Green Public Procurement and the Carbon Data Gap for Irish Manufacturers

From 1 June 2026, non-residential public construction projects in Ireland valued over EUR 5 million must produce a whole-life cycle greenhouse gas emissions assessment. That requirement sits inside Ireland’s Green Public Procurement Strategy, it is backed by government policy, and it applies to projects that are already in procurement now.

For Irish construction product manufacturers, this is not a future risk to monitor. It is a present-day readiness question.

The contractors and specifiers building those projects need product-level carbon data to complete their assessments. Environmental Product Declarations - EPDs are the recognised data source. Manufacturers who have them are ready to respond to those requests. Manufacturers who do not are doubly exposed: they face both the DPP compliance deadline under Construction Product Regulations (CPR) 2024 and an emerging commercial barrier in public sector supply chains.

What Green Public Procurement Actually Is

Green Public Procurement (GPP) is the policy framework under which public authorities in EU member states apply environmental criteria when spending public money on goods, works, and services. In Ireland, the current policy vehicle is the Buying Greener: Green Public Procurement Strategy and Action Plan 2024-2027, published by the Department of Environment in April 2024.

GPP criteria are applied at different stages of a procurement process - as technical specifications that set minimum environmental standards, as award criteria that score bids on environmental performance, or as contract conditions that require ongoing reporting. In construction, this means specifying lower-carbon materials, requiring lifecycle carbon assessments on projects, and asking for evidence of a product’s environmental impact in the form of EPDs.

The critical distinction between GPP and other environmental regulations is who drives compliance. With CPR 2024 or REACH, the regulator sets requirements and enforces them. With GPP, the buyer sets requirements and enforces them through contract. For a manufacturer, the practical result is the same: no compliant data, no supply contract.

The June 2026 Threshold and What It Means in Practice

Ireland’s GPP requirements for construction are phased. The key milestones already in force or imminent are:

From 1 September 2024: all public construction projects must apply best-practice carbon management design approaches, including specifying lower-carbon cement and concrete with a minimum 30% clinker replacement.
From 1 September 2025: building projects over EUR 10 million (non-residential) or EUR 60 million (residential) must produce a whole life-cycle greenhouse gas emissions assessment aligned with the Energy Performance of Buildings Directive (EPBD).
From 1 January 2026: infrastructure projects over EUR 10 million must produce equivalent lifecycle assessments.
From 1 June 2026: the threshold drops substantially. Non-residential public projects in receipt of exchequer funding over EUR 5 million must produce a whole life-cycle greenhouse gas emissions assessment.

The EUR 5 million threshold is not a niche edge case. A primary school extension, a civic centre fit-out, a healthcare facility refurbishment - are examples that could fall within scope. A large proportion of publicly funded construction projects will be captured by this requirement.

The assessment framework referenced is EN 15978, the European standard for whole-building lifecycle assessment. That standard relies on product-level environmental data in the form of EPDs conforming to EN 15804+A2 to calculate embodied carbon accurately and to a consistent methodology.

Why Contractors Will Start Asking Manufacturers for Carbon Data

The building-level assessment obligation sits with the design team and contractor on a public works project. But to complete that assessment, they need product data from their suppliers.

A contractor modelling embodied carbon in a building using EN 15978 methodology needs, at minimum, declared global warming potential (GWP) values for the materials they are specifying. The most reliable and auditable source of those values is an EN 15804+A2-compliant EPD. Industry average data from generic LCA databases can substitute where manufacturer-specific data is not available, but using generic data is a commercial disadvantage: generic datasets typically use conservative assumptions that make a product look worse than it actually performs.

A manufacturer with a published EPD can offer the specifier better data, a better embodied carbon number, and a traceable evidence source. A manufacturer without an EPD is handing that advantage to a competitor.

This dynamic is already visible in procurement for large building projects. The June 2026 threshold extending requirements to EUR 5 million projects will widen it considerably.

How GPP Carbon Requirements Overlap with DPP Data Requirements

This is where the two regulatory streams converge for Irish manufacturers.

Under CPR 2024, the construction products Digital Product Passport will require declared environmental performance data - specifically life-cycle environmental indicators, including global warming potential. That data must come from an EN 15804+A2-compliant EPD. The first CPR 2024 environmental declaration requirement - mandatory GWP declaration - came into force on 8 January 2026 for products covered by updated harmonised standards.

The data required for a DPP and the data required to support a GPP embodied carbon assessment are largely the same:

A published, independently verified EN 15804+A2 EPD
Declared GWP values (cradle to gate, and ideally full cradle to grave)
Structured product identification through a consistent system (GS1/GTIN under CPR 2024)
A reliable mechanism to make that data available digitally to contractors and specifiers

A manufacturer who has completed their EPD programme and structured their product data for DPP compliance is also largely ready to respond to GPP data requests. The preparation is not duplicated - it is compounded. One investment in product data infrastructure serves both obligations.

Conversely, a manufacturer with no EPDs faces both problems simultaneously and cannot solve either one quickly. The EPD process - LCA commissioning, data collection, independent verification, and publication - can take a number of months.

Two Exposures, One Preparation Problem

The practical risk picture for manufacturers who have not started their EPD programme is now clearer than it was twelve months ago.

Regulatory exposure: CPR 2024 mandates environmental performance declarations for products covered by updated harmonised standards. GWP declaration is already in scope. Without an EPD, there is no credible basis for that declaration. Non-compliance exposes manufacturers to market surveillance enforcement, which under Irish law (S.I. No. 669/2025) carries penalties up to EUR 500,000.

Commercial exposure: As GPP requirements apply to a growing share of public construction projects, contractors and specifiers working on publicly funded projects will increasingly filter suppliers by their ability to provide EPD data. A manufacturer without an EPD may be unable to win supply contracts on public projects, or may find their products defaulted to unfavourable generic carbon data in building assessments - making them look less competitive than they actually are.

Neither exposure is immediate in the sense of enforcement action landing tomorrow. But both exposures are building, and the preparation window has a fixed timeline. A manufacturer who starts their EPD programme now has a reasonable chance of completing it before the end of 2026. One who starts in the autumn of 2026 does not.

The Direction of Travel Beyond 2026

GPP requirements in construction will tighten. The Energy Performance of Buildings Directive (recast 2024) introduces mandatory whole-life global warming potential disclosure for new buildings over 1,000 m2 from 2028, and for all new buildings from 2030. That disclosure framework uses the Level(s) methodology - the EU’s common sustainability assessment framework for buildings - and relies on product-level EPD data as its primary input.

The EU is also revising the Public Procurement Directive (2014/24/EU). That revision, signalled in the Clean Industrial Deal, is expected to embed sustainability and lifecycle criteria more deeply into procurement processes across all member states. GPP, which is currently voluntary at EU level, may become mandatory for specified categories.

In Ireland, the Buying Greener strategy runs to 2027 and commits to introducing additional GPP criteria for construction by the end of 2025. The reporting framework requires public bodies to justify any procurement where they did not apply GPP criteria, creating a comply-or-explain dynamic that will push adoption further even without a mandate.

Acknowledging all of this, the honest position is that GPP is not yet creating immediate commercial pressure for most Irish construction manufacturers. At industry events this year, there is little evidence of pull from the market - contractors are not yet demanding EPDs systematically, and most procurement processes have not yet integrated carbon criteria in a way that is visible to manufacturers. That will change as the EUR 5 million threshold applies from June, and as more projects complete assessments and contract teams develop familiarity with the requirements.

The manufacturers who begin now are not responding to current pressure - they are positioning ahead of pressure that the evidence clearly shows is coming.

What to Do Now

If you manufacture construction products that go into Irish public buildings - structural elements, insulation, cladding, internal systems, fit-out components - GPP carbon requirements are relevant to your business.

The practical steps are the same ones DPP compliance requires:

Establish whether your products have EN 15804+A2-compliant EPDs. If you have EPDs but they are based on the older +A1 version of the standard, check whether they declare the full set of indicators now required under CPR 2024 and the EN 15978 assessment framework.
If you do not have EPDs, start the commissioning process now. The timeline from commissioning an LCA to publishing a verified EPD through EPD Ireland is four to nine months. June 2026 is weeks away. The relevant preparation window for this year’s procurement cycles is already tight.
Register with GS1 Ireland if you have not. Product identification is a prerequisite for DPP compliance and is good practice for supply chain data management generally.
Assess your readiness across both obligations at the same time. DPP and GPP data requirements overlap substantially. A readiness assessment that treats them as a single product data infrastructure problem is more efficient than two separate workstreams.

DPP Delivery’s readiness assessment maps your current position against CPR 2024 DPP requirements and GPP data readiness in a single structured engagement, producing a prioritised action plan with realistic timelines and cost estimates. Contact us to discuss your situation, or take our self-assessment to get an initial picture of where you stand.

References

Department of Enterprise, Trade and Employment, “Procurement Guidance for Public Bodies: Reducing Embodied Carbon in Construction,” Government of Ireland, 2024. Available at: enterprise.gov.ie/en/publications/guidance-public-bodies-reducing-embodied-carbon-in-construction
Department of Environment, Climate and Communications, “Buying Greener: Green Public Procurement Strategy and Action Plan 2024-2027,” Government of Ireland, 2024. Available at: gov.ie/en/department-of-climate-energy-and-the-environment/publications/green-public-procurement-strategy-and-action-plan-2024-2027
European Parliament and Council, Regulation (EU) 2024/3110 (Construction Products Regulation), Official Journal of the European Union, 2024.
S.I. No. 669/2025, European Union (Construction Products) Regulations 2025, Irish Statute Book. Available at: irishstatutebook.ie/eli/2025/si/669
European Commission, “GPP Criteria and Requirements,” Green Forum. Available at: green-forum.ec.europa.eu/green-business/green-public-procurement/gpp-criteria-and-requirements_en
EPD Guide, “EU CPR 2026 Moves from Law to Action.” Available at: epd.guide/environmental-regulations-and-laws/eu-cpr-2026-moves-from-law-to-action
European Commission, “Commission Encourages Low-Carbon Construction Materials with Calculation Framework for Life-Cycle Global Warming Potential,” 16 December 2025. Available at: energy.ec.europa.eu