Background
This article is about the rules concerning placing construction products on the market in the United Kingdom. It has been written in light of the EU Construction Product Regulations 2024 (CPR 2024) being published. It also looks at the Ecodesign for Sustainable Products Regulation (ESPR 2024), which was published earlier in 2024 and shares similar sustainability and digitalisation objectives.
As many of the products manufactured in UK are sold into the EU market, the requirements to follow these Regulations will be relevant to UK manufacturers.
Finally, there are different rules for Northern Ireland. To view these, see Construction Products Regulation in Northern Ireland on the GOV.UK website.
Construction products in the UK
The UK Government has recently updated its Construction Products Regulation in Great Britain guidance. In February 2025, it was announced that the recognition of the CE Mark will continue beyond June 2025, with no formal end date currently specified by the UK Government. Therefore, the assessment of conformity with a relevant standard or assessment can be recognised UKCA or CE marking. In addition, the February update included the publication of a wide-ranging Construction Products Reform Green Paper that set out a consultation programme for reform of the construction product regime. The consultation is also set against the backdrop of the Morrell-Day Independent Review of the Construction Product Testing Regime, which followed the Grenfell tragedy. Several references are also made to the Code for Construction Product Information (CCPI), which aims to raise standards in construction product information and marketing, and to drive positive culture change in the manufacturing and supply sector in relation to product information and marketing.
The green paper consultation is seeking (until 21 May 2025) industry views on whether aligning with the new requirements being introduced through the CPR 2024 is the best way to meet UK objectives for reform. This would mean applying equivalent rules, to the relevant products, when placing products either on the UK market or placing UK products on the EU market.
Upcoming changes
If, as a manufacturer, you serve the EU market, then the changes are on their way. If, as a manufacturer, you only serve the UK market, then the green paper consultation will decide how much of CPR 2024 will be followed in the UK.
Some of the key changes for construction product manufacturers moving from CPR 2011 to CPR 2024 are listed below. These apply to products that fall under CPR – those covered by a harmonised Technical Specification (hTS) or a European Technical Assessment (ETA).
Product identification
Manufacturers shall ensure that there is a visible and legible unique identification code for their product types. This should ideally be on the product itself or, if not possible, on a fixed label, on the packaging or on an accompanying document.
While the CPR 2024 does not mandate the use of any specific system, such as GS1, the use of global identifiers, such as Global Trade Item Numbers (GTINs), is compatible with the Regulation’s goal of unique, interoperable product traceability. The use of these identifiers already has high adoption rates in retail, healthcare and food industries.
More information on GS1 can be found on the GS1 web page Understanding the CPR update and the role of the DPP. GS1 is a not-for-profit, international organization developing and maintaining its own standards for barcodes and the corresponding issue company prefixes.
Instructions for use and safety information
There are new requirements for manufacturers to provide improved safety information and instructions for use. These should be in the language determined by the country of use, and should cover transport, installation, maintenance, deconstruction and demolition.
Data carrier
A data carrier is to be included alongside the CE Mark. This would typically be a barcode, QR (quick-response) code or RFID (radio frequency identification), which can be read by a digital device to enable a user to discover the necessary information about that product. This data carrier acts as a pointer to the Digital Product Passport (DPP) but does not itself contain the full dataset.
Environmental sustainability
The declaration of the environmental sustainability of that product according to EN 15804 is a new requirement. The declaration must be based on EN 15804 and, where applicable, verified by an appropriate third-party organisation.
The most common method for manufacturers to quantifiably demonstrate the environmental impact of a product is through an Environmental Product Declaration (EPD). More information on EPDs can be found on the BRE web page Environmental Product Declaration - EN 15804.
Digital Product Passport (DPP)
The DPP initiative will apply to a much wider range of products than simply construction. In parallel to the initiative in construction, this is being progressed in textiles, batteries and electronic devices, amongst others. An understanding is now in place of what DPPs are, but the details of how they will work are currently at the consultation stage. This consultation is looking at data storage, management and potential certification schemes for service providers.
More details of the consultation stage can be found on the European Commission web page Digital product passport – rules for service providers.
It will be possible to go from the data carrier (for example the QR code) to an online location to view the product’s DPP. This will be a digital record that contains comprehensive information about the construction product and its use throughout its life cycle. In simple terms, the DPP complements the CE Mark by offering a digital and more comprehensive view of a product's compliance and life cycle data. The content of a DPP for construction products will include:
- The unique identification code.
- The Declaration of Performance (DoP) and Declaration of Conformity (DoC).
- Evidence that supports this declared performance.
- Instructions for use, and safety information.
- Specific labelling required by EU law, such as hazardous substances, energy efficiency or chemical safety.
- Data carriers to key parts, where applicable – such as the DPP for an integrated sensor.
For further information on DPPs, see the Construction Products Europe publication CPR Guide for Manufacturers: Navigating the Construction Products Regulation.
How NBS intends to support manufacturers and specifiers on NBS Source
It is no coincidence that the data structures and functionality within NBS Source reflect recent industry initiatives, such as the CCPI and DPPs. NBS is a member of several industry groups and committees, and is helping to contribute to initiatives that help make the industry better. Several examples are provided below that show how NBS is helping manufacturers get ready for DPPs.
Unique IDs
To demonstrate how NBS Source is dealing with globally unique IDs that are defined externally, the product FactoryClad Roll 40 from Knauf Insulation is shown in Figure 1.
When defining a product, or indeed variants of that product, NBS Source encourages the manufacturer to add both their internal stock keeping unit (SKU) code and also a GTIN/ European Article Number (EAN) code from the GS1 system. This single code, if used consistently, would be the connecting ID between multiple platforms, encompassing product information management, manufacturing, promotion, specification (such as NBS Chorus), project intelligence (such as Glenigan), customer relationship management (CRM), distribution channels and ultimately asset management. One ID can travel through the product’s life cycle.
Specification properties
When creating product clauses, NBS technical authors consider the appropriate clause information, including the relevant performance and product characteristics. This includes any relevant standards (national or harmonised) that apply to the product. This information forms the template used for the relevant manufacturer product information in NBS Source. Figures 2A and 2B illustrate this, showing both generic data and an overhead door closer from the manufacturer Allgood Ltd. The harmonised standard BS EN 1154 is cited, and values from the manufacturer’s DoP are positioned against the technical characteristics as defined in the standard.
Evidence of performance
Where manufacturers have third-party certification evidence that supports the DoP, this can also be hosted on NBS Source.
This is illustrated in Figures 3 and 4, which show a balustrade system from Delta Balustrades Ltd. The BSI Kitemark confirms the suitability of the particular system to the relevant British Standards. It should be noted that a traffic light system of indicators is used to give confidence to the specifier that the certification is still within its expiry date.
Instructions for use
Figure 5 an (access panel from The Access Panel Company Ltd) shows that all documentation about a product can also be accessed. Documentation for installation, operation, maintenance and disassembly can be associated with the product.
Sustainability information
Each manufacturer on NBS Source has the ability to digitise their core sustainability information, as defined in standardised documentation such as Environmental Product Declarations (EPDs). Figure 6 shows a concrete paving slab from the manufacturer Brett Landscaping. Information can be viewed regarding the factory location, the expected life, the inclusion of red list materials, and the embodied carbon. In addition, the EPD can be downloaded as a PDF.
For more information on sustainability, see the NBS article NBS and sustainability.
Product information management (PIM) integration
Finally, the interoperability of information between digital systems is key for a digital future. For efficiency and accuracy, the same information should flow from the PIM system to the many other platforms that specifiers, buyers and other key stakeholders use. Figure 7 shows the data entry system that manufacturers using NBS Source have access to. PIM integration functionality is well under way at NBS. This will allow data to flow between digital systems.
What if a specifier asks for a Digital Product Passport now?
As discussed in this article, as of May 2024, the precise definition of DPPs and how this data is structured and stored is not yet known. The consultation process is under way, and it is probable that other sectors, such as textiles and batteries, will lead the way ahead of construction. However, the majority of the information expected to be included in a DPP can already be provided through a manufacturer’s product page on NBS Source. As the requirements for the industry become clearer, NBS will support manufacturers and specifiers to prepare and work efficiently and accurately, and will remove any complexities.
information
To learn more about how NBS Source supports construction product manufacturers in meeting evolving digital and regulatory requirements, visit the NBS Source web page.
