New CPR

The European construction sector is undergoing a significant transformation with the entry into force of Regulation (EU) 2024/3110, which replaces the previous Regulation (EU) 305/2011 on the marketing of construction products. On 18 December 2024, Regulation (EU) 2024/3110 of the European Parliament and of the Council (hereinafter referred to as the new CPR) was published in the Official Journal of the European Union. This regulation lays down harmonised rules for the placing of construction products on the market and repeals Regulation (EU) No 305/2011.

The introduction of Regulation (EU) 2024/3110 presents both a challenge and an opportunity for the construction industry. On the one hand, it imposes new compliance obligations for construction products; on the other, it promotes transparency, sustainability, and digitalization—key elements increasingly demanded by the market.

The Regulation entered into force on January 7, 2025, and will be applicable from January 8, 2026.

There is no need for concern – the new rules will be introduced gradually, as illustrated in the timeline below.

The new Construction Products Regulation (CPR) updates the voluntary CE marking system for construction products, providing more legal clarity for manufacturers and regulators.

Products using the European Organisation for Technical Assessment (EOTA) route will benefit from new market instruments under the new CPR, including:

• CE marking with data carriers
• declarations of performance and conformity (DoPC)
• general product information, instructions for use and safety information
• digital product passport (DPP), when implemented

The definition of harmonised technical specifications has changed. Only performance-harmonised standards and implementing acts adopted for the same purpose (fallback option) are now considered and defined as harmonised technical specifications (performance HTS)

The EOTA route remains voluntary for manufacturers seeking CE marking for innovative products not covered by performance HTS

EADs are not part of the new harmonised zone, meaning they are not considered harmonised technical specifications but should follow assessment methods defined in performance HTS to ensure regulatory consistency

An ETA can only be issued if the corresponding EAD is cited in the Official Journal of the European Union

If a new EAD needs to be developed for an ETA request, the TAB will provide the ETA only after the EAD is cited

EADs must not overlap with the scope of performance HTS

• If a product is covered by a performance HTS, it falls under the harmonised zone, and the TAB will inform the manufacturer that the ETA request cannot be processed but characteristics may be considered in the revision of the relevant performance HTS

If it is unclear whether a performance HTS overlaps with a potential EAD, developing the EAD is allowed if

• The product's declared use is outside the performance HTS’ intended use
• The materials used differ from those in the performance HTS
• Assessment methods of the performance HTS are unsuitable for the product

EADs can be requested by groups of manufacturers, associations, or the Commission, but each manufacturer receives an individual ETA upon request

There are specific validity and expiration periods

• EADs are valid for 10 years
• EOTA can request a 10-year extension from the Commission in the final year before expiration
• ETAs can be used for five years after an EAD expires

The procedure for requesting ETAs and adopting EADs is now more streamlined, enhancing coordination between EOTA and the Commission

The new CPR requires that new EADs include all essential characteristics related to environmental sustainability (life cycle assessment indicators according to EN 15804), with ETAs declaring these characteristics in the following stages

• Global Warming Potential (GWP) upon EAD citation
• The core list of LCA-EPD indicators by 2029 (four years after the date of application of the new CPR)
• The full list of LCA-EPD indicators by 2031 (six years after the date of application of the new CPR)

ETAGs (equivalent of EADs under the Construction Products Directive) cannot be used for CE marking under the new CPR

ETAs based on non-cited EADs cannot be used for CE marking under either the outgoing or the new CPR from the date of application of the new CPR. These ETAs will be treated as new CPR ETA requests and must follow new CPR rules if the product and its intended use are not covered by a performance HTS.

EADs cited under the outgoing CPR can be transferred to the new CPR if a manufacturer requests an ETA for the respective product under the new CPR. The new ETA and EAD must then meet all requirements of the new CPR.

Key milestones:

• End of 2030 – end of validity of EADs from current CPR
• End of 2035 – end of validity of ETAs from current CPR

CONTACT

Post address:
INSTITUTE FOR TESTING AND CERTIFICATION
DIVISION CSI – CENTRE OF CIVIL ENGINEERING
Certification of construction products
Pražská 16/810
102 00 Praha 10
Czech Republic
mapy.cz