Across the EU, the category-specific rules your EPD follows are being rewritten and made binding. Here is what shifts, for which products, and when.
An Environmental Product Declaration (EPD) does not run on a single rulebook. It follows a layered set of rules, and the layer that decides what you declare, in what unit, and which stages of a product's life you must model is the complementary product category rule, or c-PCR. That layer is now being revised across most product categories, and it is moving from a voluntary program rule toward a compliance obligation. It changes what your next declaration has to contain. This article assumes you already work with EPDs; if terms like declared unit, functional unit, or module B are new to you, start with One Click LCA's simple guide to EPDs.
Note: this article deals with the European system built on EN 15804. Other markets, including North America and much of the Asia-Pacific region, use ISO 21930 as their core standard, with their own product category rules. The two standards are closely aligned but not interchangeable, and the c-PCR mechanism described here belongs to the EN 15804 system.
The layer beneath the standard
An EPD follows three layers of rules, not one.
Core rules: EN 15804+A2 sets the shared method for every construction product EPD in Europe: which impact categories to report, which life cycle stages to include, and how to present results. Outside Europe, ISO 21930 plays this role.
Complementary PCR (c-PCR): On top of the core, a c-PCR adds the category-specific rules the core standard leaves open, for concrete, insulation, windows, metals, and the rest. It sets the declared unit, whether a functional unit is required, and which use-stage modules apply.
Program operator instructions: The operator you publish with, for example EPD International, EPD Hub, or IBU, adds its own general program instructions on top.
Your EPD must satisfy all three. The core standard rarely changes. The c-PCR layer holds most of the category-specific requirements, and it is the layer now in motion.
A companion reference, the c-PCR requirements table, breaks this layer down standard by standard and module by module. For each category it shows the declared unit, whether a functional unit is required, which normally optional modules become mandatory, and any statements the c-PCR forces you to make.
What is changing, and why now
CE marking is what a construction product needs in order to be sold legally in the European Union. It signals that the product meets EU rules, based on the manufacturer's Declaration of Performance and Conformity. Under the revised Construction Products Regulation, that declaration now has to include environmental performance, not only safety and technical performance (One Click LCA guide to the Construction Products Regulation).
Three things follow from that:
A c-PCR is mandatory where it exists. When CEN, the European standards body, publishes a c-PCR for a category, it takes precedence over the program operator's own rules for that product group (ECO Platform verification guidelines). A new c-PCR is not an option you can take or leave. It becomes the rule you follow.
The whole layer is being rewritten at once. Most c-PCRs were written for the older version of the core standard. A coordinated CEN project called CODEV-PCR is now revising them, and writing new ones, to match the current standard, EN 15804+A2, and the new regulation (CEN-CENELEC). So even a category with a stable c-PCR today can expect a revised one.
These revised c-PCRs are being written to sit inside the official product standards that back CE marking. That changes their weight. Where a c-PCR exists, it is already binding for the EPD you publish, on the program-operator side. What is new is that, under the CPR, declaring environmental performance is becoming mandatory to place a product on the market, phased in as each product family's standard is updated. The rules you once followed for a voluntary EPD are moving into the standards that decide market access.
The regulation puts a clock on all of this. Environmental disclosure phases in by indicator set: Global Warming Potential from 8 January 2026 for products whose product standard has been updated, a wider set of indicators from 9 January 2030, and full life cycle reporting by 9 January 2032, with penalties enforceable from 2027 (One Click LCA guide to the Construction Products Regulation). The timing runs per product family, not on a single date, so some categories move well before others.
How your EPD work changes, by type of change
A new or revised c-PCR can change your EPD in four ways. The specifics differ by category, but the pattern is consistent.
The declared unit can change. Fabricated structural steel, for example, is set to be declared per 1 kg under its metal c-PCR, rather than the 1 tonne many older declarations used. That c-PCR is still a draft, so treat the figure as proposed until it is ratified.
A functional unit can become required where a declared unit was enough. Thermal insulation tied to a specific building application must carry its thermal resistance as a functional unit, not only a physical quantity.
Use-stage modules can become mandatory. Concrete must account for carbonation in the use stage, and piping systems inside buildings (EN 16904) require declaration of the full life cycle including all B modules.
New mandatory statements and limits can apply. Some categories require you to declare an omission explicitly, and some prohibit comparative claims between products.
A worked example: concrete under EN 16757
Say you publish an EPD for ready-mix concrete. Under the concrete c-PCR, carbonation, the gradual reabsorption of CO2 by hardened concrete, is no longer something you can quietly leave out. You have to address it at the use stage, in module B1, and at end of life, in modules C3 and C4, following the calculation method set out in the standard. Quantifying the uptake is optional, but if you choose not to, the c-PCR requires you to state that exclusion in the EPD rather than stay silent.
For a declaration that previously stopped at the factory gate, that is a new module to model, a new data input to source, and a new statement to write. The declared basis can shift as well, because concrete carries its own functional unit format built around strength class, exposure class, and a defined service life.
Multiply that pattern across insulation, windows, hardware, flooring, pipes, and metals, and the point holds: the same product can produce a materially different EPD once its c-PCR updates.
What each c-PCR asks you to do, on top of EN 15804+A2
A quick reference for people already making EPDs. Each standard below is a complementary rule (c-PCR): it does not replace EN 15804+A2, it adds to it. This sheet only lists the extras, so every line tells you what to do differently for that product group. Covers 14 of the 15 c-PCRs in the EPD Hub Core PCR Annex I. One (road materials / bituminous mixtures, EN 17392-1) is left out for now because it is still at draft stage.
Before you start
You always declare these modules for any product, under EN 15804+A2:
A1-A3: making the product (materials, transport to the factory, manufacturing).
C1-C4: end of life (removal, transport, processing, disposal).
D: benefits beyond the life cycle, such as recycling credits.
One exception: a product that is physically integrated into another product and cannot be separated at end of life, loses its identity through physical or chemical transformation, and contains no biogenic carbon may use a cradle-to-gate scope. In that case C1-C4 and D are not required.
These modules are optional by default, so a c-PCR has to tell you to add them:
A4: transport from the factory to the building site.
A5: installing the product.
B1-B7: the in-use stage (use, maintenance, repair, replacement, refurbishment, energy, water).
Two units you will see:
Declared unit: the amount your numbers are reported for, such as 1 m2, 1 kg or 1 m3. Use this when the product's exact job in the building is not fixed.
Functional unit: the same idea, but tied to a stated performance over a service life. Use this when a c-PCR asks for it.
Version note: the EPD Hub Core PCR runs on EN 15804+A2 (2019). A few older c-PCRs were written for the earlier +A1 (2013) version, and timber for the original 2012 version. Where that is the case it is marked, because the indicator list and the way biogenic carbon is reported are different.
Draft note: some c-PCRs below are still unratified drafts. Their rules can still change, so treat those as provisional.
1. EN 16485:2014 - Round and sawn timber
Built on the original EN 15804:2012 (older than both +A1 and +A2). Final standard. A newer edition is on the way.
You need to | What to do |
Set the declared unit | Declare per one of the listed units, for example 1 m3 of sawn timber, or one item such as a wood window. If it is not a mass, give a factor to convert it to 1 kg. Always state the wood’s density and moisture content. |
Set the functional unit | Optional. Use one when the product's function in the building and its service life are defined (i.e. for a cradle-to-grave EPD). State the density and moisture content with it. |
Declare which modules | Declare A1-A3, C1-C4 and D. End of life is required under the EPD Hub +A2 rules. For wood it also matters because A1-A3 counts the stored carbon as a credit, and that credit is only balanced when the carbon is released at end of life (C3), so leaving end of life out would overstate the benefit. |
Set the service life | Only needed for gate-with-options and full-life-cycle EPDs. |
Model or state | Follow the wood carbon rules: only count the product as carbon-neutral if the wood comes from sustainably managed forests, and track that carbon across the stages, including burning at end of life (C3). Note this is the older, pre-+A2 way of handling biogenic carbon. |
Compare products | Same rules as EN 15804. Nothing extra. |
2. EN 16757:2022 - Concrete and concrete elements
Built on EN 15804+A2:2019. Final standard.
You need to | What to do |
Set the declared unit | Declare per 1 m3 of concrete (state the strength class and exposure class), or per precast unit, or per 1 m2 of wall. You may give mass in tonnes. |
Set the functional unit | Optional. If you use one, state the size, the use, the key performance (strength and exposure class per EN 206, or load-bearing / thermal / acoustic performance) and the service life. Example: 1 m2 of load-bearing wall for a set service life. |
Declare which modules | The usual baseline (A1-A3, C1-C4, D). No additional modules are formally required, but you must address carbonation in B1 and at end of life (see below), so in practice B1 carries mandatory content even if the module itself stays optional. |
Set the service life | If you know the end use, set it at least as long as the building is expected to last. If you don’t, set it yourself for the intended use. |
Model or state | Model carbonation (concrete slowly reabsorbing CO2) in the use stage (B1) and end of life (C3, C4). Counting the absorbed CO2 is optional, but if you leave it out you must say so on the EPD. If you count it, give your assumptions, put the amount and the method in the report, and enter the absorbed CO2 as a credit (a negative number). Split any slag or fly-ash credits by market value. |
Compare products | Same rules as EN 15804. Nothing extra. |
3. EN 16783:2017 - Thermal insulation products
Built on EN 15804+A1:2013 (older version). Final standard.
You need to | What to do |
Set the declared unit | Boards and batts: declare per 1 m2 at a stated thermal resistance (R-value). Pipe sections: per 1 m of length, stating conductivity, diameter and thickness. Civil-engineering products: per 1 m3, stating conductivity. You may add factors to convert to other units. |
Set the functional unit | Required when the product is tied to a building use. State the R-value for that use. If the R-value does not apply, state the relevant function instead. |
Declare which modules |
Declare A1-A3, C1-C4 and D (the EPD Hub +A2 baseline). For products that are only finished once installed (sprayed, blown or loose-fill), also declare A5 and describe the installation.
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Set the service life | As EN 15804. State the conditions you based it on. |
Model or state | For sprayed, blown or loose-fill products, describe the installation (A5). This description is required. |
Compare products | Same rules as EN 15804. |
4. EN 16810 - Resilient, textile, laminate and modular floor coverings [DRAFT]
Draft prEN 16810:2024, built on EN 15804+A2:2019. Not yet ratified, and read from a low-quality file, so treat as provisional.
You need to | What to do |
Set the declared unit | Declare per 1 m2 of installed floor covering, for the stated use area. |
Set the functional unit | Required. 1 m2 of installed floor covering for the stated use and use area (per EN ISO 10874). Include the service life. |
Declare which modules | Either the full life cycle (A, B, C, D) or up to the factory gate with options. Confirm against the final text. |
Set the service life | Report impacts per one year of use. The service life is fixed at one year. |
Model or state | Only make comparisons in the context of how the covering is used in the building. |
Compare products | Only within the same building use. |
5. EN 16903 - Buried plastics piping systems [DRAFT]
Draft prEN 16903:2024, built on EN 15804+A2:2019 (with the AC:2021 correction). Not yet ratified, so treat as provisional.
You need to | What to do |
Set the declared unit | Declare per 1 m of length (by mass) of the buried system. State the inner diameter (DN); for pressure pipes state the pressure class (PN); state the stiffness class (SN). If you mix sizes, give conversion factors. |
Set the functional unit | Required for cradle-to-grave. Based on conveying a specified fluid over a specified distance at a given inner diameter, expressed as the total weight of a typical installed and backfilled system. Report the inner diameter (DN), pressure class (PN) or stiffness class (SN), SDR ratio, material, and component types. Give a factor to convert back to 1 m of length. If B modules and the use scenario are not declared, use a declared unit instead. |
Declare which modules | If you publish the gate-with-options type, you must declare A4. Other types run the full life cycle plus D. |
Set the service life | 100 years. |
Model or state | Nothing beyond the unit and module rules above. |
Compare products | Same rules as EN 15804. |
6. EN 16904 - Plastics piping systems inside buildings [DRAFT]
Draft prEN 16904:2021, built on EN 15804+A2:2019. Not yet ratified, so treat as provisional.
You need to | What to do |
Set the declared unit | Declare per 1 m of length (by mass) of the piping system. |
Set the functional unit | Required for cradle-to-grave. Defined for pressure and non-pressure applications for a single apartment, scalable to the full building by simple multiplication. The system may include pipes, fittings, seals, valves and fixing elements. Present a bill of components with mass per piece, total mass, and pipe lengths and diameters. If B modules and the use scenario are not declared, use a declared unit instead. |
Declare which modules | Declare the full life cycle: A1-A3, A4, A5, B, C1-C4 and D. This means A4, A5 and B are all required here. |
Set the service life | 50 years. |
Model or state | Declare end of life as a 100% version of one of the three set scenarios. |
Compare products | Same rules as EN 15804. |
7. EN 16908:2017+A1:2022 - Cement and building lime
Built on EN 15804+A2:2019. Final standard. (Your copy is the UNE version; confirm whether to cite the 2017+A1:2022 or the 2019 designation.)
You need to | What to do |
Set the declared unit | Declare per 1000 kg (1 tonne). |
Set the functional unit | None. Cement and lime are materials used to make other products, so there is no functional unit. |
Declare which modules | A1-A3 only (up to the factory gate). Later modules are optional. You may report lime carbonation in A5 and B1 if you wish. |
Set the service life | None. The service life belongs to the finished products (concrete, mortar, and so on). |
Model or state | Do not include biogenic CO2 from biomass or waste fuels in the total CO2. State whether the data is from one site or is a sector average. Keep each stage’s impacts in its own module. |
Compare products | You cannot compare products with these EPDs, because there is no functional unit. |
8. EN 17160:2019 - Ceramic tiles
Built on EN 15804+A1:2013 (older version). Final standard.
You need to | What to do |
Set the declared unit | Declare per 1 m2 of tile. |
Set the functional unit | Required for cradle-to-grave. 1 m2 of ceramic tile for covering walls and floors, over 50 years. For cradle-to-gate, use the declared unit (1 m2, without the service life). |
Declare which modules |
Declare A1-A3, C1-C4 and D. Tiles are a finished product, so end of life is required under the EPD Hub +A2 rules. Do not use the factory-gate-with-options split; this standard does not allow it.
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Set the service life | Set it from the product’s performance, using the ISO 15686 method. State the in-use conditions, and say that the service life applies only to those conditions. Make it possible to verify. |
Model or state | Declare any release of dangerous substances to indoor air, soil and water during use. This is required. |
Compare products | Only compare factory-gate EPDs under the same conditions, and justify anything you leave out. |
9. EN 17213:2020 - Windows and pedestrian doorsets
Built on EN 15804+A1:2013 (older version). Final standard.
You need to | What to do |
Set the declared unit | Declare per 1 m2. Calculate on the standard sizes given (for example a 1.23 x 1.48 m window), and state the size and configuration you used. |
Set the functional unit | Required. Build it on 1 m2 plus a service life, and also give the U-value and solar properties. |
Declare which modules | The baseline (A1-A3, C1-C4, D), plus: handle installation (A5) at building level; work out energy performance at building level, not inside module B; and if the product has an insulated glass unit, include replacing that unit at least once every 31 years in module B. |
Set the service life | Only declare it once you have provided all use-stage scenarios (B1-B5). Up to 30 years needs no proof; 31-50 years needs supporting documents; over 51 years needs justification. Cap glass units at 30 years. |
Model or state | State the size and configuration behind your 1 m2 result. Leave out electric motors and drives for shutters or blinds; they need their own EPD. |
Compare products | Same rules as EN 15804. |
10. EN 17328 - Gypsum-based construction products
Built on EN 15804+A2:2019. The final standard is EN 17328:2024; the file in the project is the earlier draft (prEN 17328:2022). Check details against the 2024 final before publishing.
You need to | What to do |
Set the declared unit | Declare by product type. Boards (plasterboard, fibreboard): per 1 m2 installed, stating thickness (mm) and weight per m2. Powders (binders, dry mortars): per 1 kg of dry product, stating the powder-to-water mix, the layer thickness and the coverage (kg/m2). Moulded parts (tiles, wall boards): per 1 kg, plus a factor to convert to 1 m2 if applied to a surface. Calcium sulfate screed: per 1 kg dry, stating the mix ratio. Ready-to-use jointing compound: per 1 kg, stating thickness and coverage. Other gypsum products: per 1 kg, stating thickness and coverage for coatings. |
Set the functional unit | Optional, and a declared unit is usually the better fit. If you use one, follow the standard’s Table 2 and EN 15804. |
Declare which modules | Declare the full life cycle: A1-A3, A4, A5, B, C1-C4 and D. This means A4, A5 and B are all required here. |
Set the service life | Assume at least 50 years, since gypsum does not age when installed correctly. Justify any other value. |
Model or state | For A4, document your transport modes and distances. For A5, model the installation energy and materials (for example water mixed into powders, or fixing and plastering) and include on-site waste; use 5% site waste unless you justify a different figure. State whether the data is from one site or is an average. |
Compare products | Same rules as EN 15804. Also take the accessory product standards into account when comparing. |
11. EN 17388-1:2024 - Flexible sheets for waterproofing, Part 1 (full life cycle)
Built on EN 15804+A2:2019. Final standard. (Your copy is the 2025 UNE version of EN 17388-1:2024.)
You need to | What to do |
Set the declared unit | Declare per 1 m2 of roof waterproofing sheet. |
Set the functional unit | Required. 1 m2 of plain roof waterproofing system. Define and declare the service life, and state the thickness or mass per m2. |
Declare which modules | Declare the full life cycle plus D: A1-A3, A4, A5, C1-C4 and D, and address B1-B5. This is the version that forces A4, A5, C and D. B6-B7 do not apply. |
Set the service life | Based on staying watertight. Use 30 years if you have no specific data. State the value and its source on the EPD. |
Model or state | In A5, describe the installation, the material use (including joints and waste), the jointing method, the installation energy and the waste handling. |
Compare products | Same rules as EN 15804. |
12. EN 17388-2:2024 - Flexible sheets for waterproofing, Part 2 (factory gate with options)
Built on EN 15804+A2:2019. Final standard. (Your copy is the 2025 UNE version.)
You need to | What to do |
Set the declared unit | Declare per 1 m2 of roof waterproofing sheet. |
Set the functional unit | Optional (you may use either a functional unit or a declared unit). If functional: 1 m2 of plain roof waterproofing system. |
Declare which modules | The baseline (A1-A3, C1-C4, D). A4, A5 and B are optional. B6-B7 do not apply. This is the lighter version of Part 1. |
Set the service life | Based on staying watertight. State the value and its source. |
Model or state | State the source of the service life. |
Compare products | Same rules as EN 15804. |
13. EN 17610:2022 - Building hardware
Built on EN 15804+A2:2019. Final standard. (Your copy is the UNE-EN 17610:2023 version.)
You need to | What to do |
Set the declared unit | Declare per 1 kg. State the parts and the mass per piece. |
Set the functional unit | Required when the product's function in the building is known. Write it as: ensure [function] using [product] at [x] kg net mass over [y] years, equal to at least [z] use cycles. Use the wording given for your hardware type (handles, hinges, locks, closers, and so on). If the function is unknown (for example hardware to be incorporated into a door or window), use the declared unit instead. |
Declare which modules | The usual baseline. Nothing extra is forced; the additions here are about the unit and durability. |
Set the service life | Base it on the tested number of use cycles. |
Model or state | State the parts and the mass per piece. |
Compare products | When you compare products with different service lives, use the same study period. |
14. EN 17662 - Execution of steel and aluminium structures [DRAFT]
Draft prEN 17662:2021, built on EN 15804+A2:2019. Not yet ratified, and read from a low-quality file, so this is the least reliable entry. Verify against a clean copy.
You need to | What to do |
Set the declared unit | Declare per 1 kg for products covered by EN 1090-1. Other products may use a declared or a functional unit. |
Set the functional unit | Use one for products not covered by EN 1090-1. |
Declare which modules | Could not be read cleanly from the draft. Verify. The standard is mostly about scrap and recycling accounting. |
Set the service life | A clause exists and appears to follow EN 15804. Verify. |
Model or state | Follow the scrap-input and recycling rules. Verify these against a clean copy. |
Compare products | Follow EN 15804. Confirm. |
Where this is heading
EPD data increasingly feeds the regulated Declaration of Performance and Conformity, and in time the construction Digital Product Passport (One Click LCA on the Digital Product Passport). The category rules are catching up to that role now. Getting your c-PCR right today is what keeps your EPD usable tomorrow.
To see how the layers fit together, read One Click LCA on what EN 15804+A2 changed and on the Construction Products Regulation. To model your next EPD, explore the One Click LCA EPD Generator.