audience 

Regulator and products and producers/traders importing covered products 

Products 

Products of sectors from cement, iron & steel, aluminum, fertilizers, electricity, 
hydrogen (transition phase) 

109 In the context of CBAM (Article 3 Definitions of Regulation (EU) 2023/956), direct emissions are defined as 
“missions from the production processes of goods, including emissions from the production of heating and cooling 
that is consumed during the production processes, irrespective of the location of the production of the heating or 
cooling”, while indirect emissions are defined as “emissions from the production of electricity which is consumed 
during the production processes of goods, irrespective of the location of the production of the consumed electricity”. 

110 COMMISSION IMPLEMENTING REGULATION (EU) 2023/1773 

Confidential information for the sole benefit and use of the European Commission. 

Page 79 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Calculation 
basis 

- a determination of the emissions from the source streams based on activity data 
obtained from laboratory analyses or standard values using measurement systems 
and calculation factors;  
-or a determination of the emissions from emission sources by continuous 
measurement of the concentration of the relevant greenhouse gas in the flue gas and 
the flue gas flow rate. 

Table 29 highlights the analysis of the CBAM methodology and lists key findings.

Confidential information for the sole benefit and use of the European Commission. 

Page 80 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

ID 

Aspect 

Analysis 

Key findings (pro/con) 

Table 29. CBAM analysis and key findings 

1a 

GHG emission coverage and system 
boundaries (Scope 1/2/3) 

1b 

Coverage of product families in 
methodology  

1c 

Comparability & product specific rules  

Limited, only covers manufacturing (A3); 
mainly direct emissions; for some products 
also indirect emissions from electricity use 
need to be considered. However, there is the 
possibility of scope extensions, e.g., to 
embedded emissions in the transport of the 
goods 

No good coverage of the seven product 
families. Only one product family is well-
covered (structural metallic products, M120) 
and two others are partially/indirectly covered 
(M100, M114; for details see next section). 
The other four product families are not 
covered. 

High requirements for calculating the 
embodied emission of products. However, 
these requirements mainly specify the system 
boundaries of processes and emissions that 
need to be included per CN code, but not go 
into detail regarding emission accounting 
rules, accuracy requirements, etc. 

Like the EU ETS, CBAM provides clear 
rules on the emission reporting of products 
covered under this system. 

Within the current CBAM system, only a 
few of the considered product families are 
covered.  

1d 

Diversification of GWP impact category   Focus on GWP (GHG emissions) only 

CBAM is only requesting the assessment 
of GHG emissions as a final emission 
factor and is not fully compatible with the 
provisions under the Level(s) indicator 1.2 

Confidential information for the sole benefit and use of the European Commission. 

Page 81 

 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

requiring a split out of different GWP 
categories and life cycle stages.  

1e 

Rules for mass balance  

Similar to EU ETS, CBAM allows for 
installation-level mass balancing. Although the 
CBAM Regulation 2023/956 does not specify 
this topic, the Implementing Regulation for the 
transitional period does.111  

For the application under the CPR, rules for 
mass balance should be consistent at least 
within a product family but preferably 
across different product families to ensure 
coherency. Further details to be specified 
under WP2. 

1f 

Rules for allocation 

CBAM does not specify rules for allocation. 
However, similar to EU ETS, a measurement-
based methodology shall be used.112 

For the application under the CPR, rules for 
allocation should be consistent at least 
within a product family but preferably 
across different product families to ensure 
coherency. Further details to be specified 
under WP2. 

2a 

Data quality assurance of methodology   Not yet in place 

2b 

Quality & availability of datasets 

No actual data published yet, However, 
default values for the transitional period exist 
and are publicly available. 

For the products covered under CBAM, 
currently there are publicly available default 
values provided to be used in the 
transitional period. Also for the definitive 
period, default values will be determined. 

111 See Annex III, B.2 Choice of monitoring methodology & B.3.2 Mass balance method of Implementing Regulation (EU) 2023/1773. 

112 See Annex III, B.8. Requirements for CO2 transfers between installations & B.8.3 Monitoring rules for CO2 transfers of Implementing Regulation (EU) 
2023/1773. 

Confidential information for the sole benefit and use of the European Commission. 

Page 82 

 
 
 
 
 
 
 
 
 
 
 
 
 
2c 

 Fraud resilience of methodology 

Not yet in place 

3a 

Ease of use for manufacturers & 
customers 

3b 

Feasibility for authorities 

4a 

Compatibility with EPBD  

4b 

Compatibility with other legislation 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

A verification system in line with the well-
established EU ETS verification is 
foreseen. 

The system as such is not yet in use and 
therefore no assessment of the practical 
application of the system has yet been 
conducted. 

Not commonly used, transitional period started 
in October 2023, full CBAM will not start until 
Jan 2026; in the future a relevant reporting 
obligation for products that are falling under 
this 

CBAM is a new system. Therefore, reporting 
experience is very limited and not public until 
now. However, several guidelines and 
trainings exist. 

CBAM is a new system. Therefore, experience 
with the system are very limited and not public 
until now. However, several guidelines and 
trainings exist. 

The system as such is not yet in use and 
therefore no assessment of the practical 
application of the system has yet been 
conducted. 

Moderate compatibility: CBAM does not 
differentiate between fossil and biogenic GWP 
and CBAM also only covers GHG emissions 
from manufacturing. 

Reasonable. CBAM is the bridge from the 
ETS installation perspective to a PCF 
perspective. 

CBAM enables different connection points 
to other legislation. It is closely linked to EU 
ETS but provides a product level 
perspective which is more in line with the 
reporting of climate relevant data for 
construction products 

5a 

Consideration of CCU, CCS emission 
(mitigation) impacts 

Currently, there is no recognition of CCUS in 
CBAM. However, as CBAM is supposed to 
mirror EU ETS and ETS recognizes the role of 

Confidential information for the sole benefit and use of the European Commission. 

Page 83 

 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

5b 

Consideration of recycled and re-used 
content 

5c 

Consideration of energy system aspects  

CCUS, some accounting rules for CBAM will 
be added in the future. 
Similar to EU ETS, system does not need 
additional allocation methods for recycled and 
re-used content as lower GHG emissions of 
secondary material is already accounted for in 
the emissions reporting logic. 
Partially, as emissions from electricity used is 
considered from some goods. 

Confidential information for the sole benefit and use of the European Commission. 

Page 84 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 30 presents the coverage of the analysed product families under CBAM. 

Table 30. Coverage of the analysed product families under CBAM 

Product family 

Coverage in CBAM 

M100 

M120 

M114 

M103 

M135 

M113 

M112 

Precast concrete 
(including the 
reinforcing steel)  
Structural metallic 
products 
Cement 

No direct coverage, but the key materials clinker and 
steel are covered. 

Good coverage, many steel and aluminium CN 
codes covered by CBAM 
No full coverage by CBAM; cement clinker and some 
cement types (Portland, aluminous ad other 
hydraulic cement) are covered, no coverage of lime 
(CN code 2522 xxxx) and hydraulic road binders 

Thermal insulating 
product 
Flat glass, profiled 
glass, and glass 
block products 
Wood based 
panels 
Structural timber 

Not covered by CBAM 

Not covered by CBAM 

Not covered by CBAM 

Not covered by CBAM 

3.5 Innovation Fund methodology 

The Innovation Fund (IF) GHG emission avoidance calculation represents the difference between 
the emissions that would occur in a reference scenario, in the absence of the proposed project, 
and the emissions from the project activity over a defined period. The IF GHG emission avoidance 
criteria is composed by two aspects: absolute GHG emission avoidance, and the relative emission 
avoidance.   

The  IF  GHG  methodology  is  able  to  assess  projects  concerned  with  the  avoidance  of  GHG 
emissions in the use and end-of-life phase of products, as well as to account for process inputs 
such  as  biomass,  biofuels,  intermediate  products  and  by-products  of  other  processes,  wastes, 
and  the  use  of  some  feedstocks  or  process  chemicals  that  are  outside  the  scope  of  the  EU 
Emissions Trading System (EU ETS).  

The building sector (via the combustion of fuels) has become eligible to the Innovation Fund by 
being listed in the EU ETS Annex III. Relevant building materials have been in scope of since its 
inception,  by  being  covered  under  Energy  Intensive  Industries  (EII)  and  under  the  use  of 
Renewables and or Energy Storage projects.  

In  the  last  IF  call,  the  GHG  calculation  approach  for  building  projects  that  intend  to  produce 
electricity and/or heat or electricity produced or used from renewable origin, including bio-origin 

Confidential information for the sole benefit and use of the European Commission. 

Page 85 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

for  use  in  buildings  shall  follow  the  renewable  section  (section  4)  of  the  methodology.  This 
includes  bio-heat,  bioelectricity,  as  well  as  projects,  where  bio-waste  is  used  as  feedstock  for 
energy purposes. If the heat or electricity is of a different origin, the project should use EII section 
(section 2) of the methodology. The most direct connection to the CPR provisions may be drawn 
for the use case of a projects whose principal product is an innovative construction material(s) for 
use in buildings. In this case the methodology for activities falling in the energy intensive industry 
sectors should be applied. To fall in one of the energy intensive industry sectors, the principal 
product(s)  must  be  or  must  substitute  a  product  or  function  of  a  product  whose  conventional 
production  is  covered  by  Annex  I  of  the  EU  ETS  Directive.  Generally,  the  method  is  not  fully 
applicable to construction products, as is designed for a project basis and incrementally assumes 
a  change  in  production  or  the  supply  chain  to  be  assessed.  However,  there  may  be  some 
components of the methodology that could be considered for the application under the CPR:  

1.  The methodology applied for the reference case and the project scenario calculation for 
the avoidance calculation under section 2. As this methodology is based on the use of 
EU ETS data, the guidance on integrating EU ETS data into the project could be 
followed, when developing a hybrid approach under the CPR.  

2.  The decision hierarchy according to which the Innovation Fund’s reference scenario 

shall be calculated.  Appendix 2.3 provides a hierarchy of data sources for inputs and 
products, that need to rely on secondary data sources. This data hierarchy provides a 
concise list of data sources, which could be considered as example for the 
implementation under aspect 2b. 

3.  The general approach to account for CCU and CCS technologies as outlined under 

chapter 2.2.1.4 (CCS) and 2.2.1.5 (CCU).  

See Table 31 for different components to the IF GHG avoidance calculation methodology.  

Table 31. Overview of Innovation Fund (IF) GHG avoidance calculation methodology 

Component 

Developers 

Status 

Objective 

Legal mandate 

Audience 

Products 

IF GHG Avoidance Methodology 

EC  

2023 last version published with IF23 NZT Call (EU Funding & 
Tenders Portal (europa.eu)) 

Method for calculating GHG avoided emissions for application and 
performance reporting under Innovation Fund of 10 year operation  
Award criteria for the Innovation Fund and also project 
implementation reporting requirement linked with the grant 
disbursement.  

Regulator 

Energy intensive industries, carbon capture 
and utilisation (CCU), carbon capture and storage (CCS), energy 
storage and renewable energy. 

Confidential information for the sole benefit and use of the European Commission. 

Page 86 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Calculation basis 

Absolute GHG emission avoidance and relative GHG emission 
avoidance, GHG emissions based on EU Emissions Trading 
System (EU ETS) Directive 2003/87/EC, Annex II, some 
components such as the allocation rules is built on ISO 14044 
(Appendix 2.1 of the methodology) 

Table 32 presents the analysis of the Innovation Fund methodology based on the pre-defined 
assessment aspects. 

For an overview of the product families covered under the Innovation Fund methodology, see 
Table 33. 

Confidential information for the sole benefit and use of the European Commission. 

Page 87 

 
 
 
 
 
 
 
  
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

ID 

Aspect 

Analysis 

Key findings  

Table 32. Innovation fund methodology analysis and key findings.  

1a 

GHG emission coverage and system 
boundaries (Scope 1/2/3) 

1b 

Coverage of product families in 
methodology  

1c 

Comparability & product specific rules  

1d 

Diversification of GWP impact category  

GHG emissions for each life cycle stage shall 
be included in the calculations for the 
reference scenario, including any relevant 
emissions corresponding to “inputs”, 
“processes (incl. carbon capture)”, 
“combustion (principal products)”, “end of life 
(principal products)”, and “non-principal 
products”. The system boundary defines the 
set of processes. 

Projects intending to produce innovative 
construction materials for use in buildings. 
Activities falling under principal product(s) that 
substitute a product or function of a product 
whose conventional production is covered by 
Annex I of the EU ETS Directive 
The approach is designed to compare the 
project’s principal product(s) emission with a 
reference case or an equivalent function(s) to 
the project’s principal product(s).  
Methodology consistent with the EU ETS 
approach, with the focus is on process 
emissions. Removal of CO2 is accounted for 
no matter if it is in from of fossil or biogenic 
GWP. Biogenic CO2 shall have an emission 
factor of zero. Upstream emissions from land 
use changes may be considered in particular 
cases but are generally excluded from the 
emission calculation 

The methodology captures the emissions 
of all life cycle stages for the principal 
product. The scope is set by the defined 
processes. This means that depending on 
these boundaries, consideration if life cycle 
stages may vary depending on the principal 
product.  

Coverage of energy intensive construction 
products (in accordance to EU ETS).  

Comparison of products with an equivalent 
function is possible. The comparison 
criteria are used to score projects from a 
multiple sectors not only buildings.  

No consistent consideration of biogenic 
and LULUCF carbon emissions.  

1e 

Rules for mass balance  

No explicit mention of rules for mass balance. 

n/a 

Confidential information for the sole benefit and use of the European Commission. 

Page 88 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

1f 

Rules for allocation 

2a 

Data quality assurance of methodology  

2b 

Quality & availability of datasets 

2c 

 Fraud resilience of methodology 

Rules for allocation shall follow the decision 
hierarchy as stated under ISO 14044 
(Appendix 2.1) 
The identification of elastic inputs into “de 
minimis” (small contribution to the overall 
emissions) and “significant inputs” is required 
following section 2.2.2.1. The calculation 
needs to be specific to the project however 
benchmarks and other sources in accordance 
with the data hierarchy under appendix 2.3 are 
to be used.  
For calculation of fuels the approach provides 
the IF fossil fuel comparator is provided. An 
inputs data hierarchy is provided, stating 
sources to be used for calculation purposes 
(European Commission 2024) 
Each application is reviewed by CINEA and 
checked for consistency. In general 
beneficiaries shall obtain, record, compile, 
analyse and document monitoring data, 
including assumptions, references, activity 
data and calculation factors in a transparent 
manner that enables the checking of 
performance achieved during the operation of 
the project. 

Aligns with EN 15804+A2 

Values are generally based on secondary 
data sources. 

The hierarchy for datasets makes this a 
very tangible methodology for the 
application. 

A monitoring, reporting and verification 
system for the disbursement and 
knowledge sharing is required.  

3a 

Ease of use for manufacturers & 
customers 

Application of method in practice has been 
shown to create a high administrative burden 
both for projects applying for the fund but also 
for CINEA.  

The calculation of emissions is complex, 
and IF applicants need to invest into 
internal capacity building or outsource the 
application. 

3b 

Feasibility for authorities 

Each application is reviewed by CINEA and 
checked for quality and credibility of the 
calculation of GHG emission avoidance 
potential. 

The EC institution CINEA is well 
acquainted with the methodology as it has 
been applied for different large-scale calls 
under the Innovation Fund over the last 

Confidential information for the sole benefit and use of the European Commission. 

Page 89 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

4a 

Compatibility with EPBD  

No direct connection to the provisions under 
the EPBD.  

No direct connection to the provisions 
under the EPBD. 

years. Overall, the method requires a 
relatively high administrative involvement. 

4b 

Compatibility with other legislation 

5a 

5b 

Consideration of CCU, CCS emission 
(mitigation) impacts 

Consideration of recycled and re-used 
content 

5c 

Consideration of energy system aspects  

The fossil fuel comparator differs from 
comparator values used in the REDII because 
the IF methodology (in order to align with EU 
ETS) does not consider the emissions from 
extraction and transport of crude oil, nor the 
transport and distribution of the final fuel 

Provision for considerations of CCU, CSS are 
described in detail in the approach, as it is a 
centerpiece of application. 

Provisions for the consideration of emissions 
released at the end of life shall be covered 
under the product box EoL. 

For the consideration of renewable energy the 
approach provides a separate methodological 
section (section 4). Grid electricity consumed 
is to be calculated as having zero associated 
GHG emissions, which corresponds to the 
projected average emissions of the 2050 grid 
electricity mix. 

The innovation methodology is directly 
aligned with the benchmark system of the 
EU ETS. The methodology provides clear 
guidance on a hierarchical structure of 
calculation approaches when benchmark 
data is not directly available.  

Provision for considerations of CCU, CSS 
are described in detail in the approach, as 
it is a centerpiece of application. 

Provisions on EoL are relatively high level 
and do not account for a more complex 
supply chain model. 

Emission factor for scope 2 are effectively 
excluded in the methodology. 

Confidential information for the sole benefit and use of the European Commission. 

Page 90 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 33. Coverage of the analysed product families under Innovation Fund methodology 

Product 
family 

M100 

Coverage in IF methodology 

Precast concrete (including 
the reinforcing steel)  

M120 

Structural metallic products 

M114 

Cement 

M103 

Thermal insulating product 

M135 

Flat glass, profiled glass, and 
glass block products 

M113 
M112 

Wood based panels 
Structural timber 

Not directly mentioned, can fall under Covered under 
Energy Intensive Industries (EII) Iron & steel and 
Cement & lime 
Methodology section 2 to be applied for Energy 
Intensive Industries (EII) Iron & steel 
Methodology section 2 to be applied for Energy 
Intensive Industries (EII) Cement & lime 
Methodology section 2 to be applied for Energy 
Intensive Industries (EII) Glass, ceramics & construction 
material (combination of the EU ETS activities 'Glass 
and ceramics', 'Mineral wool' and 'Gypsum') 
Methodology section 2 to be applied for Energy 
Intensive Industries (EII) Glass, ceramics & construction 
material (combination of the EU ETS activities 'Glass 
and ceramics', 'Mineral wool' and 'Gypsum') 
Can be covered as a product substitute of a EII product 
Can be covered as a product substitute of a EII product 

Confidential information for the sole benefit and use of the European Commission. 

Page 91 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

3.6 PCF for intermediate products 

The current work of JRC on the development of Product Carbon Footprint (PCF) method for 
intermediate products covered by EU ETS and CBAM, which may serve as one potential hybrid 
approach to be considered. In general, the approach aims at combining values of GHG 
emissions calculated and quantified under the EU ETS scheme/CBAM (mainly scope 1 and 
partially scope 2) and with additional emissions occurring throughout the entire life cycle of an 
intermediate product (scope 3), considering the PEF methodology.  

The PCF method includes cross cutting standardized rules for the calculation of a PCF such as 
system boundaries, declared units and characterization factors. The approach proposes two 
separate stepwise approaches to calculate the PCF of EU manufactured products and imported 
products. Furthermore, specific calculation rules to determine individual GHG emission 
contributions identified as relevant for the PCF of both EU and imported products in a life cycle 
perspective are defined under the approach. As the current status of the PCF report has only 
been circulated recently for internal review, this hybrid approach will not be further assessed at 
this point. The design and considerations of the hybrid will however be highly relevant under 
WP2, where the results of the study will be further assessed.  

3.7 Fit-for-purpose hybrid approach 

[Note: This section reflects our suggestion for a “fit-for-purpose hybrid approach” based on 
discussions in the timeframe of work package 1, until 15 April. Based on exchanges and 
discussions thereafter, the suggested hybrid has evolved. These further developments will be 
reflected in the work of WP 2.] 

As a central point of reference, the design of the hybrid approach should consider the feasibility 
of applying this approach in practice. Under the present application case of introducing climate 
relevant information in the CPR acquis, the approach should therefore be designed in a way 
that the multitude of different construction product producers can make use of the method in the 
most simple and straight-forward way. Based on this hypothesis, the hybrid approach could be 
designed including the following considerations:  

1.  The simplest way to include emission factors into product declarations for construction 
products would be to provide default values to the producers. These default values 
may be based on a calculation approach derived from the methodology used to calculate 
a generic EPD based on EN 15804-A2. 
To account for the variety of products within one product family, e.g., different insulation 
materials, the provision of default values on a subgroup level may be required. 
They should either reflect an average emission or even represent the lower band of 
performance (e.g., worst performing 10%) of products within a product group. 
EU ETS or CBAM could serve as data sources. Regarding EU ETS, the weighted 
average values per benchmark (or a lower to be determined other value) may serve as 
data sources for the generic EPDs of the products covered under EU ETS. Regarding 
CBAM, the default values for the transitional period of the CBAM, which represent ‘world’ 
averages weighted by production volumes. 

Confidential information for the sole benefit and use of the European Commission. 

Page 92 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2.  If a producer wants to diverge from the default values, e.g. because the emissions from 
the construction product life cycle would be lower than the provided default value, the 
producer may use the GWP result from a specific EPD created in accordance with the 
EN 15804-A2. To streamline the approach chosen for the EN 15804-A2, additional 
provisions may need to be implemented. 

3.  Generally, the values reported within in the product declaration should be included in 
such a way that the information can be directly used for a comparative assessment of 
different construction product options on building level, meaning that the values would 
need to be reported compatible with the  EPBD, where a delegated act specifying how to 
determine the global warming potential of a building is in preparation. Regarding the 
provisions made under Level(s), at least the following categories should be split out, see 
Table 34 below. The approach would ensure coverage of at least stage A1-A3, C and D 
and the key GWP categories. 

Table 34. Key environmental performance categories for comparative assessment of construction 
products 

GWP total 
GWP carbon 
GWP biogenic 
GWP LULUCF 

A1-3 

X 
X 
X 
X 

C 

X 
X 
X 
X 

D 

X 
X 
X 
X 

In this hybrid scenario all construction products could be covered under the approach. The 
default values would need to be created at least for each product category, potentially sub-
category level. The default values would be applied for all construction products, that are not 
using a product specific EPD. For the product specific EPD the c-PCRs are to be considered 
per product group. Comparative assertions would only be possible on building level. Within one 
product family, the default values would allow for a benchmark comparison. This would require 
additional provisions, such as the definition of a unified reference unit per construction product 
(m3 or t) or both.  

Regarding data quality provisions, the provisions under the EN 15804 would be followed for 
EPDs, through the EPD verification process. For products under the EU ETS, the EU ETS 
default values would apply. The hybrid with default values decreases the amount of effort by 
producers to a very low degree. However, when wanting to update the information to specific 
EPDs, the producer is required to create this at his/her own cost. Potentially it could be 
considered to introduce a “fine” for using the default values, adding 20% of emissions on the 
initial value. The default values would be provided by the authorities. A European database for 
product emission information tracking should be introduced. 

The default values provided to the manufacturers would be in line with the reporting 
requirements under the Level(s) indicator 1.2 (excluding LULUCF) and in turn under the 
provisions of the EBPD. The default values would enable manufacturers to instantly provide 
climate relevant data in their product information. The expansion to provide a specific EPDs 
allows the manufacturers to showcase better performing construction products, giving them an 
incentive to assess their specific product emissions. However, the fit-for-purpose hybrid 

Confidential information for the sole benefit and use of the European Commission. 

Page 93 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

approach would differ from approaches already established both through regulations and in the 
construction sector. 

The provision of default values by an EC institution would require the respective administrative 
body to conduct a comprehensive calculation of default values for a large amount of 
construction families and potentially sub-family level construction product categories. Since the 
CPR stipulates, that the responsibility of the information lies with the manufacturer, this transfer 
of responsibility may not be in line with the CPR requirements. However, if this issue could be 
solved, the effort would still be lower than the effort for all manufacturers to individually provide 
data. Once the system is set up it would mean reduced work for each update cycle of 5 years. If 
the default values are developed consistently by an EU institution, it can be ensured that the 
calculation methodology applied for each construction product is consistent across different 
categories. The assessment of EPDs would be continued by external verification bodies. In 
accordance with the update cycle of EU ETS benchmark data, the default values should be 
updated every 5 years and building on the timeline of the EU ETS 

For the consideration of CCU/CCS the methodology could make reference to the provisions 
under the CRCF. CCU/CCS would then only be allowed to be used in the calculation of the 
EPD, if a certification according to CRCF is in place. This would be a divergence from the 
original EN 15804 A2 logic. 

Recycling content could be allocated in the upstream emissions as defined by the EN 15804 
regarding them as input. End of life considerations would need to always be calculated and 
disclosed separately in stage D. Offsetting of these emissions (if benefits) in the other life cycle 
stages would not be allowed. 

Regarding the energy system, EN 15804 provisions should be expanded to so that the market-
based approach should only be allowed in the regional scope e.g., Europe and under very strict 
requirements regarding the certification of the “clean” energy (providing a certificate of origin). 
Potentially a reduced set-of criteria under the RFNBO Delegated Act could be considered. 

Composite products may not directly be covered by the default values. Guidance would need to 
be given on how default values should be allocated to composite products. This could be done 
in accordance with the basic logic applied under the Innovation Fund emissions avoidance 
calculation. 

3.8  Comparative overview  

The overall objective of WP 1 is to assess the advantages and disadvantages (pros and cons) 
of the selected methodological approaches to include climate relevant information into the 
construction product regulation. The assessment of pros and cons was conducted based on the 
qualitative and quantitative assessment aspects and the in-depth analysis of the individual 
approaches along these aspects as well as for the seven product families.  

The following sections provide an overview of key findings, comparing the different approaches 
with each other regarding the alignment of the current methodologies with CPR provisions, as 
well as requirements by the ToR to provide a scientifically robust methodology for the inclusion 
of climate aspects into the CPR acquis.  

Confidential information for the sole benefit and use of the European Commission. 

Page 94 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Overall, all of the analyzed approaches are comprised of relevant elements to include climate 
information into the CPR acquis, but none of the approaches is perfectly fitted to fulfill the 
purpose without any additional considerations. Each approach has specific strengths, but also 
specific weaknesses when it comes to their suitability. The following comparative overview per 
assessment aspect lists these considerations, which will be the basis for the conclusion and the 
further assessments under WP 2. 

1a 

GHG emission coverage and system boundaries (Scope 1/2/3) 

Regarding the emission coverage, the CPR requires a whole life cycle assessment. However, 
this premise should be put into perspective to the relative importance of the different life cycle 
stages contributing to the total GHG emissions of a construction product need to be considered. 
Furthermore, the comprehensiveness should always be put into relation to the quality of data 
and the efforts related to monitoring and reporting (also see discussion under aspect 2a).  

The harmonized product standards request the authority to choose which LCA stages are the 
most relevant and therefore mandatory for the assessment. As the assessment of GHG 
emissions for the different product families under chapter 3 suggests, 60-80% of the (fossil) 
emissions occur in the product stage (A). In particular, some products such as cement, serve as 
intermediate products, where a cradle to gate assessment appears to be the only sensible 
scope. Therefore, the applicability of methodologies may differ between product families. This 
flexibility should be represented in the approach that is chosen to cover all product families 
under the CPR acquis. In terms of comprehensiveness, PEF offers the most elaborate 
methodology to assess the carbon emissions of any product (including composites and 
intermediates) along its life cycle. With all LCA stages included as mandatory for end products, 
this method requires the definition of standard use cases and scenarios for the life-cycle. As the 
building level assessment is excluded from the CPR scope, this prescriptive method may not be 
fully applicable. On the other hand, defining coherent use cases and EoL scenarios, this may 
also offer the highest ability for comparison of products.  

CBAM is a product-level assessment of emissions, which at the same time mirrors ETS 
regulation. It covers scope 1 and partially scope 2 and 3 emissions, as highlighted in Table 35, 
and it could therefore be highly relevant to further investigate how CBAM and the methodology 
under the CPR acquis can built on each other and be harmonised over time. As CBAM is still a 
fairly new method, detailing of this intersection should be focus of future work.  

The EU ETS methodology covers mainly direct emissions from the material and manufacturing 
phase (A1, A3). Thus, the scope of the EU ETS is relatively narrow. However, for the products 
with highest relevance113, the bulk of fossil GHG occur in the product phase. For these product 
groups, the EU ETS scope may be sufficiently covering the bulk of emissions in a scientifically 
robust way. However, at this stage, the method may not offer the flexibility needed under the 
CPR acquis to report on the entire variety of products.  

The avoided emissions calculation methodology provides guidance on a calculation approach 
based on EU ETS values. Therefore, the scope of the assessment method is similar to the EU 
ETS scope.  

113 EC (2020): Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs: Product families and 
priorities for the CPR Technical Acquis management. 

Confidential information for the sole benefit and use of the European Commission. 

Page 95 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Table 35. System boundaries (Scope 1/2/3) in the different methods 

Scope 1  

Scope 2 

Scope 3 

X 

X 

X 

X 

X 

X 

X 

(X)  

X 

X 

(X) 

Method 

PEF 

EN 15804+A2 

EU ETS 

CBAM 

IF Method 

1b 

Coverage of product families in methodology  

Considering the wide scope of application the method will have across versatile construction 
products covered by the CPR, it is favorable for the method to cover as many of the potential 
construction product families as possible. To date, PEF is the methodology that covers the 
widest range of products as shown in Figure 17, being a method that can generally be applied 
to all products. Among construction products, EN 15804+A2 covers all products as well 

Figure 17. Coverage of products by considered methodologies from high to low 

EU ETS covers the installation specific emission factors of some of the construction products 
considered in the assessment, but not all. To date, CBAM only covers a few construction 
products and there is only limited implementation experience and data available. The IF 
methodology is focused on (energy) projects. Therefore, coverage of products is limited to the 
scope of the projects and cannot be fully compared to the other methodologies. 

1c  

Comparability & product specific rules  

As the climate relevant information of a product will be included in the product declaration, 
inevitably comparisons between products within one product family will take place. If 
comparison within the same product family shall be possible, the method used under the CPR 
need to ensure that within one product family, clear calculation and measurement rules for GHG 
accounting exist, e.g. in form of product category specific rules. The considered methods deliver 
a different degree of comparability. While EN 15804+A2 offers the most product specific rules 
for the assessed product families in form of c-PCR, PEFCR under PEF include more stringent 
rules for product specific groups. To date, the construction sector has not been 
comprehensively addressed under the PEFCR, as the EN 15804 is more commonly used in the 

Confidential information for the sole benefit and use of the European Commission. 

Page 96 

CoveragePEFEN 15804+A2EU ETSIF Methodology (project based)CBAM 
 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

construction sector. Product specific rules under EN 15804+A2 could potentially be harmonized 
within a PEFCR approach, to reach this level of coverage. If the PEFCR approach would be 
applied under the CPR, use case and end of life scenarios should be defined coherently across 
all construction products, which could even enable comparative assertions across different 
product families regarding a similar function. Regarding the process level, EU ETS delivers a 
level of comparability, as measurement and calculation rules are stringently defined. 
Considering EU ETS for final construction products however may require additional product 
specific calculation steps, which need to be defined for each product individually.  

1d 

Diversification of GWP impact category  

Under the adopted CPR, climate relevant information is covered in the predetermined 
environmental essential characteristics (i.e. impact categories) in Annex II, through 4 impact 
categories: GWP total, GWP fossil, GWP biogenic, GWP LULUCF. Both the EN 15804+A2 and 
PEF define rules for the calculation of these categories. Rules for the calculation of biogenic 
carbon differ between the methods. While the EN 15804+A2 requires to account for biogenic 
carbon entering the system as negative, the PEF method requires zero rating. The release of 
biogenic carbon is accounted for in both approaches equally. Therefore, the use of biogenic 
input material and the carbon removal potential is better reflected in the EN 15804+A2 
approach. EU ETS and CBAM do not recognize negative emissions and capture and storage of 
biogenic carbon nor Land, Land Use Change and Forestry (LULUCF). If applied under the CPR, 
this method would need to be complemented by rules on how to consider biogenic carbon and 
LULUCF carbon. As the product assessment showed, biogenic carbon in many cases and 
under the current supply chain set-up is negligible. However, as carbon removals will be 
instrumental in achieving the 2040 objective and climate neutrality, nature-based carbon 
removal solutions will play an essential role. Therefore, the biogenic and LULUCF portions of 
the product supply chains will need to be considered coherently.  

1e 

Rules for mass balance 

With a growing share of e.g. electricity from renewable sources, biobased materials, and 
recycling content, allocation of environmental impacts of inputs and outputs to the physical 
product become more complex. Therefore, mass balance approaches are increasingly being 
discussed, to better reflect this. Both the PEF and the EN 15804+A2 do not state clear guidance 
on which approached should be used in this regard. The EU ETS allows for a mass balance 
approach within the production of a specific installation, focused on inputs and outputs directly 
related to physical units of a specific installation. For the application under the CPR, rules for 
mass balance should be consistent at least within a product family but preferably across 
different product families to ensure coherency. The rules should consider that no disconnection 
between GHG intensity of physical product and product declaration occur, to reflect actual 
environmental impacts of a product.  

1f 

Rules for allocation  

Since the CPR requires a product level assessment, the rules for allocation need to be clearly 
defined. It is particularly relevant for such products, where multifunctional processes occur, for 

Confidential information for the sole benefit and use of the European Commission. 

Page 97 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

instance, producing by-products which are further used by other (construction product) supply 
chains. PEF offers a hierarchy according to which allocation should preferred over economic 
allocation. EN 15804+A2 does allow for both allocation methods equally. As the decision, whether 
physical or economic allocation appear to be more sensible very much depends on the particular 
product supply chain, definitive allocation rules should be defined under the CPR per construction 
product.  

2a 

Data quality assurance of methodology 

The mandatory disclosure of climate relevant information in the product declarations of 
construction products pursuant to the CPR creates an unprecedented liability of this data being 
reported. To ensure a high scientific robustness of the data, data quality needs to be high both 
for primary and secondary data. In particular quality and requirements of primary data need to 
be expediently described in the methods. All considered methods require specific data for 
relevant processes of the foreground system of a product supply chain. However, stringency on 
what “specific” data is, when specific data is required and how strict the system is regarding the 
use of secondary data for relevant processes differs per method. The most advanced method in 
this regard is the EU ETS method, which prescribes highly detailed measurement and 
calculation of the emissions from an installation. PEF only allows for 10% generic data to be 
used in the LCA and a mandatory data needs matrix, prescribing an ambitious requirement as 
well. The EN 15804+A2 system appears to be the most flexible with regards to primary data 
provisions. However, it defines a detailed set of requirements for secondary data. All methods 
require data used as input to the assessment and disclosure of GHG emissions of a 
construction product to be complete, representative and consistent. To ensure high scientific 
robustness of data reported under the CPR, the requirements for specific data need to be as 
high as possible. Therefore, the well-established system for acquiring EU ETS data should be 
implemented under the CPR at least for the product families, that are currently covered under 
the EU ETS. To account for potential trade-offs with regards to feasibility of data collection for 
the manufacturers, it should be further refined, which data along the product life cycle needs to 
be as precise as possible and where potentially efforts for data collection could be reduced, e.g. 
by defining cut off criteria or prescribed scenarios.  

2b 

Quality & availability of datasets 

If the use of secondary data sources is allowed for calculation of carbon emissions under the 
CPR aquis, requirements for the use of these secondary data sources should be described in 
the harmonized standard. The secondary datasets should furthermore be easily accessible, 
validated and comprehensive. The EU ETS offers an unprecedented source for up-to-date 
emission data on industrial processes in Europe. Therefore, this data should be integrated as 
secondary data source under the CPR. Building on the PEF approach, secondary datasets 
should furthermore be characterized by a data quality scoring system to determine their 
appropriateness. Secondary data could furthermore be made available as Life cycle Data 
Network Nodes. For PEF a the EF4.0 database aims at providing this functionality. Ease of use 
and clear guidance on the datasets should be a central design consideration. Processes on 
reporting and updating of data would have to be defined by the CPR system, which should be 
closely aligned with the aspiration of the CPR to introduce digital product passports.   

Confidential information for the sole benefit and use of the European Commission. 

Page 98 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

2c 

Fraud resilience of methodology 

To ensure high transparency and validity of the climate information disclosed by construction 
products, effective measures to circumvent fraud should be implemented for the respective 
method. As described under aspect 2c, multiple components of a verification system are 
necessary to ensure a comprehensive fraud resilient implementation of a methodology.  

Table 36 provides a comparative overview of these components: 

Table 36. Comparative overview of the components for a fraud resilient implementation 

Component   

Comparative overview 

Third-party 
verification system  

Requirements for 
third-party verifiers 

Validation 
monitoring system  

Reporting system 

All considered methods have an independent third-party validation system in 
place.  
All methods have requirements for third-party verifiers in place however 
implementation stringency appears to differ per method, with EU ETS having the 
highest requirements and EN 15804+A2 offering most flexibility to the different 
program operators in the implementation of these requirements. 
An independent monitoring body is in place in all methodologies. For EN 
15804+A2 this is done by independent regional program operators, which 
appear to have high authority over the implementation of the methodology and 
verification. Many program operators have their own additional guidance, where 
specifications are made that are unique to their EPCs. While both the external 
validation system as well as industry knowledge have grown over the years, 
EPDs differ strongly across different geographies. The EU ETS is monitored by 
national authorities. The well-established monitoring system has been optimized 
over the last 19 years of PEF is governed by the EU Commission. For different 
PEFCR independent, cross-European technical secretariats are implemented.  
The EU ETS system has an established reporting system in place, which is 
administered by the national authorities. Results are only communicated to the 
public in an aggregated format. For PEF and EN 15804+A2 reporting is not 
centrally organized. Verified EPDs are published by the different EPD platforms 
and by the companies. Results from PEF assessments need to be published in a 
report by the companies.  

For the implantation of the provisions under the harmonized standard, a verification and 
monitoring system should be set-up, that is building on the existent systems in place. The EU 
ETS system appears to be the most suitable system, as it is based on national authorities, that 
have a long track record in governing and administering the system. If the system shall be built 
on the EN 15804+A2, specifications on involvement of public authorities need to be developed. 
Furthermore, the inconsistencies between different implementing bodies (program operators) 
need to be substantially reduced, to ensure validity of the result across all European 
geographies.  

3a 

Ease of use for manufacturers & customers 

Regarding the ease of use for manufacturers, all methods require capacity building, and resources from 
the manufacturers to implement the methodologies under the CPR acquis reporting. Some methods like 

Confidential information for the sole benefit and use of the European Commission. 

Page 99 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

the EU ETS and the EN 15804+A2 are already commonly used by many manufacturers. However still, in 
both cases, alterations of the methods will be needed to ensure compliance with the CPR. Industrial 
stakeholders confirmed, that the additional data collections efforts required under the PEF methodology 
are relatively high. The ease of use for implementing the provisions under the CPR should therefore 
consider the following aspects: 

•  Easy and low-cost access to suitable reporting software, which guides through the process by 

providing all relevant methodological requirements in an automated way. Regarding the software 
readily available systems should be considered to built on. 

•  Easy access and potentially direct integration of accepted secondary datasets (e.g. EU ETS 

reporting) into the reporting software. 

•  Fall-back options for small and medium enterprises, for which the assessment effort is 

disproportionally high. 

•  Refinement of the method, which data needs to be specific and precise and which steps in the 

supply chain could potentially be covered by generic data and scenarios. 

•  Centrally stored and unified database for external access, which planners and costumers can 

easily integrate into their assessment, by providing compatible data formats. 

3b 

Feasibility for authorities 

Moving from a voluntary to a mandatory climate information disclosure scheme requires 
authorities to ensure the validity and reliability of the provided information from a legal 
standpoint. Therefore, the effort for authorities in the implementation will be high anyway. 
Nonetheless, automated and digitalised systems will also be an important prerequisite for 
authorities to reduce extra efforts. Furthermore, contractual agreements with third-party 
operators, such as under the EN 15804+A2 could reduce efforts for authorities, as long as high-
quality implementation of the provisions can be ensured. Following the example of the EU ETS 
system, nationally organised institutions may be able to best coordinate the assessment of the 
products in the local context. As some European countries have furthermore started to 
implement the EN 15804+A2 in national law. A close assessment of existing set-ups and 
lessons learned should therefore be conducted to allow for a feasible integration of the method 
in practice. 

4a 

Compatibility with EPBD  

Regarding the downstream use of these CPR climate footprint information a coherent use of the 
data at the building level needs to be ensured. The CPR is also mentioned in Annex III of the 
EPBD regarding the use of data. The data therefore needs to be reported in such a way, that it 
can feed into provisions under the EBPD regarding GWP assessment. Details on GWP 
provisions under the revised EPBD are still further developed, such as scope, calculation and 
disclosure requirements and may still be adapted. EN 15978 shall serve as calculation basis, 
therefore only the more elaborate LCA based approaches would currently allow for a direct use 
on building level, as they differentiate between different life cycle stages and GWP impact 
categories. In light of the provisions under the EPBD, the EN 15804+A2 seems to be the 
methodology that will present least problems at the level of a building calculation, because it is 
directly in line with EN 15978, which in turn is the basis for Level(s). Both Level(s) and EN 

Confidential information for the sole benefit and use of the European Commission. 

Page 100 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

15978 are directly mentioned in the EPBD and there is an existing harmony between EN 15804, 
EN 15978 and Level(s).  

4b 

Compatibility with other legislation 

Regarding other legislation in particular the compatibility with the ESPR should be considered, 
as there is a close connection regarding upstream climate information. The methodology for 
assessing environmental impacts under the ESPR is directly related to the PEF method. The 
ESPR makes several references to PEF for the identification and setting of criteria. This is 
particularly relevant for products, that are based on similar intermediate products but are 
produced for different purposes e.g. glass or metal products. It is highly relevant that the 
methods for these product families are as aligned as possible to reduce discrepancies between 
product declaration for the producers. If the PEF method would be used, this alignment is more 
easily reachable. However, also the continuous alignment between EN 15804+A2 and PEF may 
allow for close alignment. As currently developed under the ESPR for metallic products, 
potential hybrids between ESPR and EU ETS may also be thinkable, making an integrated 
approach a feasible option under the CPR.  

5a 

Consideration of CCU, CCS emission (mitigation) impacts 

As stated by the European Commission114 carbon capture and storage will be instrumental in 
achieving the 2040 objective and climate neutrality by 2050. Therefore, it is to be expected that 
the consideration of CCU and CCS technologies will grow in relevance over the coming years. 
The methodology implemented under the CPR should therefore consider the accounting of 
CCU, CCS. Under both the EN 15804+A2 and the PEF method, credits associated with 
temporary (carbon) storage or delayed emissions shall currently not be considered. Under the 
EU ETS, CCS is allowed and CCU is under revision. It is expected that there will more detail in 
an updated monitoring and reporting regulation to be published around mid-2025. 

For the inclusion of CCU and CCS therefore a merged approach may be needed to enable the 
consideration of these technologies. Based on the EU ETS, the EU Innovation Fund, 
established a coherent method to calculate carbon credits for carbon capture and storage 
projects, which could serve as a basis. Furthermore, reference to the provisions under the 
CRCF could be made. CCU/CCS would then only be allowed to be used in the calculation of a 
product carbon footprint, if a certification according to CRCF. 

5b 

Consideration of recycled and re-used content 

The CPR puts particular emphasis on the consideration of resource efficiency. The use of 
recycled and re-used content to produce construction products becomes an increasingly 
important measure not only for reducing the resource footprint of a product but also to decrease 
its carbon intensity. Therefore, the consideration and allocation of recycled and re-used content 

114 EC (2024): Towards an ambitious Industrial Carbon Management for the EU, https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52024DC0062 

Confidential information for the sole benefit and use of the European Commission. 

Page 101 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

in both the upstream and downstream supply chain of a product is a relevant aspect that should 
be considered by the respective method. However, the uncertainty of EoL considerations at the 
end of the life cycle introduce additional complexity and carbon emissions can only be 
estimated. The EU ETS considers recycled content only through potentially reduced energy 
demand in the secondary supply chain of an installation. With the whole life cycle formula, the 
PEF methods aims at establishing a coherent approach to account for credit and burdens that 
occur at the end of life. Furthermore, a dataset for recycling rates are provided. The EN 
15804+A2 takes a slightly different approach, also considering the EoL in the reporting as a 
separate step, but not allowing for offsetting of any credits within the value chain. Both of the 
approaches can be seen as suitable under the provisions of the CPR. To consider a possibly 
simple, but also robust approach it could be considered to provide provisions under CPR that 
define emission reduction rates, when secondary processes are implemented, following the 
PEF dataset approach. This method would need to be further detailed under WP 2. 

5c 

Consideration of energy system aspects  

As stated under aspect 5c, the allocation of the energy inputs and evaluation of their 
sustainability can have a high impact on the overall emissions of a product lifecycle. In particular 
with a growing electrification and introduction of renewable energy sources, the relevance of 
scope 2 emissions increases. Within the considered methodologies, the accounting approach 
for scope 2 emission is heterogeneous. The PEF approach prescribes a hierarchy for 
considering grid emissions, favoring a market-based approach as first choice. The EN 
15804+A2 does not make specific provisions to this, however it appears that different program 
operators do specify particular provisions within their EPD guidance. Considering the EU ETS 
system, scope 2 emissions are accounted for at the source of their production to avoid double 
counting. Therefore, this share of consumed energy does not count into the product level 
benchmarks. Under CBAM, some scope 2 emissions - the GHG emissions from the generation 
of electricity used to produce the goods - are included for some products. As of now, these 
products are cement and fertilisers.115 The list will potentially be extended.  

Considering the coherency that will be needed to correctly report emissions under the CPR, it is 
highly relevant to specify these provisions. Particularly if a hybrid is introduced with EU ETS 
values, the methodological approach needs to be harmonized between the LCA and the EU 
ETS methods, to create meaningful results. 

115 See Regulation (EU) 2023/956, Annexes I minus the goods listed in Annex II. 

Confidential information for the sole benefit and use of the European Commission. 

Page 102 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

4. Conclusion  

The following conclusions can be drawn from our analysis of different approaches for the 
inclusion of product carbon footprint information into the CPR acquis. 

•  All of the analysed approaches are comprised of relevant elements to include climate 
information into the CPR acquis, but none of the approaches is perfectly fitted to 
fulfill the purpose alone: All of the analysed approaches – PEF, EN 15804-A2, EU ETS, 
CBAM – have been designed for specific purposes. The approaches all have specific 
strengths, but also specific weaknesses, when it comes to their suitability to include product 
carbon footprint information into the CPR acquis. 

•  A fit-for-purpose hybrid approach is needed: The CPR acquis regulates a large and very 
important market.116 When assessing the inclusion of climate information into the CPR 
acquis, a focus should lie on practicality, while at the same time ensuring the use of robust, 
correct methodology and information. To ensure both, the used approach should, meet the 
following key requirements: 

o  Ease of use in practical application: Providing climate information for construction 
products should be made as easy as possible for the users. Also, the cost and time 
needed to provide the information should be reduced to a minimum to minimise the 
economic and administrative burden of this regulation. 

o  Provision of default values per regulated product as readily available fallback 

option: To reduce the effort needed per product, readily available default values could 
be made available in an online tool for all regulated construction products. 
Manufacturers could present specific product carbon footprint information for their 
products, e.g., prove that they made improvements and have lower GHG emission 
values. 

•  The Fit-for-purpose approach could be based on the implementation of EN 15804 

through CPR and incorporate improvements for the potential issues identified in this 
study. In general, the suggested approach must be consistent with the regulatory 
framework of the CPR and the applicable legal constraints. 

•  As described in section 3.7, a tailored hybrid approach for CPR can build on the 
existing approaches: A hybrid approach, combining elements of the established 
approaches, could be developed to leverage existing experiences while at the same time 
fulfilling the purposes of the CPR acquis and the needs of everyday use in the construction 

116 Estimations for the market size of the European construction products market differ but all come to a significant 
market size. The estimated annual market volume ranges from €90 billion to €500 billion. Source: EMR (2023): 
Europe Construction Products Market Outlook. Available online at 
https://www.expertmarketresearch.com/reports/europe-construction-products-market.; CEN (2024): Construction. 
Available online at https://www.cencenelec.eu/areas-of-work/cen-sectors/construction/construction-products/, 
checked on 4/10/2024.   

Confidential information for the sole benefit and use of the European Commission. 

Page 103 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

industry. The EN 15804-A2 could serve as a basis for the assessment. EU ETS (and CBAM) 
could serve as data sources. 

•  Applicability of approaches varies across different product families: For some GHG-

emission-intensive products like concrete and cement, carbon intensities covered under the 
EU ETS represent a very high share of the product carbon footprint and with that an 
adequate approximation value. Based on the high level average EPD results, a cradle-to-
gate approach appears to be sufficient for M100 precast concrete, M120 structural metallic 
products, M114 cement and lime, M135 glass, M103a thermal insulating products of mineral 
wool and glass wool. For the other two product families, M113 wood-based panels and 
M112 Structural timber, the end-of-life stage and or recycling, recovery and reuse stage are 
highly relevant to be considered for an accurate GHG emission assessment.  

•  Recycling, reuse and recovery (LCA stage D) should be considered separately: For 
some product families, LCA stage D appears to be more relevant than for other product 
families under their current set up. However, since this is a stage considering the future use 
case of a construction product at its end of life, this stage is highly uncertain and should 
therefore be rather included as an indicative value, reported separately.  

•  Comparative assertions between different product families remain to be derived from 
their ‘function’, specific purpose on building element or whole-building level to also 
drive a holistic low carbon design in buildings and construction: The same purpose on 
a building (or building element) level can be achieved with different designs using different 
construction products. The amount of material needed to fulfil the purpose, expected lifetime 
and requirement of other composite products differs between construction products. Thus, 
e.g., comparing the specific GHG emissions per ton of construction products from different 
product families on product level often won’t lead to meaningful results. Comparative 
assertions should only be made on the basis of comparable function(ality), i.e. being based 
on a ‘functional unit’ that allows for a meaningful comparison due to having a comparable 
function and characteristics in a building element or on whole-building-level. 
This also means that comparing the use phase of a construction product is not helpful on a 
product level, but should only be assessed in the context of a specific purpose/application. 

•  Compatibility to EBPD, EN 15978 and Level(s) framework is key for a successful 

application: As a prerequisite for a coherent use of climate relevant product information at 
the building level, the information needs to be reported in such a way, that it can feed into 
provisions under the EBPD regarding GWP assessment. Details on GWP provisions under 
the revised EPBD are still further developed, such as scope, calculation and disclosure 
requirements and may still be adapted. EN 15978 shall serve as calculation basis, therefore 
only the more elaborate LCA based approaches would currently allow for a direct use on 
building level, as they differentiate between different life cycle stages.  

• 

Implementation timelines of CPR acquis and EPBD need to be aligned: The inclusion of 
climate aspects into the CPR acquis is not only relevant because of the respective 
requirements in the CPR, but also because of requirements in the EPBD that relate to GHG 
emissions of construction products via the embodied carbon of buildings. Thus, to be able to 
fulfil requirements related to embodied carbon and GWP of buildings, information on the 
GHG emissions of construction products needs to be available to be able to fulfil GWP 
requirements on the building level. 

Confidential information for the sole benefit and use of the European Commission. 

Page 104 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Considering the current schedule, the process for the inclusion of climate aspects in the 
CPR acquis may require several years and may not be completed before 2030. However, 
information to assess the GWP potential of buildings is needed before January 2028. 

• 

[Within this project:] Potential readjustment of WP 2117 : The main finding of WP 1 is that 
a tailored hybrid or rather ‘mixed’ approach, which we have briefly described as part of this 
WP 1 report, may be best suited to include climate information in the CPR acquis. However, 
further detailing of this potential hybrid (or ‘mixed’) approach is needed to provide a valuable 
and robust input for the CPR acquis decision-making process. Thus, we suggest 
developing the core elements of this approach as part of WP 2 accompanied by an iterative 
impact assessment. For this, we would reduce the depth of the planned analysis of 
implications of two approaches and shift part of the planned capacity to detailing the hybrid 
(‘mixed’) approach.  

117 WP2: Propose at least 2 methodologies/approaches that can incorporate carbon footprint information in the CPR, 
and elaborate one (selected by the Commission) in detail.  

Confidential information for the sole benefit and use of the European Commission. 

Page 105 

 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

5. Appendix 

5.1 Overview of international and European standards for LCA in 

buildings and construction products  

Table 37. Overview of international and European standards related to the assessment of the life 
cycle-related environmental performance of buildings and construction products 

Level 

Standard 

Title 

Products 

ISO 14040:2006 

Environmental management — Life cycle assessment — 
Principles and framework 

Scope 

World 

Products 

ISO 14044:2006 

Environmental management — Life cycle assessment — 
Requirements and guidelines 

World 

Construction-
products 

ISO 21930:2017 

Construction-
products 

ISO 22057:2022 

Sustainability in buildings and civil engineering works — 
Core rules for environmental product declarations of 
construction products and services 

Sustainability in buildings and civil engineering works – 
Data templates for the use of environmental product 
declarations (EPDs) for construction products in building 
information modelling (BIM) 

Construction-
products 

EN 15804:2012+ 
A2:2019 

Sustainability of construction works – Environmental 
product declarations – Core rules for the product 
category of construction products 

Construction-
products 

EN 15942:2021 

Sustainability of construction works - Environmental 
product declarations - Communication format business-
to-business 

World 

World 

Europe 

Europe 

Building 

ISO/TS 
12720:2014 

Sustainability in buildings and civil engineering works — 
Guidelines on the application of the general principles in 
ISO 15392 

World 

Building 

ISO 15392:2019 

Sustainability in buildings and civil engineering works — 
General principles 

World 

Building 

Building 

ISO 16745-
1:2017 

ISO 16745-
2:2017 

Building 

ISO 20887:2020 

Sustainability in buildings and civil engineering works — 
Carbon metric of an existing building during use stage — 
Part 1: Calculation, reporting and communication 

Sustainability in buildings and civil engineering works — 
Carbon metric of an existing building during use stage — 
Part 2: Verification 

Sustainability in buildings and civil engineering works — 
Design for disassembly and adaptability — Principles, 
requirements and guidance 

World 

World 

World 

Confidential information for the sole benefit and use of the European Commission. 

Page 106 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Building 

ISO 21678:2020 

Building 

ISO 21929-
1:2011 

Building 

ISO/TS 21929- 
2:2015 

Building 

Building 

ISO 21931-
1:2010 (under 
revision) 

ISO/TR 
21932:2013 

Sustainability in buildings and civil engineering works — 
Indicators and benchmarks — Principles, requirements 
and guidelines 

Sustainability in building construction — Sustainability 
indicators — Part 1: Framework for the development of 
indicators and a core set of indicators for buildings 

Sustainability in building construction — Sustainability 
indicators — Part 2: Framework for the development of 
indicators for civil engineering works 

Sustainability in building construction — Framework for 
methods of assessment of the environmental 
performance of construction works — Part 1: Buildings 

World 

World 

World 

World 

Sustainability in buildings and civil engineering works — 
A review of terminology 

World 

Building 

EN 15643:2021 

Sustainability of construction works - Framework for 
assessment of buildings and civil engineering works 

Building 

EN 15978: 2011 
(under revision) 

Sustainability of construction works – Assessment of 
environmental performance of buildings – Calculation 
method 

Europe 

Europe 

5.2 List of PCR documents published and under development 

PCR DOCUMENTS PUBLISHED 

•  EN  16757  Sustainability  of  construction  works  –  Environmental  product  declarations  – 

Product Category Rules for concrete and concrete elements [CEN/TC 229] 

•  EN 16908/A1 Cement and building lime – Environmental product declarations – Product 

category rules complementary to EN 15804 [CEN/TC 51] 

•  EN 17074 Product Category Rules for Environmental Product Declarations for flat glass 
products used in buildings and other construction works (Flat Glass PCR) [CEN/TC 129] 

•  EN 17610 Building hardware – Environmental Product Declarations – Product category 

rules for building hardware [CEN/TC 33] 

•  EN 16485:2014 Wood and wood based products for use in construction 

PCR DOCUMENTS UNDER DEVELOPMENT 

•  prEN 16578 Sustainability assessment – Ceramics sanitary appliances [CEN/TC 163] 

•  prEN  16810 Sustainability  of construction  work  –  Environmental  product  declarations  – 
Product category rules for resilient, textile and laminate floor coverings [CEN/TC 134] 

•  prEN 16783 Thermal insulation products – Product category rules (PCR) for factory made 

and in-situ formed products for preparing environmental product [CEN/TC 88] 

Confidential information for the sole benefit and use of the European Commission. 

Page 107 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  prEN  16904  Plastics  piping  systems  –  Sustainability  of  construction  works  –  Product 

Category Rules (PCR) for plastics piping systems inside buildings [CEN/TC 155] 

•  prEN  16903  Plastics  piping  systems  –  Sustainability  of  construction  works  –  Product 

Category Rules (PCR) for buried plastics piping systems [CEN/TC 155] 

•  prEN  17383  Road  traffic  noise  reducing  devices  –  Sustainability:  Key  Sustainability 

Performance Indicators (KSPI) Declaration [CEN/TC 226] 

•  EN  17213/prA1  Windows  and  doors  –  Environmental  Product  Declarations  –  Product 
category rules for windows, roof windows and external pedestrian doorsets [CEN/TC 33] 

•  prEN 17160 Product category rules for ceramic tiles [CEN/TC 67] 

•  prEN  16485  Round  and  sawn  timber  –  Environmental  Product  Declarations  –  Product 

category rules for wood and wood-based products for use in construction [CEN/TC 175] 

•  prEN  17388-1  Flexible  sheets  for  waterproofing  –  Environmental  product  declaration  – 
Product  Category  Rules  for  bituminous  and  synthetic  flexible  sheets  for  (roof) 
waterproofing – Part 1: Cradle to grave [CEN/TC 254] 

•  prEN 17388-2 Flexible sheets for waterproofing – Environmental product declarations – 
Product Category Rules for bituminous and synthetic flexible sheets – Part 2: Cradle to 
gate with options [CEN/TC 254] 

•  prEN  17328  Complementary  Product  Category  Rules  for  Gypsum-based  Construction 

Products [CEN/TC 241] 

•  prEN  17662  Execution  of  steel  structures  and  aluminium  structures  –  Environmental 
Product Declarations – Product category rules complementary to EN 15804 for Steel and 
Aluminium  structural  products,  and  other  metal  products,  for  use  in  construction  works 
[CEN/TC 135] 

•  EN 16510-1/prA1 Residential solid fuel burning appliances - Part 1: General requirements 

and test methods [CEN/TC 295] 

•  prEN 18001 Curtain Walling — Environmental Product Declarations — Product category 

rules for curtain walling [CEN/TC 33] 

•  EN 14782 Self-supporting metal sheet for roofing, external cladding and internal lining - 

Product specification and requirements [CEN/TC 128] 

•  EN 14783 Fully supported metal sheet and strip for roofing, external cladding and internal 

lining – 

•  prEN  17328  Complementary  Product  Category  Rules  for  Gypsum-based  Construction 

Products [CEN/TC 241] 

Confidential information for the sole benefit and use of the European Commission. 

Page 108 

 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  prEN  17662  Execution  of  steel  structures  and  aluminium  structures  –  Environmental 
Product Declarations – Product category rules complementary to EN 15804 for Steel and 
Aluminium  structural  products,  and  other  metal  products,  for  use  in  construction  works 
[CEN/TC 135] 

•  EN 16510-1/prA1 Residential solid fuel burning appliances - Part 1: General requirements 

and test methods [CEN/TC 295] 

•  prEN 18001 Curtain Walling — Environmental Product Declarations — Product category 

rules for curtain walling [CEN/TC 33] 

•  EN 14782 Self-supporting metal sheet for roofing, external cladding and internal lining - 

Product specification and requirements [CEN/TC 128] 

•  EN 14783 Fully supported metal sheet and strip for roofing, external cladding and internal 

lining - 

5.3 List of national EPD requirements in Europe118 

Country 

Requirement  

Details 

Table 38. National EPD requirements 

Belgium 

EPDs required for sustainability 
marketing claims. 

EPDs to be published in the B-EPD 
program. The Federal Public Service 
Health, Food Chain Safety and 
Environment (FPS Health) is the 
programme operator. Royal Decree 
describes minimum requirements for 
the use of environmental claims for 
construction products and to register 
environmental product declarations in 
a federal EPD database since 2014.119 

France 

Under the RE2020 Building LCA 
legislation environmental claims can 
only be made about construction 
products which are supported by 
EPDs according to EN 15804 +A2120. 

Publication under INIES and PEP 
Ecopassport. The EPD must be in 
French language for the INIES 
program. 

118 Adopted from https://oneclicklca.com/en/resources/articles/guide-to-global-epd-requirements-by-country an 
complemented by other sources 

119 https://energyville.be/en/product/environmental-product-declarations-epds-for-construction-products/  

120 https://oneclicklca.com/en/resources/articles/en-15804a2-epd-data-for-manufacturers 

Confidential information for the sole benefit and use of the European Commission. 

Page 109 

 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Germany 

Federal projects LCA studies require 
the BNB certification, which is based 
on EPDs under EN 15804. 121 

The OKOBAUDAT database is used. 
IBU program is the most common 
choice for EPD publishing.  

Netherlands 

Denmark 

Specific Dutch implementation of EN 
15804 as Assessment Method under 
its building regulations and tender 
procedures for civil engineering 
structures. 122 

EPDs are to be used and published in 
the national NMD database or MRPI 
EPD program.  

As of January 2023, performing an 
LCA analysis has become a 
mandatory requirement for obtaining 
a building permit for most types of 
buildings in Denmark. 123 

Building LCA calculations should 
adhere to the standards set forth in EN 
15978:2012, and Environmental 
Product Declarations (EPDs) should 
align with EN 15804 +A1 or +A2124 

5.4 EU ETS emission factors overview 

Table 39. Emission Factors Benchmarks across different products125  

Benchmark 

1  Refinery products 
2  Coke 
3  Sintered ore 
4  Hot metal 
5  EAF carbon steel 
6  EAF high alloy steel 

Benchmark 
value for 2021-
2025  

tCO2e/t 

Weighted average 
GHG emissions 
intensity of all 
installations in 
2016/2017  
tCO2e/t 

Number of (sub-) 
installations 
using the 
benchmark for 
free allocation 

0,023 
0,2 
0,2 
1,3 
0,2 
0,3 

0,031 
0,3 
0,2 
1,5 
0,3 
0,3 

90 
33 
24 
28 
76 
82 

121 https://www.oekobaudat.de/en.html 

122 https://milieudatabase.nl/media/filer_public/89/42/8942d5dd-8d37-4867-859a-
0bbd6d9fb574/bepalingsmethode_milieuprestatie_bouwwerken_maart_2022_engels.pdf 

123  

124 https: https://bygningsreglementet.dk/Tekniske-bestemmelser/11/BRV/Version-2-Bygningers-
klimap%C3%A5virkning/Kap-1_2//pub.norden.org/us2023-463/appendix-building-lca-and-bim-practices-in-
denmark.html 

125 European Commission (2021): Update of benchmark values for the years 2021– 2025 of phase 4 of the EU ETS. 
Available online at https://climate.ec.europa.eu/system/files/2021-
10/policy_ets_allowances_bm_curve_factsheets_en.pdf, checked on 4/10/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 110 

 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Benchmark 

Iron casting 
7 
8  Pre-bake anode 
9 

[Primary] Aluminium 
10  Grey cement clinker 
11  White cement clinker 
12  Lime 
13  Dolime 
14  Sintered dolime 
15  Float glass 
16  Bottles and jars of colourless 

17 

Bottles and jars of coloured 
glass 

18  Continuous filament glass fibre 
19  Facing bricks 
20  Pavers 
21  Roof tiles 
22  Spray dried powder 
23  Mineral wool 
24  Plaster 
25  Dried secondary gypsum 
26  Plasterboard 
27  Short fibre kraft pulp 
28  Long fibre kraft pulp 

29 

Sulphite pulp, thermo-
mechanical 

30  Recovered paper pulp 
31  Newsprint 
32  Uncoated fine paper 
33  Coated fine paper 
34  Tissue 
35  Testliner and fluting 
36  Uncoated carton board 
37  Coated carton board 
38  Carbon black 
39  Nitric acid 
40  Adipic acid 
41  Ammonia 
42  Steam cracking 
43  Aromatics 
44  Styrene 
45  Phenol/ acetone 
46  Ethylenoxid / Ethylenglykol 

Benchmark 
value for 2021-
2025  

tCO2e/t 

Weighted average 
GHG emissions 
intensity of all 
installations in 
2016/2017  
tCO2e/t 

Number of (sub-) 
installations 
using the 
benchmark for 
free allocation 

0,3 
0,3 
1,5 
0,7 
1,0 
0,7 
0,8 
1,4 
0,4 
0,3 

0,2 

0,3 
0,1 
0,1 
0,1 
0,1 
0,5 
0,0 
0,0 
0,1 
0,1 
0,0 

0,0 

0,0 
0,2 
0,2 
0,2 
0,3 
0,2 
0,2 
0,2 
1,5 
0,2 
2,12 
1,6 
0,7 
0,023 
0,4 
0,2 
0,4 

0,4 
0,4 
1,6 
0,8 
1,1 
1,1 
1,2 
1,5 
0,5 
0,5 

0,4 

0,4 
0,2 
0,2 
0,2 
0,1 
0,8 
0,1 
0,0 
0,1 
0,1 
0,1 

0,0 

0,0 
0,2 
0,2 
0,2 
0,4 
0,2 
0,2 
0,1 
1,8 
0,2 
1,14 
1,9 
0,8 
0,029 
0,6 
0,3 
0,5 

32 
15 
25 
191 
12 
171 
36 
6 
42 
92 

95 

14 
73 
35 
89 
122 
62 
11 
29 
44 
29 
45 

31 

253 
23 
87 
63 
128 
118 
71 
46 
12 
57 
5 
35 
39 
29 
11 
7 
12 

Confidential information for the sole benefit and use of the European Commission. 

Page 111 

 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Benchmark 

47  Vinylchlorid-Monomer (VCM) 
48  S-PVC 
49  E-PVC 
50  Hydrogen 
51  Synthesis gas 
52  Soda ash 
53  Heat Benchmark 
54  Fuel Benchmark 
55  Process emissions 

Benchmark 
value for 2021-
2025  

tCO2e/t 

Weighted average 
GHG emissions 
intensity of all 
installations in 
2016/2017  
tCO2e/t 

Number of (sub-) 
installations 
using the 
benchmark for 
free allocation 

0,2 
0,1 
0,2 
6,84 
0,2 
0,8 
47,3 
42,6 

0,3 
0,1 
0,2 
8,88 
0,2 
0,9 
76,8 
57,9 

20 
16 
8 
49 
10 
12 
6 619 
2 789 

5.5 Common databases for EPDs 

Table 40 provides a non-exhaustive list of EPD databases, that is based on the JRC document 
“indicative list of software tools and databases for Level(s) indicator 1.2” (version December 
2020): 126  

Table 40. Examples for databases for EPD and embodied emission factors of construction 
materials 

Database 

Link 

ACLCA Product Category Rules 
(USA) 

http://www.aclca.org/ 

ASTM EPD (USA) 

Australasian EPD 

https://www.astm.org/CERTIFICATION/EpdAndPCRs.html 

http://www.epd-australasia.com/ 

Base carbone ADEME (France) 

http://www.basecarbone.fr/ 

Bau EPD (Austria) 

http://www.bau-epd.at/en/building-materials-with-
transparency/ 

Bauteil Katalog (Swiss) 

http://www.bauteilkatalog.ch/ch/fr/catalogueconstruction.asp 

BRE Environmental Profiles (UK) 

https://www.bre.co.uk/Environmental_Profiles.html 

BRE Verified EN 15804 EPD (UK) 

http://www.bre.co.uk/greenguide/page.jsp?id=558 

CSA EPD (Canada) 

http://www.csaregistries.ca/epd/about_epd_pcrs_e.cfm 

DAP construcción (Spain) 

http://www.csostenible.net/index.php/es/sistema_dapc 

126 Indicative list of software tools and databases for Level(s) indicator 1.2 (version December 2020): 
https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2021-07/UM3_Indicator-
1.2_list_of_LCA_software_and_databases.pdf 

Confidential information for the sole benefit and use of the European Commission. 

Page 112 

 
 
 
 
 
 
 
 
 
 
 
 
Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

Database 

Link 

DAP Habitat (Portugal) 

http://daphabitat.pt/?page_id=461 

DIOGEN (France) 

www.diogen.fr 

Ecoinvent 

ELCD 

http://www.ecoinvent.org/database/database.html 

http://eplca.jrc.ec.europa.eu/ELCD3/index.xhtml?stock=default 

EPD Danmark (Denmark) 

http://www.epddanmark.dk/site/index.html 

EPD Italy 

http://www.epditaly.it/ 

EPD Latin America 

https://www.epd-americalatina.com/ 

EPD Norge (Norway) 

http://epd-norge.no/pcr/ 

5.6 RFNBO Delegated Acts 

Commission Delegated Regulations (EU) 2023/1184127  and (EU) 2023/1185128 set out 
sustainability criteria for Renewable Fuels of Non-Biological Origin (RFNBOs) and RCFs (Full 
name). These include: 

• Greenhouse gas savings requirement: RFNBOs must achieve a 70% emission reduction
relative to a fossil comparator of 94 g CO2eq/MJ during a period of at most one calendar
month. Overall greenhouse gas content must be below 3.4 kg CO2eq/kg H2 (< 28.2 g
CO2eq/MJ H2), excluding GHG emissions from manufacturing, e.g., renewables,
electrolyser plant;

• Renewable electricity sourcing: Detailed requirements, e.g., for the temporal and

geographic correlation with renewable electricity production;

127 European Commission (EUR-Lex) (2023a): Commission Delegated Regulation (EU) 2023/1184 of 10 February 
2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a Union 
methodology setting out detailed rules for the production of renewable liquid and gaseous transport fuels of non-
biological origin. Available online at https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.L_.2023.157.01.0011.01.ENG&toc=OJ%3AL%3A2023%3A157%3ATOC, 
checked on 2024. 

128 European Commission (EUR-Lex) (2023b): Commission Delegated Regulation (EU) 2023/1185 of 10 February 
2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a 
minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology 
for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological 
origin and from recycled carbon fuels. Available online at https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.L_.2023.157.01.0020.01.ENG&toc=OJ%3AL%3A2023%3A157%3ATOC, 
checked on 4/15/2024. 

Confidential information for the sole benefit and use of the European Commission. 

Page 113 

Support contract for inclusion of climate aspects in the revision of the 
Construction Products Regulation acquis. WP 1 final report 

•  Voluntary certification schemes to prove sustainability of RFNBOs are to be developed 

and acknowledged by the EU (via the planned “Union Database”). 

Table 41. Overview of Renewable Fuels of Non-Biological Origin (RFNBO) Delegated Act 

Component 

RFNBO 

Developers 

Status 

EC 

2023 

Objective 

Defining sustainability criteria for RFNBOs 

Legal mandate 

EU Delegated Regulations on Renewable Hydrogen 

Audience 

Regulator and covered fuel producers  

Calculation 
basis 

Products 

As per Delegated Act 

Recycled carbon fuels (RCFs) and renewable liquid and gaseous transport fuels of 
non-biological origin (RFNBOs) 

The applicability of these criteria in the context of the CPR acquis seems limited. The criteria, 
especially on renewable electricity sourcing, are very extensive and do not seem easily 
implementable. See Table 41 above for the various elements. It will be important to have robust 
verification for low carbon energy sources used. However, the ease of use of this verification is 
of great importance in this context. Thus, rather a further developed system of guarantees of 
origin seems appropriate here. This is a larger discussion that is out of scope here. 

Confidential information for the sole benefit and use of the European Commission. 

Page 114 

 
 
 
 
 
 
 
GETTING IN TOUCH WITH THE EU 

In person 

All over the European Union there are hundreds of Europe Direct information centres. You can find the 
address of the centre nearest you at: https://europa.eu/european-union/contact_en 

On the phone or by email 

Europe Direct is a service that answers your questions about the European Union. You can contact 
this service: 

– by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls),

– at the following standard number: +32 22999696, or

– by email via: https://europa.eu/european-union/contact_en

FINDING INFORMATION ABOUT THE EU 

Online 

Information about the European Union in all the official languages of the EU is available on the Europa 
website at: https://europa.eu/european-union/index_en 

EU publications 

You can download or order free and priced EU publications from: https://op.europa.eu/en/publications. 
Multiple copies of free publications may be obtained by contacting Europe Direct or your local 
information centre (see https://europa.eu/european-union/contact_en). 

EU law and related documents 

For access to legal information from the EU, including all EU law since 1952 in all the official language 
versions, go to EUR-Lex at: http://eur-lex.europa.eu 

Open data from the EU 

The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets from the EU. 
Data can be downloaded and reused for free, for both commercial and non-commercial purposes.