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"Regulation (EU) 2024/3110 of the European Parliament and of the Council laying down harmonised rules for the marketing of construction products", as the full name of the CPR (Construction Products Regulation) reads, came into force. However, the new legal framework will not become generally applicable until January 8, 2026. This is meant to ensure that the construction industry has sufficient time to familiarize itself with the amended legal provisions. There are also other deadlines. For example, information on fine dust emissions as well as on eco- and human toxicity must be included in the product declaration for harmonized construction products, but only from January 9, 2032.

In view of these transitional periods and the associated uncertainties, Klaus Winkels, Managing Director of the GEV, the German Association for the Control of Emissions in Products for Flooring Installation, Adhesives and Building Materials – advises all players in the construction industry to base their product choice on tried and trusted quality seals such as the EMICODE^®, as these will continue to remain valid. "Naturally, there are also rules for the use of eco- and sustainability labels such as the EMICODE^®. The requirements to be met may be stricter than those prescribed by law, but the assessment methods must be the same as those used to assess the performance of a harmonized product," explains the expert. "This leaves room for the EMICODE^® to persist as a quality seal in a class of its own. In individual cases, however, methodological adjustments may be necessary."

The primary aim of the Construction Products Regulation (CPR) is to create a single market for construction products in order to facilitate the free movement of those products for European companies. "The new regulation had become necessary because, following a decision by the European Court of Justice, the EU is responsible for ensuring that harmonized standards are created ‘without shortcomings’," says Winkels. "Harmonized standards are used by experts to lay down the safety and performance requirements that a construction product needs to fulfill. The publication of new and revised harmonized standards was therefore temporarily suspended by the EU Commission."

The publication of the revised CPR has now laid the foundation for a further harmonization of the rules governing construction products. "This harmonization is achieved through the so-called ‘CPR Acquis Process’, in which EU member states submit their requirements. Manufacturers‘ associations are involved in the harmonization process when so-called ‘Standardization Requests’ are issued for the creation of harmonized standards for construction products," explains Winkels. On approx. 300 pages, comprising 96 articles and 11 annexes, the EU regulates, among other things, the framework for requirements to be met by harmonized construction products. "Since this work will take many years in a priority-based process, the old CPR from 2011 will continue to apply for another 15 years and affects construction products that have not yet been regulated under the new provisions. If there is no EU regulation in place for these products, national law applies – in Germany the Conformity Mark or Ü-Zeichen."

In addition to capturing the requirements of EU member states, construction products must also be environmentally sustainable as part of the Green Deal and serve the EU’s circular economy and climate goals. "Compliance with the requirements is verified in various audit procedures, which causes an additional cost burden for manufacturers," emphasizes Winkels. Furthermore, manufacturers will have to submit a Digital Product Passport for their products in order to manage communication – a complex process given the large number of requirements.

"It remains to be seen whether the EU will succeed in reconciling the multitude of tasks, goals, and interests," Winkels remarks. "Recently, there has been growing political resistance to the regulations being too detailed and too complicated. But this often ignores the fact that the requirements mostly originate from the member states and were achieved through complicated agreement processes." All parties involved must strive to focus on the essentials and thus enable greater efficiency in this single market.

Extra box: The EMICODE^® label

The EMICODE^® label is awarded by the GEV, the German Association for the Control of Emissions in Products for Flooring Installation, Adhesives and Building Materials. Only products that guarantee the lowest possible indoor emissions are awarded the EMICODE^® certificate. Building materials equipped with this label are available for a wide variety of trades. They have been tested for harmful VOC emissions by independent laboratories in special test chambers. To ensure long-term compliance with the predefined limit values, the initial test is followed by regular spot checks that are carried out, without advance notice, by independent experts and testing institutes.