EU Construction Products Regulation (CPR) 2024/3110: implementation timetable has begun
As of 8 January 2026, mandatory environmental reporting and digital documentation come into effect for product groups covered by updated harmonised standards; priority is given to precast concrete, steel structure and window-door groups.
The new Construction Products Regulation replaces the existing CPR, and while retaining the declaration of performance (DoP) system, it expands the areas of digital product passport, environmental sustainability and market surveillance.
Implementation is staged: as harmonised technical specifications are renewed, product groups move to the new regime. This is why one manufacturer's product may come into scope before or after another's.
As long as the declared essential characteristics and assessment system do not change, the existing DoP logic is preserved; what changes is the information the declaration carries and how it is presented.
A calendar with three dates
The new Construction Products Regulation (EU) 2024/3110 was published on 18 December 2024 and entered into force on 7 January 2025. The first articles to take effect were the general provisions on developing new standards.
Most of the provisions began to apply on 8 January 2026; on the same date, certain articles of (EU) 305/2011 were repealed. The rules on penalties apply from 8 January 2027.
This staged structure means the two regulations will coexist for a while. Which framework a material is subject to depends on whether a new harmonised standard has been published for that material.
The engine of the transition: harmonised standards
The new regulation does not replace the old one overnight; the transfer proceeds in stages according to the publication of new harmonised standards. When a new standard is published for a product group, that group moves to the new framework.
For a manufacturer this means the timetable must be followed through its own product group's standard rather than through general announcements. The information that "the CPR has changed" does not say what to do; which standard applies from which date does.
Environmental data enters the declaration of performance
Under the new framework, declarations of performance and conformity also carry environmental data. The first requirements on climate impact apply from 8 January 2026; additional environmental requirements come into effect on 9 January 2030 and 2032.
This requires life-cycle data behind the declaration. Producing the data is not a one-time calculation: when raw material composition, energy source or production location changes, the declaration must also be updated.
In practice, the most time-consuming part is the data collection chain. A product-level environmental declaration cannot be built without component data from the supplier; this is why preparation for the 2030 requirements starts with supplier contracts in 2026.
Why the construction products regime differs from others
In the EU's other product legislation, the mark declares that the product is SAFE. In construction products, however, the mark shows that the product's PERFORMANCE has been declared — not that it is safe. This distinction arises from a legal necessity.
The reason is the limit of authority: the safety of a building is a matter of national construction legislation, and member states have not delegated this authority. Each country decides for itself what fire resistance a wall must have.
The arrangement therefore says "measure and declare performance in a common language" and leaves the acceptance threshold to national legislation. A product carrying a declaration of performance cannot be used in a destination country if it does not meet that country's threshold — and that is not a defect of the mark but the design of the arrangement.
Why factory production control is a separate obligation
Construction products are mass-produced and vary between batches: fluctuation in aggregate, cement, polymer or metal raw material directly affects the product's performance. This is why a single type test is not considered sufficient.
Factory production control is the system that shows production is continuously monitored and declared performance is maintained: the sampling plan, control frequency, record-keeping and actions to take in case of deviation are established in writing.
As the assessment level rises, this control is audited by a notified body; at the highest level, the product type is also certified by the body. A stricter level applies to critical characteristics such as fire performance.
What to look at during the transition period
As the construction products regime is renewed, the most frequently asked question is: what will happen to existing declarations of performance and certificates? The typical approach is a staged transition: existing technical specifications remain in force for a while, and product groups are moved to the new regime as new specifications are published.
This is why the schedule is tracked by product group; there is no single date for all products. What matters is the stage the specification for one's own product group is at.
Controllable items are prioritised: maturing factory production control records, completing the declaration of performance in terms of product characteristics, and listing the national thresholds of target countries. These generate value independently of the schedule.
What to do?
- 1Track the status of your product group's harmonised specification.
- 2Review your DoP and labelling information according to the new regime.
- 3Set up your environmental data collection process now.
This article is for informational purposes and does not constitute legal advice. How a regulation applies to your product depends on the product's technical characteristics and target market; the exact scope can only be determined by examining the product.