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How to Comply with CPR 2024: What Irish Manufacturers Need to Know

· 8 min read · DPP Delivery
CPR 2024 Compliance Ireland

The revised Construction Products Regulation - commonly referred to as CPR 2024 - represents the most significant overhaul of EU construction product regulation in over a decade. It replaces the existing CPR 305/2011 framework that has governed CE marking, Declarations of Performance, and market access for construction products since July 2013.

For Irish construction product manufacturers, CPR 2024 is not an abstract piece of Brussels legislation. It directly affects your ability to sell products in the EU single market, which for most Irish manufacturers is the primary commercial market. Understanding the changes, their timeline, and the practical steps required for compliance is essential.

What CPR 2024 Changes

The Digital Product Passport Mandate

The headline change is the introduction of a mandatory Digital Product Passport (DPP) for construction products. Under CPR 2024, every product placed on the EU market will require a machine-readable digital record containing performance declarations, environmental data, and substance information. This is covered in depth in our article on what a DPP actually is.

The DPP is not simply a digital version of your current DoP PDF. It is a fundamentally different approach to product data - structured, machine-readable, hosted at a persistent URI, and linked to the physical product via a unique identifier and data carrier (typically a QR code).

Enhanced Declaration of Performance Requirements

The Declaration of Performance remains the cornerstone of CPR compliance, but CPR 2024 expands and strengthens the requirements:

  • Digital format mandatory: DoPs must be available in machine-readable form, not just as downloadable PDFs. The era of the Word-document-saved-as-PDF Declaration of Performance is ending.
  • Expanded essential characteristics: The range of characteristics that must be declared is broadened, particularly around durability, safety in use, and environmental performance.
  • Stronger link to harmonised standards: CPR 2024 aims to resolve the long-standing bottleneck in harmonised standard development that has plagued the current regulation. New mechanisms for standard adoption and citation should mean fewer products caught in regulatory limbo.

Environmental Sustainability Declarations

This is entirely new territory for construction product regulation. CPR 2024 introduces mandatory environmental sustainability requirements:

  • Life-cycle environmental performance based on EN 15804-compliant EPD data must be declared for products within scope.
  • Carbon footprint declaration - specifically the Global Warming Potential across relevant life-cycle stages - becomes a regulatory requirement, not a voluntary differentiator.
  • Recycled content and recyclability information must be provided, supporting the EU’s circular economy objectives.

For manufacturers who already have EPDs, this is manageable. For those who do not, obtaining EN 15804+A2-compliant EPDs becomes an urgent priority. Our guide on bridging from EPD to DPP explains how existing EPD data feeds into these new requirements.

Substances of Concern Reporting

CPR 2024 significantly strengthens substance reporting obligations:

  • SVHC declarations aligned with REACH Candidate List requirements must be included in the DPP.
  • Broader substance of concern categories beyond SVHCs may be defined through delegated acts for specific product categories.
  • SCIP database alignment - the existing obligation to notify the ECHA SCIP database about articles containing SVHCs is reinforced and integrated into the DPP framework.

This is the area where many manufacturers have the largest data gap. Knowing the full chemical composition of your products - including additives, surface treatments, and binders - is not optional under CPR 2024.

What Is Different for Irish Manufacturers Specifically?

Ireland’s position creates specific considerations:

EU Single Market Dependence

Irish construction product manufacturers are overwhelmingly oriented toward the EU single market. Unlike UK manufacturers who face the EU market as an export market with its own regulatory complexities, Irish manufacturers operate within the single market. CPR 2024 applies directly - there is no transposition into national law required for regulations. When CPR 2024’s provisions take effect, they take effect in Ireland immediately.

UK Market Divergence

Since Brexit, the UK operates its own construction product regulatory framework. The UK is not adopting CPR 2024 and is developing its own approach to construction product regulation. For Irish manufacturers who sell into both the EU and UK markets, this means managing two regulatory regimes. CPR 2024 compliance does not guarantee UK compliance and vice versa. You need to understand both, but prioritising CPR 2024 compliance is essential for maintaining EU market access.

National Authority Readiness

In Ireland, market surveillance for construction products falls under the National Standards Authority of Ireland (NSAI) and the Department of Enterprise, Trade and Employment. As CPR 2024 strengthens market surveillance provisions, expect increased scrutiny of product declarations. The days of filing a DoP and hoping nobody checks are drawing to a close.

Enterprise Ireland and IDA Support

Irish manufacturers may be able to access Enterprise Ireland supports for digitalisation, compliance, and export market readiness. The DPP is fundamentally a digitalisation project, and some of the investment required - particularly in data infrastructure and IT systems - may be eligible for support. Explore this early.

Timeline of Obligations

CPR 2024 follows a phased implementation:

  • 2024: Regulation entered into force. Framework provisions active.
  • 2025-2026: European Commission develops and adopts delegated acts specifying detailed requirements for individual product categories, including DPP data requirements.
  • 2027-2028: First product categories expected to require full DPP compliance for market placement. Priority likely given to high-volume, high-environmental-impact products such as cement, concrete, steel, insulation, and aggregates.
  • 2028-2030: Broader rollout to additional product categories.
  • Ongoing: Delegated acts will continue to bring additional product categories into scope.

The critical point: even though your specific product category may not yet have a defined DPP deadline, the structural requirements - structured data, product identification, environmental declarations - apply broadly. Waiting for your specific delegated act before taking any action is a high-risk strategy.

Practical Compliance Steps

Here is what Irish manufacturers should be doing now, regardless of which product category they fall into:

Step 1: Audit Your Current Declarations

Pull out your Declarations of Performance. Are they current? Do they reference valid harmonised standards? Is the data within them structured and consistent, or are they ad hoc documents created years ago and never reviewed? If your DoPs have not been updated since they were first created, start here.

Step 2: Ensure EPD Coverage

If you do not have EPDs for your main product lines, begin the process of obtaining them. This involves commissioning a Life Cycle Assessment (LCA) from a qualified practitioner, having the results verified by an EPD programme operator, and publishing the EPD. This process takes months, not weeks. Start now.

If you have EPDs, check they comply with EN 15804+A2 (the current version of the standard). Older EPDs may need to be updated.

Step 3: Register for GS1 and Assign GTINs

Contact GS1 Ireland and register as a member if you are not already. Assign GTINs to every distinct product variant in your catalogue. This is the foundation of product identification for the DPP.

Step 4: Structure Your DoP Data

Extract the data from your DoPs into a structured format - a spreadsheet is a reasonable starting point, though a proper product database is the end goal. Map each data field: product type, intended use, harmonised standard, essential characteristics, declared values, AVCP system, notified body. This structured data set is what will feed into your DPP.

Step 5: Map Your Substances of Concern

Compile a substances of concern register for each product. Engage your raw material suppliers for Safety Data Sheets and full composition declarations. Identify any SVHCs present above 0.1% by weight. If you use complex chemical products (adhesives, coatings, sealants, admixtures), this exercise may reveal gaps in your supply chain data.

Step 6: Assess Your IT Infrastructure

Can your current systems produce structured data outputs? Do you have - or can you acquire - a product information management system? Can you host persistent URIs? If the answer is no to all of these, you need to either invest in capability or identify a DPP service provider who can host your passports. Our DPP readiness self-assessment covers this dimension in detail.

Step 7: Assign Ownership and Budget

Designate a DPP compliance owner within your organisation. Ensure they have the authority and budget to drive cross-functional work. This is not an IT project, a quality project, or a sustainability project - it is all three, and it needs coordinated leadership.

Common Misconceptions

“This only affects large manufacturers.” Wrong. CPR 2024 applies to all manufacturers placing construction products on the EU market, regardless of size. A small Irish precast concrete producer has the same DPP obligations as a multinational cement manufacturer. The regulation does acknowledge proportionality, but the core obligations are universal.

“We already have CE marking, so we are compliant.” CE marking under CPR 305/2011 is necessary but not sufficient under CPR 2024. CE marking continues, but the additional requirements - DPP, environmental declarations, substance reporting - are layered on top. Existing CE marking does not grandfather you into CPR 2024 compliance.

“This will be delayed or watered down.” This is the most dangerous misconception. The EU has demonstrated sustained political commitment to the Green Deal, circular economy, and digital product documentation. The ESPR has already been adopted. DPP pilot projects are underway across multiple sectors. The trajectory is clear and accelerating.

“We can sort this out when the deadline arrives.” DPP compliance requires data that takes months or years to assemble: EPDs require LCA studies, GS1 registration has lead times, substance mapping requires supplier engagement, and IT systems need procurement and implementation. If you begin when the deadline is announced, you will not be ready when it arrives.

The manufacturers who treat CPR 2024 as an opportunity - to digitalise their product data, improve their environmental credentials, and differentiate on transparency - will be the ones best positioned when the obligations take full effect. The cost of compliance is real, but the cost of lost market access is far greater.