EuroWindoor position on Worst-case LCA values reported in the future DoPC under the new CPR
The new Construction Products Regulation (EU) 2024/3110 (CPR) requires environmental sustainability declaration in the DoPC giving the European Commission the task to establish harmonised rules on how to express the environmental performance of construction products in relation to their essential characteristics, including on life cycle assessment on Basis of Annex II. Recital 7 clearly states that new requirements should not become disproportionately burdensome, particularly for SMEs. The implementation of the regulation should therefore be based on proportionality and functional equivalence, rather than strictly conservative assumptions.
In contrast to this, the outcome of Milestome B from the CPR Acquis process – Sub-group on Environmental Sustainability introduces a significant shift by requiring manufacturers to declare Life Cycle Assessment (LCA) values in the Declaration of Performance and Conformity (DoPC) either based on the worst-performing variant across production sites or through product-specific assessments. This change raises concerns over compliance complexity, a lack of clear methodology for determining worst-case values, and the risk of overestimating environmental impacts. It may also create inconsistencies in building-level LCA assessments and disadvantage manufacturers investing in more sustainable production. Furthermore, by enforcing worst-case declarations in certain cases, the regulation distorts competition based on Global Warming Potential (GWP) values, as products with identical functions may be benchmarked using different methodologies. This position explores these challenges and suggests advocating the principles of the weighted average method as a more accurate, practical, and fair approach to environmental performance reporting.
For the full position, see the following link:
EuroWindoor Position on Worst-case LCA DoPC values
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