Construction Products Regulation (CPR) 2024: An Essential Guide

Construction products are subject to performance, safety and other requirements. Currently, these requirements are set by the Construction Products Regulation 2011. However, on 8 January 2026, the Construction Products Regulation 2024 will take effect and repeal it.

In this guide, we cover the requirements of the new Construction Products Regulation, including labelling, documentation, digital product passport, and other requirements. Additionally, we also compare some of the key requirements between the old and new regulations.

What is the Construction Products Regulation 2024?

The Construction Products Regulation 2024 is a regulation that covers construction products and requires manufacturers and other economic operators to meet its environmental, performance, and safety requirements.

Additionally, the regulation sets CE marking requirements, which must be supported by documentation, including the declaration of performance and conformity and technical documentation.

The regulation introduces some new requirements for construction products, such as the following:

• The digital product passport
• The declaration of performance and conformity

Which products are covered by the CPR 2024?

The regulation covers construction products, including key parts of products, parts or materials to be used for products, and used construction products.

Construction products are products that are intended to be permanently incorporated into construction works (i.e. like a house or a commercial building) or their parts. Here we provide some examples:

• Doors
• Windows
• Sanitary appliances
• Construction adhesives
• Floorings

That said, the CPR also covers products like fire alarm systems that may not be generally thought of as construction products.

From when does the CPR 2024 apply?

The CPR 2024 applies from 8 January 2026. However, we understand that the requirements of the Construction Products Regulation 2011 (CPR 2011) continue to apply for construction products that are subject to harmonised standards published under CPR 2011, for which no standards exist under CPR 2024.

Let’s assume, for example, that there is a product (e.g. doors) for which there are harmonised standards published under the CPR 2011 and no such standards exist under the CPR 2024. In this case, the requirements set by the CPR 2011 will continue to apply until a standard for the same product is harmonised under the CPR 2024.

You can find more information about this topic in Article 95 – Derogations and transitional provisions of the CPR 2024.

Harmonised standards

Harmonised standards can be used to comply with the performance and safety requirements set by the Construction Products Regulation 2024, when such standards exist for your product. Harmonised standards under various EU regulations can be found on the European Commission or on the CEN-CENELEC website.

According to Article 5, if there are harmonised standards that cover your construction product, you must apply them if the standard is made mandatory by an implementing act. Implementing acts under EU regulations can be identified through the EU Commission’s register of delegated and implementing acts.

However, where such an act does not exist, you could still apply relevant harmonised standards under the regulation to ensure that your product meets the requirements set by the regulation.

Note that if your construction products are covered by harmonised standards, you must create a Declaration of Performance and Conformity (which is the title of a single document) and CE mark your product.

Having said that, we could not find a list of harmonised standards published under the new regulation. As mentioned in the previous section, if there are standards that are harmonised under the CPR 2011 for your product, and no such standards exist under the CPR 2024, you must refer to the requirements of the CPR 2011 and not of the CPR 2024.

Here are some examples of construction products that are covered by harmonised standards under the CPR 2011:

• Fire detection and fire alarm systems
• Mirrors from silver-coated float glass for internal use
• Modular tiles
• Slabs for floors and stairs
• Anti-flooding devices for buildings

You can find more examples of construction products covered by harmonised standards in this guide.

European technical assessment

The European technical assessment (ETA) refers to a documented performance assessment of a product. The assessment is based on the information from European assessment documents. Having your product meet the specifications of the ETA is an alternate method to complying with the requirements of the regulation.

If a harmonised standard does not cover your product, you can request a technical assessment body to issue an ETA. This is done voluntarily.

The advantage of taking the ETA route is that your product can still be CE marked. Generally speaking, here are the key steps to receiving an ETA:

a. Find a technical assessment body (TAB)

b. Request the issuance of an ETA

c. Sign an agreement of commercial secrecy and confidentiality with the TAB

d. Submit a technical file (which includes details of the factory production control that you intend to apply)

Assessment and verification systems

The assessment and verification system (AVS) refers to a system intended to assess and verify the declared performance of a construction product. Annex IX lists the different assessment and verification systems, and their requirements, such as testing, production control, and more.

The appropriate assessment and verification system for your product can be found in harmonised standards or in European assessment documents used as a basis for the European technical assessment.

Most of the systems listed in Annex IX require a notified body (excluding System 4 – Manufacturer’s self-verification and self-certification).

Documentation

Declaration of performance and conformity

Manufacturers of products covered by harmonised standards must issue a declaration of performance and conformity according to the requirements in Articles 13, 15, and 16, upon ensuring that the product complies with the relevant requirements. By doing so, the manufacturer establishes that they are responsible for the product’s conformity with the requirements of the regulation.

Even where no harmonised standards exist, the manufacturer must issue the declaration if a European technical assessment has been applied.

Here are the items required by the declaration, according to Annex V:

• Name of the Manufacturer
• Declaration Code
• Version Number
• Date of that version
• Product description
• Information on permalinks or data carriers (unless the information is available in the digital product passport)
• Information about the manufacturer
• Information about the authorised representative (where applicable)
• Information on notified bodies (where applicable)
• Information on technical assessment bodies (where applicable)
• References to certificates or validation reports from notified bodies or technical assessment bodies
• Technical reference documents
• Declared performances and sustainability characteristics
• Applicable product requirements specified by harmonised technical specifications
• Declarations

Technical documentation

Technical documentation serves as the basis for drawing up the declaration of performance and conformity. Article 22(3) of the regulation requires manufacturers to create it regardless of whether the harmonised standard or the European technical assessment route is applied.

Here is a summary of the items that must be indicated in the technical documentation:

• The declared use
• Relevant elements to demonstrate performance and conformity
• Information on procedures ensuring that the products fulfil their declared performance and remain in conformity with the regulation
• The applicable system or systems set out in Annex IX
• Information on the application of simplified procedures applied (where relevant)
• Performance of environmental sustainability calculations

European assessment documents

The organisation of technical assessment bodies creates European assessment documents. These documents are the basis for issuing European technical assessments.

Where a harmonised standard does not cover your product, you can approach a technical assessment body for a European technical assessment that is issued based on an existing European assessment document.

Where there does not exist a relevant European assessment document for your product, a new one can be adopted. The requirements for adopting the European assessment documents are outlined in Article 31 of the regulations.

Here are some examples of items that must be present in the documents:

• Product description
• Intended use
• List of essential characteristics
• Predetermined environmental essential characteristics
• Methods and criteria for assessing the performance of the product or product category
• Technical details necessary for the implementation of the assessment and verification systems
• General product information, instructions for use and safety information
• Information on the declaration of performance and conformity

Register of complaints, of non-conforming products and product recalls

Manufacturers are required to ensure that the declared performance and conformity of their products remain valid according to Article 22(4) of the regulation. Among the various procedures that the regulation prescribes, it states that where necessary, the manufacturer should adopt a register of complaints, of non-conforming products, and product recalls.

This document requirement applies regardless of whether the harmonised standard or the European technical assessment route is applied.

Labelling requirements

CE marking

When harmonised standards apply, or a European technical assessment is created for the product, you must also CE mark your product upon drawing up the declaration of performance and conformity.

According to the regulation, the CE marking must be followed by information contained in Article 18:

• The last two digits of the year CE marking were first affixed
• Information about the manufacturer (e.g. name and address)
• Information about the authorised representative (when necessary)
• Product-type’s unique identification code
• Declaration code of the declaration of performance and conformity
• Notified body identification number
• A data carrier connected to the digital product passport (if applicable)

Traceability information

Construction products must bear certain information that allows others to trace the product back to certain companies involved in its production.

According to Article 22(5), the manufacturer is required to provide the following traceability information:

• Manufacturer-specific unique identification code of the product type
• A batch or serial number

As mentioned in the CE marking section above, some traceability information must follow the CE marking (e.g. manufacturer’s name and address or identifying mark).

‘Only for professional use’ label

If the construction product requires expertise to use it, Article 22(5) of the regulation requires that the statement ‘only for professional use’ must be displayed on the label.

If a construction product does not bear the statement on its label, the product is seen as intended for non-professionals.

Environmental sustainability labelling requirements

This regulation empowers the European Commission to introduce new environmental sustainability labelling requirements through delegated acts. The acts must specify the particular product families and product categories to which the requirements apply.

Other markings and performance claims

Article 19 of the regulation specifies conditions for certain markings (other than CE marking) to appear on the construction product. For example, other markings should not obscure the CE marking.

Instructions

Construction products must be accompanied by the following information when harmonised standards or a European technical assessment exist:

a. General product information (e.g. product description, traceability information)

b. Instructions for use and safety information (e.g. Training and other requirements necessary to be fulfilled for safe use)

Further details of what needs to be provided are contained in Annex IV of the regulation.

Digital product passport

This regulation requires certain information to be featured in a digital product passport, and that is to be accessed through a data carrier. Article 76 of the regulation contains a list of information that the digital product passport must include.

The digital passport should contain the following information:

• The declaration of performance and conformity
• General product information
• Instructions for use and safety information
• Technical documentation
• Label in accordance with Article 22(9)
• Unique identifiers
• Documentation required by other EU regulations
• Data carriers, which must follow the CE marking (Article 18(g))

FAQ

When does the new EU construction product regulation 2024 apply?

This regulation applies from 8 January 2026. However, there are a number of articles and annexes that apply to future dates, which are listed in Article 96 of the regulation.

Does the CPR 2024 repeal the CPR 2011?

Yes, the Construction Products Regulation 2011 is repealed from 8 January 2026. However, there are several articles and annexes of the CPR 2011 that remain in effect till 8 January 2040.

A list of the articles and annexes that remain in effect until the later date is provided in Article 94.

Additionally, if a harmonised standard published under the CPR 2011 applies to your product, you must refer to the requirements of the CPR 2011, as long as your product is not covered by harmonised standards under the CPR 2024 as well.

Which products are exempted from the CPR 2024?

The regulation in Article 2 exempts the following products:

• Lifts subject to Directive 2014/33/EU
• Escalators or their components

The regulation also permits member states to exempt certain products. Such products should not bear CE marking.

Is CE marking required for construction products?

The CE marking is only required for construction products for which a declaration of performance and conformity has been created.

In turn, the declaration of performance and conformity is required for products for which harmonised standards exist or an ETA has been created.

Is CE marking optional for some construction products?

If the construction product requires a declaration of performance and conformity to be created, the construction product must bear the CE marking.

Note that there are construction products for which a declaration of performance and conformity does not need to be created. For example, products that are not covered by a harmonised standard do not require the declaration and the CE marking (unless an ETA is created for the product). However, such a product must still comply with the other requirements of the regulation.

Are CE-marked construction products accepted in the UK?

Yes, CE-marked construction products are accepted. The guidance page “Construction Products Regulation in Great Britain” was published on GOV.UK states that the CE mark will continue to be available when placing construction products on the market across the UK.

Is a digital product passport required for construction products?

Yes, a digital product passport is required for construction products. We found that Article 18(2)(g) mentions that the data carrier connected to the digital passport must follow the CE marking.

As such, it is possible that the digital passport is only required when the product is CE marked. However, in the regulation, we could not find an explicit statement confirming that the digital product passport is only required where CE marking is present.

Are user instructions required for construction products?

General product information, instructions for use, and safety information must be provided for those products that are covered by a harmonised standard or a European technical assessment.

What can I do if there are no harmonised standards for our construction products?

In this case, you must assess whether harmonised standards under CPR 2011 apply to your product. If it does, you should refer to the requirements of the CPR 2011.

If harmonised standards do not exist under both the CPR 2024 and CPR 2011, you can contact a TAB and ask them to issue a European technical assessment for your product.

By working with a technical assessment body, you can have your product’s performance assessed, draw up the declaration of performance and conformity, and ultimately affix the CE marking.

Are notified bodies required for construction products?

This depends on the assessment and verification system that you have applied to the construction product. As explained in Article 10, harmonised standards and European assessment documents contain information regarding which assessment and verification system is required for a specific construction product.

In turn, the assessment and verification systems listed in Annex IX explain whether you need a notified body in order to complete the assessment.

All systems, excluding System 4, list tasks for notified bodies. System 4 claims that there is no task for the notified body, even though notified bodies are mentioned.

How does the CPR 2024 differ from the CPR 2011?

In the table below, we compare some of the important requirements contained in the Construction Products Regulation 2024 and the Construction Products Regulation 2011.

	CPR 2024	CPR 2011
Documentation requirements	Declaration of performance and conformity Technical documentation Register of complaints, of non-conforming products and product recalls Record keeping requirements	Declaration of performance Technical documentation Appropriate technical documentation Specific technical documentation Register of complaints, of non-conforming products and of product recalls
Labelling requirements	CE marking Data carrier connecting to digital product passport Traceability information Environmental sustainability labelling requirements ‘Only for professional use’ label	CE marking Traceability information
Digital product passport	Required	Not required
European technical assessment	Voluntary if no harmonised standards exist	Voluntary if no harmonised standards exist
Instructions	General product information, instructions for use and safety information	Instructions and safety information