UK updates construction products rules from Jan 2026
The government has signed off the Construction Products (Amendment) Regulations 2025, made on 6 November and laid before Parliament on 10 November, with commencement set for 8 January 2026. The instrument updates Great Britain’s regime so that compliance demonstrated under the EU’s new Construction Products Regulation, Regulation (EU) 2024/3110, can be used to meet domestic obligations already recognised for CE‑marked goods under Articles 16A to 16C of the retained EU rules. For manufacturers, importers and distributors, it means a clearer route to place products on the GB market using documentation already prepared for the EU, notably the combined Declaration of Performance and Conformity (DoPC).
Why this matters commercially: CE marking continues to be recognised in Great Britain beyond 30 June 2025, and ministers have signalled long‑term reform of construction product regulation. Today’s amendment effectively future‑proofs that position by referencing the EU’s updated rulebook, reducing duplicate paperwork for firms trading into both markets. The government’s guidance and the industry’s September 2024 summary confirm CE recognition has been extended while wider reforms are developed.
What has changed in the text is technical but practical. Definitions are refreshed so references to the “EU Construction Products Regulation” now encompass both EU 305/2011 and the successor 2024/3110. Articles 16A–16C, which set out when GB obligations are treated as satisfied by complying with EU rules, are updated to point explicitly to the EU’s assessment and verification systems and to accept a DoPC drawn up under Articles 13 and 15 of 2024/3110. Market surveillance provisions (Articles 59A–59B) are also amended so Trading Standards can act where an operator relies on EU 2024/3110 but the paperwork is missing or incorrect. The 2013 GB enforcement regulations are tweaked so their powers apply equally when firms use the new EU route.
The timeline is tight but manageable. The EU’s new regulation was published in the Official Journal on 18 December 2024, with preparatory provisions active from 7 January 2025 and most obligations applying from 8 January 2026. Transitional dates matter for niche products: EADs established under the old regime cease to apply from 9 January 2031, and ETAs based on them expire from 9 January 2036; the old EU CPR is fully repealed in 2040. Planning around these dates will help avoid stranded stock and re‑testing surprises.
For manufacturers, the headline shift is operational: the DoPC replaces the standalone Declaration of Performance under EU 305/2011 and must be provided digitally or via a product passport where used. Sustainability data move into the core product information, which many clients are already asking for in tenders. If you already compile DoPCs for the EU, this amendment means that, from 8 January 2026, the same dossier can underpin GB placements where you are using the EU route referenced in Articles 16A–16C.
Importers should tighten checks now. From January, you’ll need to verify that the overseas manufacturer has carried out the applicable EU assessment and that the product is accompanied by a compliant DoPC. Your business name and contact details must appear on the product, packaging or accompanying document, and you’re expected to keep a record of complaints and take swift corrective action if a risk emerges. These are familiar duties under EU 2024/3110 and they will now satisfy the GB route referenced in Article 16B when correctly executed.
Distributors will not escape scrutiny. The obligation is to ensure the product bears the right markings, that the DoPC or a valid reference accompanies the item, and that storage and transport do not compromise declared performance. Where issues arise, distributors must cooperate on withdrawals and recalls. Aligning warehouse SOPs to capture the DoPC and traceability data will reduce friction during spot checks.
Enforcement will feel more joined‑up. OPSS leads GB market surveillance for construction products and has been scaling activity since 2021, with a risk‑based focus. The amended Articles 59A–59B give Trading Standards a clean line to act on missing or defective EU‑route paperwork, while the 2013 Regulations ensure GB enforcement tools apply when businesses rely on 2024/3110 documentation. Expect more document‑led inspections and targeted sweeps on higher‑risk categories.
Supply chains crossing the Irish Sea need special attention. Northern Ireland continues to apply EU rules for construction products under the Windsor Framework, and the Assembly’s scrutiny notes confirm 2024/3110 is in scope. For GB‑based firms selling into NI, the DoPC and CE route remain standard; for NI‑based firms moving goods to GB, the updated GB recognition of EU 2024/3110 reduces friction provided documents are complete and accurate.
A typical SME scenario helps bring this to life. Take a Leeds‑based importer of fixings sourcing from a CE‑ready EU manufacturer. Today, they receive a DoP. By early January, that supplier issues a DoPC under 2024/3110. The importer verifies the assessment route, files the DoPC digitally, ensures their UK contact details appear on the label, and updates their complaints log template. The same file supports EU and GB placements, cutting duplicate certification while improving audit readiness.
Costs should be contained but not zero. The explanatory note to the instrument signals no significant impact, yet most SMEs will still invest time in document mapping, data field updates and training warehouse teams to capture the DoPC. The upside is fewer parallel files and a clearer path for mixed GB/EU trade once the EU provisions bite on 8 January 2026. Industry bodies also expect sustainability data requests to become routine as clients adjust procurement specs.
What to watch next: OPSS guidance as enforcement ramps through 2026; emerging harmonised standards under the new EU mandate; templates for DoPCs; and any government response to the 2025 green paper on construction products reform. Those policy choices will determine how far GB goes beyond document checks into testing and environmental disclosures. For now, aligning your EU‑format DoPC with GB placements is the simplest win.