EU Construction Products Regulation 2024/3110 (CPR recast)

What is it?

Regulation (EU) 2024/3110 fully replaces the previous Construction Products Regulation 305/2011. It was published in the Official Journal of the EU and entered into force at the start of 2025. The substantive obligations do not all land at once. They are activated per product category through delegated acts, each time the revised harmonised standard (hEN) for that product family is published. As of May 2026 no new hEN has appeared, but the hard switch is set for 2027.

The core of the regulation stays structurally familiar: harmonised conditions for placing construction products on the EU single market, with CE marking as the condition for market access. What is new is the requirement profile behind it. For the first time an environmental declaration is mandatory through the Declaration of Performance and Conformity (DoPC). It merges the declaration of performance with environmental indicators and replaces the separate EPD in the long run without abolishing it: EPD data feeds straight into the DoPC. Also new is that the CPR creates the legal basis for the Digital Product Passport (DPP) for construction products for the first time. It covers the 36 product families defined in Annex VII, from load-bearing elements through insulation and fire protection to windows and doors.

Who is affected?

The regulation addresses manufacturers, importers and distributors of construction products placed on the EU market. Distributors also carry stronger duties of care and cooperation when passing on product information and working with market surveillance authorities. The regulation does provide relief for SMEs, but that relief mainly concerns administrative requirements. The substantive data obligations apply largely equally and are highly relevant for mid-sized companies too.

Application is strictly product-category specific: each of the 36 product families is activated through its own delegated act. Manufacturers typically learn 18 to 24 months before mandatory application what exactly their category has to deliver. The Commission’s working programme sets the order: precast concrete and steel first, then structural steel and reinforcing steel, followed by windows and doors. Further construction products come after that. Anyone producing in those categories has the shortest run-up and at the same time the largest change to their own data obligations, because those products carry a high global warming potential share in the building-level LCA.

Which deadline applies?

The CPR 2024/3110 applies in stages.

• 8 January 2026: the CPR applies. The obligation to declare global warming potential is legally in force, but takes effect only once the revised hEN for the relevant product family is published. As of May 2026 no new hEN has been published.
• 8 January 2027: national market surveillance authorities can impose penalties.
• 2026 to 2028: the Commission’s working plan order, cements and steel first, then windows, doors and further construction products. As soon as the hEN for a category is revised, the GWP obligation applies immediately for that category.
• 2030: further environmental indicators under Annex II e to m (acidification, eutrophication, water use and others).
• 2032: the complete life cycle set under Annex II a to s.

The exact cut-off dates per product category are only fixed once the relevant delegated act is published. Manufacturers should actively watch for the publication covering their own category. The typical lead time between the legal act and the obligation is rarely enough to start building EPD data and DPP structures at that point.

What has to be done?

From a manufacturer’s perspective the preparation breaks into five workstreams.

• Portfolio mapping: compare your own product portfolio against the coming HTS categories and prioritise by the working plan order.
• A life cycle data basis to EN 15804+A2: build it modularly per product family, with a background data set that can be followed and documented assumptions. The GWP values from the EPDs feed directly into the DoPC.
• Prepare DoPC processes: bring the declaration of performance and the environmental indicators together, both in the data and in the sign-off. The DoPC is the market access documentation, and without it a product cannot be placed on the market.
• Digital Product Passport: define the data model, ERP and PIM connection, unique product identifiers and data carriers (QR code, NFC, data matrix). The DPP is primarily a data and IT project, not a classic compliance project. The data flow runs LCA → EPD → DPP, sequentially rather than in parallel, which means existing EPD and LCA data is used as structured input. The DPP is maintained across the whole product life rather than published once. You also have to distinguish which data should be public, which should travel only along the value chain and which should be available to authorities alone.
• Verification route and duties of care: establish per product category which requirements can be covered by self-declaration and which need third-party verification. For many product families third-party verification becomes mandatory. In parallel, set up supplier tracing, deviation management and internal documentation routes. The extended manufacturer duties of care call for continuous maintenance, not a one-off exercise.

What happens if you do not?

Construction products without a CPR-compliant DoPC may no longer be placed on the EU market from the relevant category-specific cut-off date. Market surveillance authorities can order withdrawals, impose fines and issue sales bans. The level of penalty follows the national implementing law of each member state and can be severe for repeat cases. In public tenders CPR conformity is already checked at the award stage, and missing or incomplete data leads to exclusion. On top of that come civil liability risks towards building owners and lead planners if conformity defects are only discovered after installation.

In market terms, what often matters more than the formal sanction is that public sector clients and sustainability-minded building owners frequently ask for DPP data and life cycle values well before the regulatory deadline. Failing to supply them drops you out of specifications even in periods when the regulatory obligation itself is not yet active. In certification-oriented segments (BNB, QNG, DGNB) the effect is immediate.