On this page
- Why EU buyers ask for EN 15804+A2 EPDs
- What EN 15804+A2 requires
- Product groups and the c-PCRs that apply
- Sector points we check in Turkish plants
- Scenarios for EU construction projects
- EN 15804 EPDs, CBAM and the CPR
- How a construction product EPD project runs
- Covering a product range in one EPD
- What you receive
We prepare EN 15804+A2 environmental product declarations for construction products made in Turkey and sold into EU projects, including cement, steel, ceramics, insulation, glass and aluminium profiles. The work covers the LCA, plant data collection, the EPD itself and coordination with the independent verifier and programme operator, so your product can be specified in tenders, whole-building LCAs and LEED or BREEAM projects.
Why EU buyers ask for EN 15804+A2 EPDs
EN 15804 is the European core product category rule for construction products. Since amendment A2 (2019), it is aligned with the EU Environmental Footprint method, and EPDs to the earlier A1 version are being phased out by programme operators and building LCA tools. A buyer in the EU who asks for "an EPD" for a construction product nearly always means an EN 15804+A2 EPD.
Demand comes from several directions at once.
- Whole-building LCA under EN 15978, which the recast EPBD (EU) 2024/1275 makes mandatory for disclosure of life-cycle GWP for new buildings over 1,000 m² from 1 January 2028 and for all new buildings from 1 January 2030.
- LEED, where the Building Product Disclosure and Optimization credit in v4 and v4.1 counts products with Type III EPDs, and product-specific verified EPDs carry more weight than industry-average ones. LEED v5 merges the material credits and continues to favour product-specific EPDs.
- BREEAM, whose materials life cycle credits rely on building LCAs that use EPD data in place of generic values.
- National schemes such as FDES on the French INIES database and the Dutch national environmental database.
- The Construction Products Regulation (EU) 2024/3110, under which GWP becomes a declared characteristic in CE marking once each product family's new harmonised technical specification applies.
What EN 15804+A2 requires
Under A2, every EPD must declare modules A1-A3 (product stage), C1-C4 (end of life) and D (benefits and loads beyond the system boundary). A cradle-to-gate EPD covering only A1-A3 is allowed only if three conditions are all met. The product is physically integrated with other products during installation so it cannot be separated at end of life, it is no longer identifiable at end of life because of a physical or chemical transformation, and it contains no biogenic carbon. Cement, mortar and some coatings can meet these conditions. Steel, glass, tiles, insulation boards and aluminium profiles normally cannot.
The standard requires 13 core impact indicators, including GWP split into total, fossil, biogenic and land use and land use change, plus 6 additional indicators, resource use and waste indicators, and the biogenic carbon content of product and packaging. Cut-off rules allow excluding flows below 1 per cent of mass and energy per unit process, with no more than 5 per cent excluded per module. Company-specific data should be no older than 5 years and generic data no older than 10. A full breakdown of modules is in our article on EN 15804+A2 modules explained.
Product groups and the c-PCRs that apply
Many product groups have a European complementary PCR (c-PCR) that adds rules on top of EN 15804. Programme operators such as the International EPD System publish matching c-PCRs under their construction PCR 2019:14. These are the ones we use most for Turkish manufacturers.
| Product group | Complementary rules | Data that moves the result most |
|---|---|---|
| Cement and building lime | EN 16908 | Clinker ratio, kiln fuel mix including alternative fuels, process CO₂ from calcination |
| Concrete and precast elements | EN 16757 | Cement content and type, supplementary materials, aggregate transport |
| Structural steel and aluminium products | EN 17662 | Steel route (electric arc furnace or blast furnace), scrap share, electricity source, module D credit |
| Ceramic tiles | EN 17160 | Natural gas use in spray drying and firing, body composition, glaze |
| Thermal insulation | EN 16783 | Blowing agents, binder, density, raw material origin |
| Flat glass and glass products | EN 17074 | Furnace energy, cullet share, soda ash |
| Windows and doors | EN 17213 | Billet origin and recycled content, anodising or powder coating, glazing |
For cement, note that EN 16908 is itself being revised under the new CPR standardisation request, which sets 30 June 2027 as the target for the revised standard. We follow the programme operator's transition rules when a c-PCR changes during your project.
Sector points we check in Turkish plants
Each sector has a few modelling choices that verifiers look at closely. In cement plants we reconcile clinker production with the plant's greenhouse gas monitoring report and treat alternative fuels such as tyre-derived fuel or refuse-derived fuel under the PCR rules for waste inputs. In steel, the electric arc furnace route dominates Turkish production, so scrap origin, pre-consumer and post-consumer shares and electricity supply decide the result.
For aluminium profiles, the origin of primary aluminium in purchased billet often outweighs everything that happens in the extrusion plant, so supplier data is worth chasing. In ceramics and glass, natural gas consumption per tonne and the share of recycled content are the main levers. Across all sectors, how you model electricity matters. Turkey's YEK-G renewable energy certificates can be used where the PCR's quality criteria for contractual instruments are met, and the residual mix applies otherwise.
Scenarios for EU construction projects
Modules A4 and A5 and the end-of-life modules depend on where the product is used. For a Turkish product going to a project in Germany or the Netherlands, A4 has to reflect the real route, for example truck to Mersin or Ambarlı, sea freight and onward road transport, not a domestic default. End-of-life scenarios for C1-C4 and D should reflect recycling and landfill rates in the target market. Where buyers in several countries use the EPD, we model a representative scenario and document how other scenarios would change the result, so building LCA practitioners can adjust it.
EN 15804 EPDs, CBAM and the CPR
Cement, iron and steel and aluminium exporters also report under CBAM, and clients often ask whether one figure can serve both. It cannot be copied across. CBAM embedded emissions follow their own monitoring rules, system boundaries and default values, while an EPD's GWP follows EN 15804+A2 and the PCR. The plant data underneath is largely shared, though, so we collect it once and run both calculations from the same source. See our CBAM embedded emissions calculation service for that side.
Under the CPR, the environmental declaration in the declaration of performance and conformity will be checked by a notified body under assessment system 3+, separately from EPD verification. The calculation method is the same EN 15804+A2 approach, so an EPD with well documented plant data is the strongest starting point. As of October 2026, no product family had yet reached the point where the GWP declaration applies under the new CPR, and the first are expected from 2027 onwards as revised standards are delivered.
How a construction product EPD project runs
- Scoping (1 to 2 weeks). Product range, plants, c-PCR, modules, programme operator and verifier.
- Plant data collection (2 to 6 weeks). Twelve months of production, energy, materials, emissions, waste and logistics data, with a site visit or video walk-through.
- LCA modelling and scenarios (2 to 4 weeks). Including A4 and end-of-life scenarios for the target markets.
- EPD drafting (1 to 2 weeks). In the operator's template, in English.
- Verification (2 to 6 weeks). We answer all findings until the statement is issued.
- Publication (1 to 2 weeks). Registration, publication and delivery of the digital data set where available, so building LCA tools can import your figures.
Covering a product range in one EPD
Tile producers, insulation manufacturers and aluminium extruders usually sell dozens or hundreds of variants. Publishing one EPD per variant is rarely sensible. We group products by process and composition, test how far results spread within each group, and then choose between a multi-product EPD with separate result tables, an average EPD, or a representative product with a stated variation. For profiles and tiles, results can often be expressed per kg or per m² with a conversion table, so specifiers can scale them to the exact item they use.
What you receive
- A verified EN 15804+A2 EPD, registered and published by your chosen programme operator
- The confidential LCA project report that the verifier reviewed
- Digital EPD data where the operator provides it, for import into building LCA tools
- A one-page summary of the main results and the scenarios used, for sales and tender teams
- A hotspot list showing which inputs drive GWP and how much each lever could change it
The general process, programme operator options and cost drivers are described on our EPD consultancy page. When you need a broader LCA for ecodesign alongside the EPD, see life cycle assessment services.