The new CPR legislation: what does it mean for you?

With the introduction of the revised Construction Products Regulation (CPR), a lot is changing for manufacturers of construction products. The updated CPR will take effect gradually, depending on the product group. But what exactly does this European legislation entail? What can you expect? And why is it smart to start preparing now?

What exactly is the CPR? 

The Construction Products Regulation (CPR) is European legislation designed to promote the free movement of construction products within the EU. The main functions of the CPR are: 

  • To create a single internal market for construction products 
  • To reduce trade barriers and ensure safe and efficient product use 
  • To regulate CE marking, third-party assessments and market surveillance 
  • To establish a common technical language by defining how product performance is assessed, verified and communicated 
  • To link EU legislation with national building regulations through the Basic Requirements for Construction Works (BRCW) 

What is the definition of a construction product under CPR-2024?

Under the CPR, a construction product is defined as any product manufactured for permanent incorporation in construction works, including buildings and civil engineering structures.

What’s new in CPR-2024? 

The biggest change? Environmental impact now plays a much larger role. As a manufacturer of construction products, you will need to demonstrate the environmental impact of your product. The Declaration of Performance (DoP) will also change: it becomes a DoPC, where the C stands for conformity. 

An EU declaration of conformity is a mandatory document that you, as the manufacturer or your authorized representative, must sign to declare that your product complies with EU requirements. By signing the declaration of conformity, you declare that you take full responsibility for ensuring your product meets all applicable EU legislation. 

Another important change concerns supervision. For all CE-marked products, monitoring by a so-called notified body will become mandatory. Even if you fall under the lightest system (for the experts: system 4), your products will still be subject to inspection. 

 

What does CPR-2024 mean for you as a manufacturer of construction products?

Broadly speaking, for each product or product group covered by a harmonized standard, you will need to complete the following steps:

    Check the new harmonized standard (hEN) and determine which aspects must be verified by a notified body.

    A new mandatory step is calculating environmental performance using an LCA (Life Cycle Assessment).

    Prepare a DoPC

    This is a Declaration of Performance and Conformity.

    Have your DoPC verified by a notified body such as Kiwa.

    In the future, the DPP (Digital Product Passport) will also be required.

    This is a new format for submitting your DoPC. Additional timelines apply here: 1.5 years after publication of the hEN, submission via the DPP will be mandatory.

When will the new version of the CPR take effect? 

A simple question with a complex answer. The new version of the CPR will officially take effect on 1 January 2026. However, for parts where the hEN (the harmonized European standard) has not yet been updated, the old CPR will remain in force. The new CPR will be introduced gradually for those specific areas. 

The start date therefore varies by product group, which can result in significant differences in implementation timelines, ranging from late 2025 to 2038. There is also still uncertainty about the exact start dates per product group. Despite this uncertainty, it is important to understand what’s coming and when. 

Which product groups will be the first to fall under CPR-2024?

Implementation will take place in phases. Precast concrete and steel will be the first. Next will follow structural steel, reinforcing steel, windows and doors and then cement and insulation materials. Other product groups will follow later. But beware: this schedule is subject to change. 

The CPR also applies to small businesses. Once you manufacture a product covered by the CPR more than once, you must comply. There are discussions about a possible exemption for small and medium-sized enterprises (SMEs), but nothing has been decided yet. 

What can you do now?

Don’t wait until all the details for your product group are known. Preparation takes time. And perhaps more importantly: soon, the entire sector will have to get started at once, so software providers, consultants and notified bodies may become overloaded. Those who start early will get the best support and avoid delays.             

Construction Product Regulation Scheme

The Construction Product Regulation (CPR) No 305/2011 provides harmonized rules for marketing of construction related products in the European Union and assesses the performance of said products.