What is the Construction Products Regulation?

What does the CPR regulate?

The Construction Products Regulation governs the placing of construction products on the European single market. It requires manufacturers to draw up a DoP (Declaration of Performance) declaring a product's essential characteristics against harmonised technical specifications, and to affix CE marking before placing the product on the market. CE marking under the CPR signifies conformity with the declared performance — it is not a quality mark.

The regulation is built around seven BWRs (Basic Requirements for Construction Works):

• BWR1 — Mechanical resistance and stability
• BWR2 — Safety in case of fire
• BWR3 — Hygiene, health, and the environment
• BWR4 — Safety and accessibility in use
• BWR5 — Protection against noise
• BWR6 — Energy economy and heat retention
• BWR7 — Sustainable use of natural resources

CPR 2024/3110 is a full recast of the original CPR 305/2011, modernising the framework to address sustainability, digitalisation, and the shortcomings identified in the standardisation system over the past decade. BWR7 — sustainable use of natural resources — is significantly strengthened in the recast, reflecting the EU's broader sustainability ambitions.

What are harmonised standards and European Assessment Documents?

There are two routes to CE marking under the CPR. The first is through harmonised European standards (hENs), developed by CEN/CENELEC at the request of the European Commission and cited in the Official Journal of the EU. Over 440 hENs are currently in force across the 37 product families, covering the majority of construction products on the market.

The second route is through European Assessment Documents (EADs), developed by EOTA (the European Organisation for Technical Assessment) for innovative products or products not fully covered by harmonised standards. Around 250 EADs are currently available. A manufacturer obtains a European Technical Assessment (ETA) based on the relevant EAD, which then serves as the basis for CE marking.

The hEN route covers the vast majority of products; the EAD route enables market access for innovative or niche products. Under the new CPR 2024/3110, both routes lead to DPP requirements once the relevant harmonised technical specifications are issued under the new regulation.

What are the 37 product families under the CPR?

The CPR covers 37 product families listed in Annex IV of the regulation. These range from foundational materials like cement and concrete to specialised products like structural bearings, geotextiles, and fire-stopping products. Each family has its own set of harmonised European standards, assessment methods, and AVCP systems.

The 37 families include, among others:

• Cement, lime, and building plasters
• Precast concrete products and concrete reinforcing and prestressing steel
• Structural metallic products and ancillaries
• Masonry and related products
• Thermal insulation products
• Roofing, cladding, and waterproofing membranes
• Doors, windows, shutters, and gates
• Aggregates and natural stone
• Pipes, tanks, and ancillaries for water and wastewater
• Chimneys, flues, and specific combustion products
• Geotextiles, geomembranes, and related products
• Road construction products and road equipment
• Structural timber and wood-based products
• Fire-stopping, fire-protective, and fire-retardant products
• Fixed firefighting equipment and fire detection and alarm products
• Power, control, and communication cables

Each product family will transition to new harmonised technical specifications under CPR 2024/3110 on a rolling basis per the Commission's Working Plan. For a full interactive overview of all 37 families, including their harmonised standards, AVCP systems, and DPP timelines, see our in-depth CPR blog analysis.

What is AVCP and how does it work?

AVCP (Assessment and Verification of Constancy of Performance) defines how product conformity is assessed under the CPR. The AVCP system assigned to a product determines the split of responsibilities between the manufacturer and an independent Notified Body.

There are five systems, from highest to lowest level of third-party involvement:

• System 1+ — The highest level. A Notified Body certifies the product itself and the manufacturer's factory production control, performs continuous surveillance including audit testing of product samples. Used for products with the most critical safety implications, such as structural bearings and certain fire-protection products.
• System 1 — Similar to 1+, but without continuous audit testing of product samples taken at the factory or elsewhere.
• System 2+ — The Notified Body certifies the factory production control system (initial inspection and continuing surveillance), but does not certify the product itself. The manufacturer performs type testing. This is the most common system, used for products such as cement, concrete, aggregates, and insulation.
• System 3 — The Notified Body performs initial type testing only. The manufacturer handles all ongoing factory production control. Used for certain products like internal wall and ceiling finishes.
• System 4 — The lowest level. The manufacturer performs all tasks — type testing and factory production control — with no Notified Body involvement. Used for products with lower risk implications.

The AVCP system is specified per product family and per characteristic. In some cases, a single product may have different AVCP levels for different characteristics — for example, chimney products are System 2+ for general characteristics but System 1 or System 3 for reaction-to-fire performance.

How does the CPR relate to Digital Product Passports?

Chapter X (Articles 75–80) of CPR 2024/3110 introduces a full DPP framework for construction products. This is separate from but complementary to the ESPR DPP framework — the CPR establishes its own product-specific digital information requirements.

DPPs under the CPR will carry the DoP in digital form, plus additional product data covering environmental performance, sustainability characteristics, and lifecycle information. The detailed DPP requirements and data fields will be established via a delegated act that has not yet been adopted.

Critically, DPP obligations apply only to products covered by new harmonised technical specifications issued under CPR 2024/3110. Products still operating under existing hENs from the old CPR 305/2011 are not yet subject to DPP requirements. Products migrate on a rolling basis as the Commission's Working Plan progresses and new specifications are adopted.

Notably, products using the EAD/ETA route may face DPP requirements before products on the hEN route, as the EAD framework is being updated more rapidly. For more on how DPPs work across all EU regulations, see our guide on what a Digital Product Passport is.

When does the new CPR take effect?

CPR 2024/3110 was published in the Official Journal on 18 December 2024 and entered into force on 7 January 2025. However, most provisions apply from 8 January 2028, after a three-year transition period designed to give industry, Notified Bodies, and national authorities time to prepare.

Key dates:

• 18 December 2024 — Published in the Official Journal of the EU
• 7 January 2025 — Entry into force
• 8 January 2028 — Most provisions begin to apply (three-year transition)
• Timeline not yet confirmed — DPP delegated act adoption and application dates

The old CPR 305/2011 continues to apply in parallel until products are covered by new harmonised technical specifications under the recast regulation. This means the two regimes will coexist for a considerable period, with products migrating family by family. Manufacturers should monitor the Commission's Working Plan for their product families' transition schedules.

What changed from the old CPR to the new CPR?

CPR 2024/3110 is a comprehensive recast, not a minor amendment. It addresses the systemic issues that plagued the old CPR 305/2011 — particularly the stalled standardisation process — while adding new dimensions around sustainability and digitalisation.

The key changes include:

• Digital Declaration of Performance — The mandatory DoP goes digital, replacing paper-based declarations with structured digital data
• Digital Product Passport framework — Chapter X introduces a full DPP framework for construction products, carrying the DoP and additional product data
• Sustainability requirements strengthened — BWR7 (sustainable use of natural resources) is substantially expanded, enabling environmental sustainability declarations alongside performance declarations
• Standardisation system reformed — The Commission gains new powers to request standards directly and to address the citation backlog that stalled harmonisation under the old CPR
• Market surveillance enhanced — Stronger enforcement mechanisms, aligned with the EU Market Surveillance Regulation (2019/1020)
• EAD process reformed — The process for developing European Assessment Documents is streamlined and given clearer legal standing
• Economic operator obligations expanded — Importers and distributors face more explicit responsibilities for ensuring product compliance, including traceability obligations

For organisations already complying with CPR 305/2011, the transition to the recast will require updates to documentation processes, data management systems, and supply chain data flows — particularly in preparation for DPP requirements.

How can Regen Studio help with CPR compliance?

Regen Studio is an independent advisory firm — we do not sell DPP software, build platforms, or take commissions from technology providers. Our advice is shaped by your needs, not by a product we need to sell. We help construction product manufacturers, importers, and industry associations navigate the new CPR requirements.

Our services include:

• CPR transition readiness assessments — evaluate your current compliance position under CPR 305/2011 and map the path to CPR 2024/3110
• DPP strategy for construction products — prepare data architecture, systems, and processes for digital Declarations of Performance and product passports
• Product family analysis — understand the specific harmonised standards, AVCP requirements, and transition timelines for your product families
• Supply chain data mapping — identify what data your supply chain needs to contribute and design collection processes
• Vendor-neutral technology selection — evaluate digital DoP and DPP platforms without conflicts of interest

Explore our in-depth analysis of all 37 product families and their DPP outlook, try our CPR DPP Tracker demo, or learn more about our innovation services and Digital Product Passport advisory.