An SME-friendly implementation of the sustainability requirements of the Construction Products Regulation: EBC & SBS Joint Position Paper

September 9, 2025

The European Builders Confederation (EBC) and Small Business Standards (SBS) detail in a joint paper how to efficiently implement the sustainability requirements introduced by the new Construction Products Regulation (CPR). Together, EBC and SBS propose a practical, proportionate and SME-friendly approach, to create a green and digital transition tailored to the realities in the construction sector.

The parallel introduction of mandatory environmental essential characteristics and the Digital Product Passport constitute progress in aligning the construction sector with climate and digital priorities. For a seamless implementation, EBC and SBS highlight challenges affecting manufacturers, particularly SMEs, and possible solutions.

EBC and SBS underline that sustainability requirements must recognise sector realities. In the paper, they detail proposals ranging from calibrated averaging over time, thresholds to distinguish meaningful environmental variation, pragmatic criteria for product-type grouping, to the separation of logistical variables such as transport distance from core impact indicators. The SME representatives also highlight the need of a risk-based logic for data inspections by notified bodies and the unique context of the EU’s Outermost Regions, which should not be disadvantaged or excluded from contributing to the green transition.

Existing and practical sustainability compliance routes for SMEs are being compromised by several challenges. These include the use of a “worst-case” methodology for environmental performance declarations (EPDs), a lack of clarity around the mechanisms for simplified procedures and collective EPDs, and limited access to verified and affordable background datasets. Additionally, SMEs are facing the emerging expectation of full-site inspections by notified bodies.

EBC Secretary General Fernando Sigchos Jimenez stated: “Our recommendations aim to deliver on environmental ambitions, boost SME competitiveness and reflect the operational reality of the construction sector. The regulatory framework must be proportionate and inclusive, so that SMEs committed to playing their part in achieving Europe’s sustainability goals can do so.

SBS Secretary General Maitane Olabarria added: “As standardisation under the new CPR moves forward, sustainability must be more than an ambition – it has to be something all market players can put into practice, in particular smaller ones. To make that possible, SMEs need mechanisms and guidance that reflect the way they work: diverse, local, and flexible.”

GOOD PRACTICE: the EBC-SBS guide for SMEs on the CPR

To assist SMEs in navigating the new CPR, EBC and SBS have developed a guide explaining in plain language how to address new obligations, including practical checklists, visuals and examples.