How the New EU CPR Affects Compliance for Construction Products Sold in Europe

What is the New Construction Products Regulation (CPR)?
The Construction Products Regulation (CPR) sets harmonised rules for placing construction products on the EU Market. The new CPR (Regulation (EU) 2024/3110) modernises the existing framework (Regulation (EU) No 305/2011) by placing a strong emphasis on sustainability, digitalisation, and market surveillance, making it a key element of the EU's Green Deal.

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What is Classified as a Construction Product?

"Any formed or formless physical item, including -printed products, or a kit that is produced and placed on the market... for incorporation in a permanent manner in construction works or parts thereof, and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works."

Construction Works includes both buildings (like houses, offices, and factories) and civil engineering works (like bridges, roads, and dams).

Excluded are:

• Individually Manufactured or Custom-Made Products
• Heritage Products

Who Does It Affect?

The regulation affects all economic operators in the construction product supply chain, including:

• Manufacturers: Primarily responsible for the product's compliance.
• Importers and Distributors: Must ensure products bear the CE marking and are accompanied by the required documentation.
• Fulfilment Service Providers and Online Marketplace Operators: Now subject to specific obligations for the first time.

Compliance is essential for continued, or new, market access in the EU for any product considered a construction product and covered by a harmonised technical specification (harmonised standards or European Technical Assessments).

Note that micro-enterprises (having fewer than 10 employees and an annual turnover or balance sheet total of less than EUR2 million) benefit from simplified procedures for the product assessment process.
 
What are the Key Changes and Requirements?

The new CPR introduces fundamental shifts in product information, environmental reporting, and market access:

1. Environmental Sustainability
The CPR significantly expands beyond traditional safety and technical performance to include new essential requirements related to environmental sustainability.

• Mandatory Environmental Reporting: Manufacturers will be required to declare and report on the environmental performance of their products, initially focusing on climate change impacts (e.g., CO2​ emissions and energy consumption) over the product's lifecycle.
• Expanded Scope of the Declaration of Performance (DoP): The DoP must now incorporate this environmental data, aligning with standards like EN 15804 (which defines rules for Environmental Product Declarations - EPDs).
• Future Requirements: The Commission is empowered to define additional product requirements on durability, repairability, and recyclability through delegated acts for specific product families.

2. Digital Product Passport (DPP)
One of the most significant changes is the introduction of the Digital Product Passport (DPP).

• The DPP is an electronic record that will store and provide access to all the product-specific information required by the CPR (including the Declaration of Performance and environmental data).
• The information will be accessible via a data carrier (like a QR code or RFID tag) affixed to the product or its packaging alongside the CE marking.
• It aims to enhance transparency, improve traceability throughout the value chain (from production to end-of-life), and facilitate market surveillance.

3. CE Marking
The CE marking remains the product's "passport" for the EU market, but its meaning is expanded. The CE marking now indicates conformity with both technical performance and environmental sustainability requirements as outlined in the new CPR.

What is the Timeline for Application?

The application of different provisions is phased:

• 8 January 2026  Most of the new regulatory articles become applicable (e.g., new operator obligations).
• Within 18 months of relevant delegated act the Digital Product Passport (DPP) becomes mandatory for the specific product category covered by the act. (Expect first delegated acts to be issued in the coming years).
• Two years after entry into force  penalty provisions for non-compliance will become applicable.
• Ongoing (2025 onwards), harmonised product standards are gradually reviewed and updated. The old and new CPR regulations will coexist until all new standards are in place.

 
What Should You Do Now?

To prepare for compliance and maintain market access, companies should take proactive steps:

• Review your Product Portfolio: Determine which products fall under harmonised technical specifications and assess your current DoP and CE marking compliance.
• Begin Environmental Data Collection: Start calculating and collecting the necessary life-cycle environmental data, especially CO2​ emissions and energy consumption, aligned with EN 15804. This data is the foundation for the new environmental DoP and the DPP.
• Plan for Digital Product Passport: Begin planning the required data infrastructure and carrier solution (e.g., QR codes, data management systems) to store and provide access to the DPP information seamlessly.
• Ensure your compliance, product development, sustainability, and legal teams are aligned and trained on the new requirements and their staggered application.

Share this article with your cross-functional teams to align on a strategy for CPR compliance. Next further help? Contact me.