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
- Main provisions apply: 8 January 2026 (staged)
- DPP mandatory: 18 months after the entry into force of the delegated act under Article 75(1) (Articles 22(7) and 80(1)). As of 11 October 2026 that delegated act has not been adopted, so no CPR DPP obligation applies yet and no date can be fixed. The Commission's indicative DPP timeline points to Q2 2027 for the act
- Assessment and verification systems: Delegated Regulation (EU) 2026/1310, in force since 17 September 2026
DPP requirements
Under Article 76(2), each construction product DPP must contain:
- The declaration of performance and conformity (DoPC). It includes the product's declared life-cycle environmental sustainability performance, starting with the climate change indicators from 8 January 2026 (Article 15)
- General product information, instructions for use and safety information
- The technical documentation
- The product label
- Unique identifiers
- Documentation required under other Union law that applies to the product
- Data carriers of key parts that have their own DPP
- Data retention: the economic operator keeps the DPP available for at least 10 years, and the system stays accessible for 25 years after the last product of the type is placed on the market (Article 75(2))
Priority product categories
Product families will be brought into the DPP obligation through delegated acts. Concrete, steel and insulation materials are often cited as early candidates, but no adopted act yet confirms the order.
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
- The EU DPP registry set up under ESPR already covers construction products within the scope of Regulation (EU) 2024/3110 (Implementing Regulation (EU) 2026/1778, recital 2)
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.
Assessment and verification systems (AVCP)
Commission Delegated Regulation (EU) 2026/1310 sets the systems for assessment and verification of constancy of performance that apply to construction product families and categories, under Article 10(2) of the CPR. It was adopted on 11 June 2026, published in the Official Journal on 28 August 2026, and has been in force since 17 September 2026. It has no separate application date.
- Annex I: the system for "deemed-to-satisfy" characteristics (Art 1)
- Annex II: systems for horizontal essential characteristics grouped under Annex X of the CPR (Art 2)
- Annex III: systems per product category (Art 3)
Manufacturers should check the Annex III entry for their product category to confirm which system, and therefore which level of notified-body involvement, applies.
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 |
| 17 September 2026 | Delegated Regulation (EU) 2026/1310 (AVCP systems) enters into force |
| Q2 2027 (indicative) | Delegated act under Article 75(1) setting up the construction DPP; not yet adopted, date from the Commission's indicative DPP timeline |
| 18 months after that delegated act enters into force | DPP mandatory for the products it covers |
| 9 January 2030 | Group 2 DoPC coverage |
| 9 January 2032 | Group 3 DoPC coverage |
| 8 January 2040 | Old CPR 305/2011 completely repealed |