Estonia is not participating in the development of circular economy standards for the construction sector because no stakeholder group has expressed an interest in doing so. Nevertheless, all market participants — architects, designers, builders, and manufacturers of construction materials — will still be required to comply with those standards. The only difference is that, because we are currently not engaged, market participants have no preparatory information regarding the environmental performance requirements that will apply to buildings and construction products. Once the standards enter into force, we will have to comply with them — without any prior public debate.

The most significant change that construction sector circular economy standards are laying the groundwork for is the digital passport for construction products and buildings. This will be the only means by which conformance with environmental performance requirements can be communicated publicly. If Estonia does not participate in the development of construction sector circular economy standards, we must accept that none of our market participants will be able to prepare for obtaining a digital product passport, simply because the information will not be available. Typically, the first information about new market requirements becomes available during the public commenting rounds on draft standards. Under the rules of the European standardisation organisation, however, that information is only accessible to member states participating in the standardisation working groups. Consequently, if Estonia does not participate, we will have to wait until construction sector circular economy standards have entered into force. By that point, all competitive advantages will almost certainly have been foregone.

Under the Construction Products Regulation (CPR, (EU) 2024/3110), significantly stricter norms have been established for the environmental performance of construction products’ essential characteristics. In addition, under the EU Circular Economy Action Plan and the Ecodesign for Sustainable Products Regulation (ESPR, (EU) 2024/1781), it is already known that a digital passport requirement has been established for the construction sector. This is not just another IT gadget but a substantive, resource-valuing internal market requirement. The digital passport for buildings and construction products is a solution that helps realise the circular economy goals of the internal market. This is an exceptionally important new understanding, given that for some reason Estonia’s construction sector engages only with either the internal market’s climate objectives or the implementation of waste and energy efficiency directives — and not with circular economy objectives.

The draft technical standards for digital product passports are currently in the public consultation stage (prEN 18216, prEN 18219, prEN 18220, prEN 18221, prEN 18222, prEN 18223) and are documents describing the technical solution. These are tools that support the achievement of circular economy objectives, and their conceptual and terminological framework has been agreed upon through the circular economy standards (the 59-series).

For the construction sector, the substantive requirements for the digital product passport are set out in the Construction Products Regulation, which entered into force in January 2025. It is known that the first sector-specific circular economy standard derived from this regulation — prEN 18177 Circular economy in the construction sector. Framework, principles, definitions — has already completed the public consultation stage. The following construction sector circular economy standards are currently in preparation:

  • framework, principles, and definitions;
  • horizontal requirements for circularity information exchange for the building digital passport;
  • horizontal requirements for circularity information exchange for the construction product digital passport;
  • horizontal requirements for the reuse of construction products;
  • horizontal requirements for circular design of construction works and products;
  • guidance on the application of circular design for construction works and products;
  • indicators and methods for assessing the circularity of construction works, components, and products.

Deposit-refund systems are considered a lifeline for circular economy development in Estonia, and these could also be introduced for construction products by requiring manufacturers to agree to take back their new, surplus, or unsold construction products. However, the Construction Products Regulation devotes only a single — and substantively rather marginal — line to this, which means it will not carry us forward.

Compared with the previously applicable regulation, the most significant consequence of the new Construction Products Regulation is that new norms have been established for the declaration of the environmental sustainability of construction products. The product lifecycle must be calculated and environmental sustainability must be demonstrated at all stages, from the sourcing of raw materials and extraction of natural resources through to the final disposal of the product. From a carbon footprint reduction perspective, the use of recovered and remanufactured products and components provides manufacturers with an additional advantage, in that the calculated lifecycle begins from the point of removal from a building.

At this point it is worth clarifying what a remanufactured product is. It is not a window frame found in a salvage pile, nor a door rescued from a building being demolished. A remanufactured product is a construction product that has undergone a reprocessing process. In other words, a product that has merely been inspected, cleaned, or repaired is not a remanufactured product. Because a used construction product must be technically equivalent to a new product or better, separate harmonised technical specifications are being developed for used products — that is, products that have not become waste or have ceased to be waste.

As an important new requirement, provisions on climate resilience for buildings have been added. With the aim of ensuring environmental protection, including climate protection as one of its components, the regulation provides for the assessment of the performance and conformity of the essential components and materials of a construction product before they are integrated into that product — meaning that mandatory new norms also apply to essential components and materials.

Construction products for which the manufacturer has prepared a declaration of performance and conformity are affixed with a CE marking. This is the only marking that certifies conformity with the essential characteristics covered by harmonised technical specifications. Whereas previously only conformity with the single essential characteristic of global warming potential (GWP) was required for CE marking, it is now necessary to declare conformity with all environmental essential characteristics listed in Annex II of the regulation. This means that harmonised technical specifications must cover all lifecycle assessment-related essential characteristics, not just climate change impact. In simpler terms: whereas currently products can be placed on the market without a declaration of performance and conformity — but with an EPD — in the future the declaration of performance and conformity will contain the same information as the EPD, and more besides.

And now, take note! The Construction Products Regulation requires the establishment of threshold-based performance classes for 16 different product-specific environmental aspects. Only three of these are aspects that Estonia is currently addressing: minimising GHG emissions over the lifecycle; energy use and efficiency; and waste volumes. The remaining 13 are either topics that may already be familiar or are entirely new. For reference, here is an overview of all the product requirements introduced by the regulation:

  • durability;
  • minimum GHG emissions over the lifecycle;
  • maximum content of reused and recycled materials and by-products;
  • selection of safe, designed-for-sustainability, and environmentally sound substances;
  • energy use and efficiency;
  • resource efficiency;
  • modularity;
  • reusability;
  • upgradability;
  • repairability;
  • ease of maintenance and renovation;
  • recyclability and remanufacturing capability;
  • separability of different materials;
  • sustainable sourcing;
  • minimum packaging;
  • waste volumes.

The purpose of the construction sector circular economy standards currently in preparation is to establish the circular economy principles, guidelines, and requirements needed to address all 16 new product requirements for construction products and buildings. The standards cover the design, deconstruction, and end-of-life stages, and apply to both new and existing buildings as well as to the construction products, building materials, and components integrated into them. Since the standard instructions for use and safety information may not always be accessible to the operators responsible for preparing for reuse, reuse, remanufacturing, and recycling, this information will henceforth be made available to all, at any time, through digital product passports.

The Construction Products Regulation therefore requires a review of Estonia’s current circular economy narrative and a fundamental conceptual shift in two respects:

  • the circular economy is not advanced through separate collection of construction waste;
  • the circular economy is not advanced through low-carbon construction.

Separate collection of construction waste is simply one precondition of the circular economy. The carbon footprint is simply one of many environmental impacts.

A call to action for construction sector leaders!
The new rules are changing the game for everyone — clients, designers, manufacturers, and builders alike. The circular economy in construction is no longer a choice; it is an inevitability. This is your opportunity to shape the future standards!

Estonia needs information on circular economy standards for the construction sector, and to obtain it, at least three professional associations must express an interest to the Estonian Centre for Standardisation (EVS).

If you are part of a professional association, take the initiative! Or share this with your association — every voice counts!

Let us together build the new rules of construction — responsibly and intelligently.

Anu Kull

Chair of EVS/TK 83 Circular Economy

01.08.2025