DPP for Cement and Concrete: CPR and CBAM

Cement is one of the rare products where three strands of EU law meet at once. The Carbon Border Adjustment Mechanism (CBAM) has been in its definitive period since 1 January 2026, with cement and clinker high on the list. The new Construction Products Regulation (CPR, (EU) 2024/3110) provides for a Digital Product Passport for construction products. EN 15804-based EPDs are already standard on green-building projects. All three want data from the same kiln.

For the general CPR framework see the DPP for construction products and the new CPR; here the focus is on serving all three regimes from one cement-specific dataset.

Three regimes, one kiln

Boundaries and units differ, so none replaces another; the inputs — fuel, calcination emissions, clinker share, production volumes — are shared. As in CBAM and the DPP: resolve methodology differences in the calculation layer, not in data collection.

Cement-specific fields

Cement's carbon story largely reduces to two numbers: the clinker factor (the share of clinker in a tonne of cement) and the emission intensity of clinker production. The supplementary cementitious materials that replace clinker — blast-furnace slag, fly ash, calcined clay, limestone — lower both the CBAM embedded emissions and the EPD's GWP. The EN 197-1 cement type (CEM I to CEM V) is the standard name for that composition; the passport should carry type code, clinker factor and constituent types together.

A sensible field list for the passport:

• Cement type and strength class (EN 197-1 designation)
• Clinker factor and shares of supplementary materials
• Production site identifier and kiln line
• Embedded emissions per tonne (CBAM-consistent) and the EPD GWP value (A1–A3)
• EPD reference, programme operator and validity date
• Batch or delivery identifier (silo, loading date)

Access tiers will follow from the CPR's delegated and implementing acts; for now the DPP data fields framework works as a template.

Concrete: cement data flows upward

Ready-mixed concrete and precast elements are not in CBAM, yet most of concrete's carbon comes from cement. A concrete producer needs the EPD and clinker factor of every cement it uses; aggregates, admixtures and transport are added on top. This is the intermediate-product logic of iron and steel and aluminium: the input's passport feeds the finished product's passport. With structured data from the cement producer, the concrete producer's EPD and CPR passport follow almost by themselves.

Granularity and evidence

For cement the natural granularity combines the product type and plant level (where EPDs and CBAM live) with the batch/delivery level (where traceability and conformity live). As in choosing model, batch or item: stable data once at model level, variable data at batch level. Evidence for the carbon figure: verified installation data for CBAM, third-party verification for the EPD, a reference to both in the passport. The product carbon footprint guide covers the calculation route.

The sequence for a Turkish producer

Türkiye is one of the EU's significant cement suppliers, and the CBAM definitive period affects that trade directly. Our suggested order:

1. Close the plant-level CBAM dataset first: the steps in the CBAM definitive period for steel exporters apply to cement too; default values carry a penalty premium.
2. Keep an EPD current for every plant and cement type; store module-level results as fields, not as a PDF.
3. Derive the clinker factor and constituent shares automatically from production records.
4. Tie the batch identifier to the delivery note and to the data carrier.
5. Generate the CBAM report, the EPD update and the passport draft from the same dataset.

The CPR passport's timeline is staged with the renewal of harmonised standards; for other sectors see the DPP timeline by sector.

Frequently asked questions