Since January, a line has been circulating in export and sustainability circles: from 8 January 2026, construction products sold in the EU must declare their global warming potential. It appears in consultancy e-books, in software vendors’ landing pages and, in shorthand, in plenty of briefing material — including earlier material of our own. The date is real. It is in the Regulation. But read on its own it is wrong — and for a Thai cement, steel, gypsum or glass exporter planning a budget for 2027, the difference matters.
We went back to the text of the EU Construction Products Regulation (EU) 2024/3110, the Commission’s first CPR working plan, and the implementing acts adopted so far. As at 30 September 2026, no product family is yet under a legal duty to declare global warming potential under the new Regulation. The first — cement — is scheduled, indicatively, for late 2028.
What the Regulation actually says
The obligation sits in Article 15. The declaration of performance and conformity — the DoPC, the document that replaces the old Declaration of Performance — must include the product’s environmental sustainability performance over its life cycle, calculated using “the latest version of software made available free of charge on the website of the Commission.” Article 15(3) then sets the minimum content on a timetable:
That is where most summaries stop. The dates are floors for what a declaration must contain once a declaration is required. They do not, by themselves, require one.
The trigger the headline leaves out
Three provisions decide when a Thai factory actually has to produce that declaration, and none of them is dated 8 January 2026:
A DoPC is required “where a product is covered by a harmonised technical specification adopted in accordance with Articles 5 or 6.” No specification, no DoPC.
Economic operators’ obligations apply “only in relation to products covered by a harmonised technical specification” or CE-marked on a European technical assessment.
Obligations apply to a product family only “from one year after the date of adoption of an implementing act” making its harmonised standard mandatory.
Standards cited under the old CPR 305/2011 “shall remain valid” until withdrawn — so today’s products keep the old Declaration of Performance, which has no carbon content.
The Commission’s own harmonised-standards page puts it plainly: under the new Regulation, the old standards will be replaced as the new ones are made mandatory, and “the first standards to be made mandatory are probably standards for cement in 2027.” A family whose standard is made mandatory in late 2027 carries obligations from roughly late 2028. At that point the climate-change indicators apply at once, because the 2026 floor has already passed.
The first standards to be made mandatory are probably standards for cement in 2027.
European Commission, CPR harmonised standards page, read 30 September 2026Where each product family stands
The Commission’s First CPR Working Plan 2026–2029 (COM(2025) 772, 16 December 2025) sets out the order. Every date in it is marked indicative, and two families that matter to Thai exporters are still being handled under the old Regulation:
| Standardisation request | Standard made mandatory | Carbon duty — earliest | |
|---|---|---|---|
| Cement, limes, hydraulic binders | Q3 2025 | Q4 2027 | ~late 2028 |
| Reinforcing and prestressing steel | Q2 2026 | 2029 | ~2030 |
| Doors, windows, shutters | Q1 2026 | 2029 | ~2030 |
| Precast concrete products | Q2 2025 | Q4 2025 | Cited under old CPR — none yet |
| Structural metallic products | Q3 2025 | Q2 2026 | Cited under old CPR — none yet |
For the mechanics behind the last column: obligations start one year after the implementing act, unless the act sets a later date. Manufacturers may also choose to apply a new specification early, from its entry into force. The Working Plan adds one further signal for cement: the Clean Industrial Deal announced “a mandatory label on cement (display of the global warming potential)” once the new cement standards are made mandatory. If you ship clinker-based products into Europe, that is the date to plan around — and it is also a CBAM good already, which is a separate regime with its own clock.
What the declaration will be — and why an EPD alone will not satisfy it
Here is the point most EPD marketing skips. The CPR never mentions environmental product declarations. EN 15804, the European standard behind construction EPDs, appears only in a recital, as the basis for the characterisation factors in the Commission’s software. When a family’s date arrives, the carbon figure on its DoPC must be:
That third step is no longer theoretical. Delegated Regulation (EU) 2026/1310, published in the Official Journal on 28 August 2026, assigns System 3+ to “environmental sustainability” across all product families. A programme-verified EPD is a different instrument with a different verifier. It will almost certainly be a useful data foundation — the inventory, the modelling and the supplier evidence all transfer — but on the Regulation’s text it does not, by itself, discharge the CPR duty. Anyone selling you an EPD as “CPR compliance” is ahead of the law.
Two documents, two language rules
This is where our own practice comes in, because the two documents follow opposite language rules:
| Language rule | Source | |
|---|---|---|
| EPD on the International EPD System | English, as a minimum. Other language versions allowed, with identical content. | General Programme Instructions 5.0.1, §7.1 |
| CPR declaration (DoPC) | The language or languages each Member State requires — not English by default. | Regulation (EU) 2024/3110, Art. 16(4) |
| Instructions and safety information | A language set by the Member State, or one easily understood by users. | Art. 22(6); Art. 24(3) for importers |
| CBAM operator emissions report | English. | Implementing Reg. (EU) 2025/2547, Art. 10(4) |
So a Thai manufacturer selling steel or aluminium building products into Germany and France ends up with plant data in Thai, an EPD that must exist in English, a CBAM emissions report in English, and — once its family is live — a DoPC in German and French. Every one of those carries the same numbers, and every one is a place for a unit, a decimal separator or a module boundary to drift. That is a translation-control problem as much as an LCA problem. Our ISO 17100 Translate–Edit–Proofread workflow exists for exactly this: one verified source, every language version checked against it.
Why a Thai exporter should still move now
If the legal duty is two years away, why act now? Three reasons that do not depend on the headline being right:
The recast EPBD (Art. 7(2)) requires life-cycle GWP to be calculated and disclosed for new buildings over 1,000 m² from 1 January 2028, and for all new buildings from 2030. Designers need product data before the CPR delivers it.
Delegated Reg. (EU) 2026/52 lists CPR declaration data first, then product-specific data calculated to EN 15804 — usable where national legislation permits it.
System 3+ includes a plant inspection to validate company-specific data. A supplier-data trail built now for an EPD is the trail a notified body will ask for.
At our 4 September census, 217 valid Thai EPDs sat on the International EPD System, almost all construction products, from 12 organisations.
If you already hold a TGO carbon footprint for the product, much of the inventory carries over. The boundary, the product category rules and the impact assessment do not. Our EPD service scopes that gap product by product, and the same carbon numbers then feed your disclosure at home.
Where the evidence runs out
We would rather tell you where this analysis could be wrong than have you find out later:
- The working-plan dates are indicative. The Commission says so in the document. Standards can arrive late; an implementing act can also set a later application date.
- Early adoption is permitted. A manufacturer may choose to apply a new specification from its entry into force, and a European buyer may ask for it before the law does.
- We could not find the Commission’s calculation software published. That is an absence of evidence, not proof it does not exist.
- Two families are on a different track. The Working Plan routes precast concrete and structural metallic products through citation under the 2011 Regulation, which carries no carbon declaration. A later standardisation request could change that.
- Cement leads the CPR calendar, but it is not where Thailand’s EU exposure sits. Eurostat Comext records EU imports of Thai cement at about €3,800 in 2025, against €119 million of Thai iron and steel fasteners. For most Thai exporters, CBAM on steel and aluminium arrives well before any CPR carbon duty.
- A buyer’s specification is not the law. Many European projects already ask for EPDs through green-building schemes. That demand is commercial and real, whatever the CPR date.
- “GWP from 8 January 2026” is a floor for the declaration’s content, not a start date for your product. Your date is set by your product family.
- No family is under a CPR carbon duty yet. Cement is first — standard made mandatory Q4 2027 (indicative), obligations about a year later.
- The CPR figure must come from the Commission’s software and be validated by a notified body under System 3+. An EPD is the foundation, not the filing.
- Your EPD must exist in English; your DoPC must be in each Member State’s language. Control the numbers across every version.
- Act for the 2028 EPBD building-carbon disclosure and your buyers’ requests — not for a deadline that has not arrived.
Exporting construction products to the EU?
We map your product family to its real CPR date, build the EN 15804 life-cycle assessment and EPD behind it, and keep the English, Thai and Member-State language versions aligned to one verified source.
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Sources, all read on 30 September 2026: Regulation (EU) 2024/3110, OJ L 18.12.2024 (Arts. 13, 15, 16(4), 20(1), 22(6), 24(3), 95, 96; Annexes II, V, IX); European Commission, COM(2025) 772 final, (First) CPR Working Plan for 2026–2029, 16.12.2025, Table 3 and s.3.4 (all dates indicative); European Commission, Construction Products Regulation — harmonised standards page; Commission Delegated Regulation (EU) 2026/1310 of 11 June 2026, OJ 28.8.2026; Directive (EU) 2024/1275, Art. 7(2); Commission Delegated Regulation (EU) 2026/52, OJ 4.5.2026, Annex III Table 1; EPD International, General Programme Instructions v5.0.1 (27.2.2025), §7.1; Commission Implementing Regulation (EU) 2025/2547, Art. 10(4). Thai EPD count: Othello census of environdec.com, 4 September 2026. Trade figures: Eurostat Comext DS-045409, EU imports from Thailand, 2025, HS 2523 and 7318, updated 15.9.2026. This article is analysis, not legal advice.
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