Tarık Ömer Gedik – Certification Manager / CPC Certification
The Construction Products Regulation (CPR) was published in the Official Journal of the European Union on 18.12.2024. With the publication of the new CPR, the old Construction Products Regulation (305/2011/EU) will be repealed on January 08, 2026. Within the framework of the European Parliament, Circular Action Plan, the revision of the regulation was carried out and the process was completed in order to facilitate the sustainability of Building Materials, the creation of a stronger single market for the recovery of Europe and the free movement of products in accordance with today’s technology.
In order to achieve the objectives of the European Green Deal and the Circular Economy Action Plan, the Commission should have the possibility to set minimum threshold levels for the environmental performance of Building Materials and product environmental requirements that prevent and reduce the impact of Building Materials on the environment.
To ensure the sustainability and durability of Building Materials, manufacturers should ensure that products can be used for as long as possible. Such longevity requires adequate design, the use of reliable parts, the repairability of products, the availability of information on repairs and access to spare parts. However, the principle of safety first, which applies to both the construction product and the construction works, must be respected in all cases and must include the protection of health.
Based on EN 15804 Sustainability in construction – Environmental declarations for products – Main rules for the product category of construction products The pursuit of environmental objectives, tincluding the fight against climate change and the transition to a circular economy, makes it necessary to establish new environmental obligations without increasing disproportionate bureaucracy and costs for economic operators, in particular small and medium-sized enterprises (“SMEs”), and to lay the groundwork for the development and implementation of an assessment method for calculating the environmental sustainability of construction products. Calculations should cover the life cycle of the product using methods established through standardization. Life cycles calculated for new products should include all stages of a product’s life, from obtaining raw materials or production from natural resources to its final disposal, and should include potential benefits and burdens outside the boundaries. For used and remanufactured products, the calculated life cycle should start with dismantling from a construction work and include all subsequent stages until final disposal. The Commission should make software available to perform the calculation, in particular the applicable characterization factors in accordance with the European standard EN 15804 or future applicable standards. Any update of this software should be notified and should trigger an update of the relevant calculations within one year.
In line with the objectives of the Circular Economy Action Plan and the waste hierarchy, in terms of increasing the circularity of building materials, product requirements should also be able to improve resource efficiency, prevent waste generation, prioritize repair, reuse and remanufacture, promote the use of secondary materials and address waste recyclability. (Production of products and byproducts.) Preparing for reuse, remanufacture and recycling requires specific design, facilitating the separation of products, components and materials during installation, deconstruction and demolition and in the subsequent stage of recycling, and avoiding mixed, blended or complex materials and related substances whenever possible. Since the usual instructions for use and safety information will not necessarily reach the economic operators responsible for preparing for reuse, reuse, remanufacture and recycling, the necessary information in this regard should be provided in digital product passports accessible via data carriers and on the manufacturer’s websites.
However, Manufacturers must realize that; The Building Materials and their intended use must be precisely defined by the manufacturer in order to create transparency for users of the Building Materials and to avoid inappropriate use of these products. For the same reason, the manufacturer should clarify whether the Building Materials are intended for professional use. In order to ensure the backward traceability of construction products, manufacturers must indicate on the product or, where this is not possible, e.g. due to the size or surface of the product, on an affixed label, on the packaging or, where this is also not possible, the unique manufacturerspecific identification code of the type of product (in a document accompanying the product)
The technical documentation on building materials prepared by the manufacturer facilitates the verification of these products by competent national authorities and notified bodies in accordance with the requirements of the European Union. To increase access to comprehensive information, this technical documentation should include the information necessary to verify the calculation that confirms the assessment of the environmental sustainability of the construction product.
General product information, instructions for use and safety information are a vital tool to provide a broad group of people potentially in need of information with sufficient information to make informed decisions about the purchase, installation, use, maintenance, dismantling, reuse and recycling of the product. Therefore, the elements to be covered by general product information, instructions for use and safety information should be specified in this Regulation and guidance on how these elements are typically covered in relation to a particular product could be included in harmonized standards of performance. However, such guidance should not extend or restrict the manufacturer’s responsibility to provide information as specified in the Regulation. The Commission should be empowered to adopt delegated acts to ensure adequate and homogeneous implementation of the obligation to provide general product information, instructions for use and safety information for specific product families or product categories, where performance harmonized standards cannot do so. (The content of general product information, instructions for use and safety information is contained in Annex IV).
Declaration of Performance Where a product is covered by an accepted harmonized technical specification, the manufacturer shall undergo the applicable assessment and verification system set out in Annex IX of the regulation and shall prepare a declaration of performance and conformity before placing such a product on the market. By preparing the declaration of performance and conformity, the manufacturer assumes responsibility for the declared performance of the product and its compliance with all applicable product requirements and shall be liable in accordance with European Union and National laws on contractual and noncontractual liability. In the absence of objective indications to the contrary, EU Member States shall ensure that the declaration of performance and conformity prepared by the manufacturer is correct and that in the absence of a declaration of performance and conformity, the product shall not be placed on the market or withdrawn in the event of non-compliance or when such a declaration is required. (The content of the Declaration of Performance is included in Annex V of the new regulation).
The CE Marking is subject to the general principles set out in Article 30 of Regulation (EC) No 765/2008. The CE marking shall only be affixed to products for which the manufacturer has prepared a declaration. By affixing or having affixed the CE marking to the product, the economic operator indicates that it is responsible for the conformity of the product with the declared performance and the applicable product requirements set out in accordance with this Regulation. The CE marking shall be the only sign evidencing the performance of the product in relation to the essential characteristics assessed in accordance with this Regulation and the conformity of the product with this Regulation.
Digital Product Passport A tool that will be created electronically and where information on products is recorded and processed in such a way that it can be shared with competent authorities in the value chain, suppliers, customers and actors in the recycling sector. Increasing transparency for products in the value chain and implementing the sanctions related to the regulations in a healthier way are among the expected benefits of the digital product passport. By the end of 2026, the Digital Product Passport system will be established and will become mandatory in the first 6 months of 2028, 18 months after its establishment.
The Digital Product Passport must include; Declaration of Performance, CE Mark, General Product Information, Instructions for Use, Safety Information and Technical Documentation.
