The 7 biggest misunderstandings about the new CPR law

The revised Construction Products Regulation (CPR) brings important changes for construction product manufacturers. While the phased rollout by product group creates some uncertainty, many key aspects are already clear. Now is the time to clear up common misconceptions, because standing still means falling behind.

Here are the 7 biggest misconceptions about the new CPR law: 

1. The introduction of the new CPR-2024 will be postponed again

In fact, the revised CPR (CPR-2024) has already entered into force, this happened 20 days after its publication in January 2025. The introduction is step-by-step:

•         Most of the articles will apply one year after their entry into force.
•         For the other articles, an as yet unknown period applies, with the exception of Article 92 (market surveillance sanctions). A period of two years applies to this.

The planning for the harmonized standards is also constantly evolving. Once the harmonized European standard (hEN) for a product group has been adapted and published, it enters into force. In practice, this means that the exact date is not yet known. It is therefore important to stay informed about the final publication of the hEN for your product group.

2. The trade association will arrange it

It's nice if your trade association thinks along, but the responsibility lies with you as a manufacturer. You must calculate the environmental performance (or have it calculated) with an LCA, a life cycle analysis. Then you have to ensure that there is a DOPC, a Declaration of Performance and Conformity. You must also have it checked by a notified body yourself.

In addition, industry averages, for example for the LCA, are no longer accepted under the CPR-2024. This means that you have to provide the LCA for your own products yourself, for example with LCA software such as R<THINK.

3. The requirements of the CPR-2024 are the same as the old requirements

The big difference is in the environmental paragraph. You will soon have to show the environmental impact of your product, over the entire life cycle. You must have these calculations checked. And your DOP becomes a DOPC: not just performance, but also compliance.

Another major difference is that, unlike the CPR-2011, used and refurbished products are now explicitly included in the scope of the CPR-2024.

4. I need an EHR for everything

Not quite. An environmental declaration on the DOPC will soon be mandatory, but only for products to which a harmonized standard applies. And: you do not have to publish the environmental declaration for the individual products as an EPD, which can save a lot of money in publication costs. We will move towards a form of system certification, where the notified body will assess the procedures, software and qualifications of personnel.

5. I only need one DOPC for my entire range

This is only allowed if all your products are comparable in terms of performance. You will soon have to create a separate DOPC for each product family, with the corresponding environmental information. Here too, under the new CPR, industry averages no longer apply.

6. CPR is the same as CE marking

CE marking is a consequence of the CPR. But the CPR goes further: it is the basis on which you determine whether you have to mark CE, which services you have to declare and how you have that checked. CE marking is the label, CPR is the recipe behind it.

7. My business is small, so this doesn't apply to me

The CPR-2024 does not distinguish between large or small (for the time being). Even if you are self-employed and deliver the same product more than once, you must meet the requirements. There may be an exception for SMEs, but nothing concrete is known about that at the moment.