The revised Construction Products Regulation is a major change to the EU framework. Its application must be assessed product by product, including the transitional provisions.
Application is staged
Regulation (EU) 2024/3110 applies in substantial part from 8 January 2026, with provisions applying on different dates and arrangements for the transition from the previous regime. A project team should not assume that every existing technical specification and document changed overnight.
Review the procurement specification
Identify the required product characteristics, declarations and supporting evidence. Clarify the responsibilities of manufacturers, importers, distributors and contractors. New sustainability and digital-information mechanisms need to be read with the measures applicable to the particular product family.
Keep contractual and regulatory questions connected
A product’s regulatory documentation does not by itself prove that the installed system meets the building contract. Record substitution approvals and preserve traceability throughout delivery and handover.
Four practical examples
Illustrative scenarios: the appropriate steps depend on the contract, evidence and applicable law. These are not reports of client matters.
An existing product specification
Check the applicable transition before rewriting the tender.
A new supplier
Confirm the relevant operator role and documentation.
A passport requirement
Verify whether a specific obligation has become applicable to that product.
A site substitution
Compare declared performance with the intended use and system design.
Further guidance
Legal framework & further reading
Reviewed: 12 November 2026. Statutory references are to German law unless stated otherwise.