The construction products industry is getting ready for changes as the application date of the new Regulation is getting closer. Regulation (EU) 2024/3110 on Construction Products (“CPR 2024”) will start to apply on 8 January 2026, with some exceptions. The new CPR repeals Regulation (EU) No 305/2011 (“CPR 2011”).
What main changes are to be expected?
The CPR 2024 aims to improve many aspects of the previous regulatory framework. Some of the key topics are streamlining market access, promoting sustainability and circular economy, and strengthening the Union market.
Streamlining market access
The revised Regulation presents the concept of harmonised zone, formed by the CPR 2024 together with the harmonised technical specifications adopted in accordance with it. Its purpose is to avoid trade barriers created by different applications of the Regulation in each EU Member State. Compared to CPR 2011, this should improve regulatory certainty and decrease the administrative burden on the economic operators.
Clarifications of key terms are now present in the Regulation (such as definition of “permanent”, crucial concept in the Regulation). Also the scope of the Regulation is extended to encompass new technologies such as 3D printing.
The system of creation of harmonised specifications for construction products is improved, with the European Commission being able to compensate insufficiencies in standard development by adopting harmonised technical specifications via implementing acts.
Sustainability and circular economy in construction products compliance
The industry may expect additional requirements covering the product sustainability. For instance, these include drafting the declaration of environmental sustainability performance, and specific labelling requirements for certain product families or categories.
Manufacturers will need to carefully assess the environmental sustainability performance of their products in line with the newly introduced Assessment and Verification System 3+ to address their environmental impact.
Another newly introduced element is the Digital Product Passport (DPP) for construction products. This is aligned with the Eco Design for Sustainable Products Regulation (EU) 2024/1781, and will become applicable later on. Once the delegated act of CPR 2024 is published and enters in force, the manufacturers will have 18 months to make DPP available.
To further promote circular economy, the CPR 2024 covers not only new, but also used and remanufactured products. This may impact importers and distributors of such products. In such cases, they should evaluate whether they do not become manufacturer under the CPR 2024 by virtue of article 26.
Strengthening the market
The CPR 2024 aims to enhance the product’s compliance and safety on the EU market, by stricter market surveillance, more coordination among the national authorities and enhanced responsibilities of the economic operators.
An economic operator is any natural or legal person subject to CPR 2024 in relation to the manufacturing or remanufacturing of products, including products to be reused, or to making those products available on the market. Obligations are set not only for manufacturers, importers, and distributors but also for fulfilment service providers.
To ensure that an EU contact point is always available for the authorities, manufacturers from third countries are newly obliged to appoint a single Authorised Representative. This obligation applies regardless of whether they sell via importer or distance sales. In case of the latter, the online marketplaces and economic operators have dedicated obligations relating to selling online. Finally, a new complaint portal is available for anyone (including consumers) to submit complaints or report possible non-compliance to the European Commission.
Do you have questions on compliance with the EU Constructions Products Regulation? Contact PRODlaw Team here or at prodlaw@obelis.net. We act as your authorised representative on the Union market.
References:
EUR-Lex (2024). Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2024 laying down harmonised rules for the marketing of construction products and repealing Regulation (EU) No 305/2011. Retrieved on 14/10/2025.
Construction Products Europe AISBL (2025). Navigating the Construction Products Regulation: Guide for Manufacturers. Retrieved on 24/04/2025.
Federal Public Service Economy (2025). Construction Products Regulation (EU) 2024/3110. Retrieved on 13/102025.
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