CPR — Construction Products Regulation
Mandatory Digital Product Passports for construction products. 10-year data retention, performance declarations, and environmental sustainability data.
Overview
The revised Construction Products Regulation (CPR) — Regulation (EU) 2024/3110 — introduces mandatory Digital Product Passports for construction products, replacing Regulation (EU) 305/2011.
Legal basis
- Adopted: November 2024
- Entered into force: 7 January 2025
- DPP mandatory (priority products): ~2027 (18 months after digital infrastructure established)
- Full coverage target: 2032
DPP requirements
Each construction product DPP must contain:
- Unique product identification (GS1 GTIN recommended)
- Declaration of Performance (DoP) or Declaration of Conformity (DoC)
- Technical specifications (strength, fire resistance, thermal performance)
- Environmental sustainability data (recycling rates, durability, lifecycle data)
- Carbon footprint and Environmental Product Declaration (EPD) data
- Recyclability and end-of-life information
- Safety data and installation instructions
- CE marking references
- Data retention: 10 years minimum
Priority product categories
DPPs first mandatory for:
- Concrete
- Steel
- Insulation materials
- Additional categories via delegated acts
Interoperability with ESPR
The CPR DPP and ESPR DPP are being developed with interoperability in mind:
- Where a construction product is also subject to ESPR delegated acts, data fields are harmonised
- Same GS1 Digital Link infrastructure
- Separate registries but designed for cross-system queries
Who is affected
- Manufacturers of construction products covered by harmonised technical specifications — including concrete, steel, insulation materials, glass, ceramic tiles, roofing products, timber products, and all other products with harmonised European standards
- Importers placing non-EU construction products on the EU market under their own name or trademark
- Distributors who modify product characteristics or rebrand products
- Designers and contractors who specify or use products with Declaration of Performance and Conformity (DoPC) requirements
- CE marking obligations affect any economic operator responsible for demonstrating conformity
Penalties and enforcement
Penalty provisions are established in Article 92 of Regulation (EU) 2024/3110, which enters into force on 8 January 2027. Member States must establish effective, proportionate, and dissuasive penalties for violations including:
- Placing CE-marked products on the market without a valid Declaration of Performance and Conformity
- Making false or misleading environmental sustainability declarations
- Failure to register DPP data or maintain required data accessibility
The penalty focus is on environmental performance declarations — carbon footprint claims, recyclability declarations, and lifecycle data included in CPR DPPs must be substantiated. Products with unsubstantiated environmental claims face withdrawal from market from 8 January 2027.
Performance classes
The CPR introduces a system of performance classes for essential characteristics, allowing manufacturers to declare performance using ranked grades rather than absolute values. This simplifies market surveillance and comparison:
- Classes are defined per harmonised technical specification for each characteristic (e.g., fire resistance: A1, A2, B, C, D, E, F)
- The DoPC must reference the applicable class for each declared characteristic
- Where a performance class is adopted, products must meet the minimum class required in each Member State's building regulations
Key dates
| Date | Milestone | |------|-----------| | 7 January 2025 | CPR 2024/3110 enters into force | | 8 January 2026 | Main provisions apply; Group 1 DoPC coverage begins | | 8 January 2027 | Article 92 penalty provisions enter into force; CE marking enforcement begins | | 2026/2027 | Digital infrastructure (DPP registry, APIs) operational | | 18 months after infrastructure | DPPs mandatory for priority products (concrete, steel, insulation) | | 9 January 2030 | Group 2 DoPC coverage | | 9 January 2032 | Group 3 DoPC coverage | | 2032 | Full DPP coverage target — all construction products | | 8 January 2040 | Old CPR 305/2011 completely repealed |