On 18 December 2024, the Official Journal of the EU released the revised Construction Products Regulation, Regulation 3110/2024. This revision is part of a broader package of initiatives announced by the European Commission already in 2022 and it updates the existing legislation from 2011. These measures are part of the European Green Deal and the Circular Economy Action Plan.
Construction products in the EU: road to new CPR
Given the European Union’s goals to achieve climate neutrality and advance a circular economy, enhancing building efficiency and the sustainability of construction products has become a central focus for European regulators. Construction products must be designed and manufactured with greater durability, recyclability, repairability, and ease of re-manufacture. Consequently, the Construction Products Regulation needed to be updated accordingly.
Timeline to application of new Construction Products rules
The new EU Regulation enters into force on 7 January 2025. It applies from 8 January 2026, with the exception of the below provisions that apply from 7 January 2025:
- Article 1 – Subject matter and objectives
- Article 2 – Scope
- Article 3 – Definitions: the new Regulation includes an updated definition of “construction product”
- Article 4 – Working plan and preparatory phase for the development of harmonised technical specifications (actions to be done by the Commission, not by economic operators)
- Article 5 (1 to 7) – Harmonised standards laying down essential characteristics dealing with performance
- Article 7(1) – Product requirements and harmonised standards conferring a presumption of conformity (right of Commission to implement delegated acts to supplement the regulation)
- Article 9 – General product information, instructions for use, and safety information, which “shall be provided in relation to construction products covered by a harmonised technical specification or a European technical assessment.”
- Article 10 – Assessment and verification systems: “The assessment and verification of a product’s performance as per the applicable HS or European Assessment Document shall be carried out.”
- Article 12(1, first sub-paragraph) – Relationship with other Union law (Commission is empowered to adopt delegated acts to avoid duplicate product’s assessments)
- Article 16(3) – Supply of the declaration of performance and conformity
- Article 37(4) – European technical assessment (right of Commission to implement delegated acts)
- Article 63 – Complaint portal (action to be done by the Commission)
- Article 89 – Delegated acts
- Article 90 – Committee procedure
- ANNEX I – Basic requirements for construction works (relevant for the preparation of standardisation requests)
- ANNEX II – Predetermined environmental essential characteristics
- ANNEX III – Product requirements (what harmonised specifications should cover)
- ANNEX IV – General product information, instructions for use and safety information
- ANNEX VII – List of product families
- ANNEX IX – Assessment and verification systems (AVS)
- ANNEX X Essential characteristics of a horizontal nature
Lastly, Article 92 on penalties applies from 8 January 2027.
Compliance of construction products in Europe
Whether from a third country or not, construction products placed on the markets in the EU and the UK must comply with the relevant Regulations. Do you have questions on regulations of construction products? Send us an email at prodlaw@obelis.net or contact us here for Obelis authorised representative services.
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