Starting January 8, 2026, the Construction Products Regulation requires product-specific carbon declarations for aggregates sold in the EU… right?
National averages won't meet compliance, site-level estimates might not either, or at least it isn't very clear right now… In reality, this regulation is implemented gradually. For the new CPR to be applied to products, each product group should harmonise its standard. As of today, the standards for aggregates are expected to be ready by 2029-2031.
Most aggregate suppliers we are speaking with are just now beginning to understand what this means.
Over the past 18 months, we've been working with quarries across Europe to establish their first product-level carbon measurements. Many came to these conversations expecting the exercise would be straightforward, confirming what they already believed: limestone is limestone, granite is granite, and carbon differences between products would be minor.
That assumption falls apart when the measurements start coming in.
Here's what we're discovering as suppliers measure for the first time, and why it will change how infrastructure projects are specified after CPR compliance kicks in.
What most suppliers believed going into this process was reasonable, given what we knew. For decades, infrastructure carbon assessments treated aggregates as background noise. The working assumption: aggregates are relatively uniform, low-carbon materials with minimal variation between suppliers or products.
Having worked in this sector for over 20 years, we made this same assumption on countless projects. 4-11 kg CO2eq/t served as acceptable proxies in environmental databases. Site averages offered slightly more precision. This approach made sense when we lacked granular data. It was pragmatic.
As suppliers work through their first product-level calculations, patterns are emerging that challenge conventional assumptions. Let me walk through what we're observing across sites in France, Germany, Poland and Hungary.
First pattern: aggregate carbon footprints span a 160x range from 0.3 kg CO₂/t for natural gravel requiring minimal processing to 48.9 kg CO2/t for dried speciality aggregates with intensive thermal treatment. These are all "aggregates" in specification language, but their carbon profiles couldn't be more different.
Second: even within a single quarry, product variation ranges from 4 to 21 kg CO₂/t. One site we worked with showed an average of 4.7 kg CO2/t, which is reasonable by industry standards. But when they measured individual products, the actual range spanned 3.6 kg to 21.4 kg, depending on processing requirements. Drying, screening intensity, and specific gradation needs: the site average masked these variations entirely.
Third pattern (this surprised me when I first saw it): the primary drivers are operational, not geological. Drying processes, electricity grid carbon intensity, material routing through crushing stages, and pit-to-plant transportation distances. Two products from the same quarry can show 5x differences in carbon footprints purely based on how they're processed.
This variability creates interconnected challenges that most firms haven't fully considered yet:
Specification risk
If your carbon calculation assumes 4 kg CO₂/t based on site averages, but actual supplied products average 7 kg, it increases the carbon footprint of a standard asphalt by more than 5%. On a 100-km highway project, this represents an additional 6 000 tonnes of CO₂ emissions. This would affect compliance precision and potentially financing conditions.
Bid accuracy
Engineering firms increasingly face carbon performance requirements in competitive tenders. If you're using national averages for carbon estimates while competitors use product-level data, there's a systematic difference in how projects get bid. When clients verify post-construction performance, that gap becomes visible and contractual.
Portfolio reporting
Infrastructure investors, development banks, and public authorities require portfolio-wide carbon tracking now. The question "what's the actual carbon footprint of infrastructure we financed in 2024-2025?" can no longer be answered with "we used national averages." The reporting standards being applied to infrastructure investments require granularity we haven't historically provided.
The competitive dynamic I'm observing: firms with product-level data can optimise material selections during design, before procurement locks in specifications. Optimisation requires data at decision-making time, not after the fact.
CPR now mandates this measurement progressively, which is key, as we have outlined.
This creates an information flow that hasn't existed before. Suppliers measure products they've never quantified this precisely. That data flows to contractors and engineering firms. Engineering firms incorporate it into specifications and carbon assessments. Clients can verify that declared carbon performance matches delivered materials.
The regulatory compliance date is fixed, yes. But the industry is also well aware that the operational capability to use this data effectively is still being built.
Most firms are still figuring out how to integrate product-level carbon data into design workflows, specification practices, and procurement evaluation. This requires changes across multiple teams, and few organisations had this capability built before 2024.
Our deep experience of infrastructure projects tells us that systematic optimisation of material choices (replacing assumptions with measurements) can scale across this entire investment volume. Also, when we analyse infrastructure projects in which teams had product-level material data from the design phase onward, patterns emerge.
Projects show 15% cost reduction on pavement structures through informed material sourcing. Carbon reduction potential reaches 50% through material selection optimisation. Maintenance costs drop by 70% through durability-focused specifications. Natural resource conservation improves by 80% through circular material integration.
(Source: ORIS analysis of infrastructure projects using product-level material carbon data, presented at IRF Annual Conference 2021)
These results come from projects in which engineering teams had granular material data during the design phase, when material alternatives could still be evaluated and specified.
The shift from voluntary carbon measurement to mandatory compliance under CPR accelerates this transformation. But the fundamental change (and this is what interests me) is moving from empirical, experience-based material decisions to data-driven, systematically evaluated alternatives.
CPR provides the regulatory push. ORIS Materials Intelligence provides the capability. Engineering firms that systematically develop this capability will set new standards for infrastructure delivery.
For engineering firms, CPR will make product-level carbon data mandatory.
The question becomes: whether to use that data for optimisation during design, or simply for compliance reporting after the fact.
And January 8th is a compliance milestone… and just the beginning.