UK Construction Product Regulations: A Practical Guide

Importers and manufacturers of construction products looking to supply their products in the United Kingdom must comply with the Construction Products Regulation (EU) 305/2011 (CPR 2011), and other regulations.

In this guide, we primarily focus on the requirements of the Construction Products Regulation (EU) 305/2011 and provide answers to frequently asked questions about the regulation. However, the guide also mentions other regulations that are relevant to construction products, such as the UK Timber Regulation and the UK REACH Regulation.

Construction Products Regulation (EU) 305/2011

The Construction Products Regulation (EU) 305/2011 sets rules for expressing the performance of construction products, the use of UKCA marking and other labelling requirements, documentation requirements, and more.

To comply with the regulation, the manufacturer must first assess if there are designated standards that cover their construction product.

Designated standards allow manufacturers to demonstrate that their products comply with the technical requirements set by the regulation. Generally, designated standards under the regulation include safety and performance requirements, but they may also include information relating to other topics, like labelling that must be featured on the product.

If there are relevant standards, the manufacturer must draw up technical documentation and a declaration of performance and affix the UKCA marking. Additionally, the manufacturer should provide traceability information, instructions and safety information.

The same requirements apply where there are no harmonised standards that fully cover the product, but the manufacturer chooses to have the product conform to a UK Technical Assessment.

Note that the Construction Products Regulations 2013 contain offences for non-compliance with the Construction Products Regulation (EU) 305/2011.

Which products are covered by the CPR 2011?

We found some examples of covered products by looking at the titles of designated standards under the regulation:

• Roomheaters
• Inset appliances including open fires
• Cookers
• Independent boilers
• Residential solid fuel burning appliances
• Flued oil stoves with vaporizing burners
• Lighting columns
• Fire detection and fire alarm system
• Building hardware
• Cement
• Vitrified clay pipe systems for drains and sewers
• Ball valves and closed bottom taper plug valves for gas installations
• Masonry cement
• Tube heaters
• Decorative laminates
• Radiators and convectors
• Fly ash for concrete
• Building lime

Note that the above list is not exhaustive.

Standards

Here are some examples of designated standards:

EN 16510-2-1 – Residential solid fuel burning appliances – Part 2-1: Roomheaters

EN 1 – Flued oil stoves with vaporising burners

EN 40-7 – Lighting columns — Part 7: Requirements for fibre reinforced polymer composite lighting columns

EN 54-2 – Fire detection and fire alarm systems — Part 2: Control and indicating equipment

EN 179 – Building hardware — Emergency exit devices operated by a lever handle or push pad, for use on escape routes — Requirements and test methods

EN 331 – Manually operated ball valves and closed bottom taper plug valves for gas installations for buildings

You can find the full list on the guidance page “Designated standards: construction products” published on GOV.UK.

UK Technical Assessment

When the performance of a construction product cannot be entirely assessed using a designated standard or when no standards exist, a manufacturer may approach a technical assessment body (TAB) for a UK Technical Assessment. The TAB issues the UK Technical Assessment on the basis of a UK Assessment Document according to Article 26 of the regulation.

Where a TAB issues the UK Technical Assessment, the manufacturer must draw up the declaration of performance and affix the UKCA marking.

Declaration of performance

When there exists a designated standard that covers the construction product or where the product conforms to a UK Technical Assessment, the manufacturer must draw up the declaration of performance according to Article 4 of the regulation.

The manufacturer should use the model set out in Annex III and follow the content requirements specified in Article 6 when creating the declaration. Additionally, it should supply the document with the product according to Article 7, and keep it for 10 years.

Technical documentation

Where the manufacturer needs to create the declaration of performance, it should draw up technical documentation as the basis for the declaration. The manufacturer should keep the technical documentation for 10 years.

According to Article 11, the technical documentation should contain a description of all the relevant elements related to the required system of assessment and verification of constancy of performance. The system explains what are the tasks for the manufacturer and the approved body (if applicable) in relation to the assessment of the construction product.

The system of assessment and verification that must be followed is generally mentioned in designated standards and UK Technical Assessments.

UKCA marking

When a designated standard covers the construction product or where the product conforms to a UK Technical Assessment, the manufacturer must affix the UKCA marking and ensure that other information contained in Article 9 follows it.

Other labelling requirements

The manufacturer of a construction product should provide the following information according to Article 11 of the regulation

• Product identification (e.g. batch number or serial number)
• Manufacturer’s contact information (e.g. manufacturer’s name, manufacturer’s contact address)

Instructions

The manufacturer should provide instructions and safety information in English. Note that some standards also contain information relating to instructions (e.g. instructions for use).

Approved bodies

Where a designated standard covers a construction product or where the product conforms to a UK technical assessment, those documents specify which system of verification and performance is required. Some of these systems require the involvement of an approved body.

All the systems, including tasks for the approved body (if any), are found in Annex V of the regulation.

UK CPR 2011 FAQ

How are construction products defined in the UK?

In Article 2 of the Construction Products Regulation (EU) 305/2011, the following definition for “construction product” is found:

‘construction product’ means any product or kit which 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;

Is UKCA marking required for construction products in the UK?

The UKCA marking is required in two scenarios:

• A designated standard covers the construction product
• The construction product conforms to a UK technical assessment

How do I know if an approved body is required?

Designated standards and UK Technical Assessments contain details relating to the system of assessment and verification needed for the construction product. Annex V of the Construction Products Regulation (EU) 305/2011 mentions all the systems and mentions where an approved body is required.

Is testing required for construction products in the UK?

It is generally necessary to test your product in order to ensure compliance with designated standards, UK Technical Assessments, and other safety and performance requirements set by the regulation.

Is CE marking accepted for construction products in the UK?

Yes, CE marking is accepted for construction products in the UK, provided that the rules in Article 16A of the Construction Products Regulation (EU) 305/2011 are followed. We also found the following information in the guidance page “Construction Products Regulation in Great Britain” published by GOV.UK:

“On 2 September it was announced the CE mark will continue to be available when placing construction products on the market across the UK.”

Other Regulations

Timber Regulation (EU) 995/2010

This regulation applies to certain construction products that contain timber. For instance, “assembled flooring panels” are specifically mentioned in the Annex of the Timber Regulation as a covered product. Companies that supply products that fall under the scope of the regulation must assess whether they are seen as an operator or a trader in relation to the regulation to confirm their obligations.

Here are some of the key requirements in the regulation:

• Due diligence system obligations for operators
• Traceability and record-keeping obligations for traders

REACH Regulation (EC) 1907/2006

This regulation requires that companies supplying construction products ensure that the product does not contain restricted substances above the set limitations. For instance, arsenic compounds used in the preservation of wood must not be used in residential or domestic constructions (whatever the purpose).

Here are some of the key requirements in the regulation:

• SVHC notification requirements
• Chemical substance registration (for substances)
• Substance restrictions

Persistent Organic Pollutant Regulation (EU) 2019/1021

This Regulation contains substance restrictions that affect certain construction products. For example, concentrations of hexabromocyclododecane that are added as a flame retardant to expanded and extruded polystyrene foam insulation must not exceed 0,01 % by weight.

Here are some of the key requirements in the regulation:

• Substance restrictions
• Requirements for holders of stockpiles
• Waste management requirements

Note: Contains public sector information licensed under the Open Government Licence v3.0.