New Construction Products Regulation: overview of requirements and compliance testing

Construction products sold in the EU must comply with the Construction Products Regulation (CPR). To show that a product is compliant, the manufacturer must, in most cases, draw up a declaration of performance and attach a CE marking to the product. This requires the manufacturer to demonstrate that the product's essential characteristics meet the requirements outlined in the CPR and applicable product-specific harmonized standards or European assessment documents.

The previous CPR, Regulation (EU) No 305/2011, was recently repealed by the new CPR, Regulation (EU) 2024/3110. Parts of the new CPR became applicable on the 7th of January 2025, while other parts will apply from the 8th of January 2026.¹ Product-specific performance requirements will be updated to match the new CPR gradually over several years when new standards and assessment documents are prepared.

Measurlabs offers a range of laboratory tests to evaluate construction product performance according to CPR requirements. We specialize in fire performance testing required for classification according to EN 13501-1 and other European classification standards, but we also provide services for evaluating other properties, such as mechanical performance, toxic substance emissions, and acoustic performance of building products.

Products subject to the Construction Products Regulation

The CPR applies to all construction products brought to market within the EU, defining them as physical items or kits intended to be permanently incorporated in buildings or civil engineering works². Annex VII of the new CPR categorizes such products into 36 product families, some of which include the following: 

• Doors, windows, shutters, and gates

• Thermal insulation products

• Wood-based panels and elements

• Floorings

• Construction adhesives

• Materials in contact with drinking water

• Power, control, and communication cables

In the previous CPR, there were 35 product areas, listed in Annex IV. Product family 36 (attached ladders), was introduced by the new CPR.

Requirements for product performance under the CPR

Annex I of the new CPR outlines the basic requirements for construction works. These will act as a basis for determining the essential characteristics of construction products when harmonized technical specifications are prepared:³

1. Structural integrity: construction works and their structural elements must be durable, serviceable, robust, and structurally resistant, even when faced with adverse events, such as earthquakes or fire. 

2. Fire safety: the spread of fire and smoke must be limited, and load-bearing capacity must be retained for a set time in the event of a fire to enable evacuation and facilitate the work of rescue and emergency services.

3. Protection against adverse hygiene and health impacts: detrimental impacts on health and safety must be limited by ensuring that construction products do not release toxic substances, hazardous particles (including microplastics), radiation, or waste into the indoor environment. 

4. Safety and accessibility: the design of construction works must not increase the risk of accidents, and the resulting buildings must be accessible to people with disabilities or reduced mobility.

5. Resistance to the passage of sound and acoustic properties: construction works must provide sufficient sound absorption and reflection to limit people’s exposure to noise pollution.

6. Energy economy and thermal performance: heating, cooling, lighting, and ventilation installations must be energy-efficient, taking into account local climatic conditions and EU targets for nearly zero-energy and zero-emissions buildings.

7. Emissions into the outdoor environment: construction works must not pose a risk to the environment through the release of hazardous substances, microplastics, radiation, waste, or greenhouse gas emissions.

8. Sustainable use of natural resources: raw materials must be used efficiently, energy use and waste generation must be minimized, and recyclability or reuse after demolition facilitated.

In addition, Annex II of the new CPR lists a set of predetermined environmental essential characteristics, which did not exist under the previous regulation. These cover the product’s effects on a range of detrimental phenomena from climate change to ozone depletion, acidification, and ecotoxicity. Declaring the product’s performance with regard to environmental characteristics will become compulsory in three stages between 2026 and 2032.⁴

Due to the abundance of different types of construction products, the more detailed requirements for essential characteristics are specified in product-specific harmonized technical specifications, which include harmonized standards and European Assessment Documents (EAD). The up-to-date requirements introduced by the new CPR will be taken into account when new technical specifications are prepared. In the meantime, existing specifications based on the previous CPR will remain in place.

Compliance testing according to harmonized standards

If a harmonized standard is available, the essential characteristics of a construction product must be assessed against the requirements specified in that standard.⁵ These characteristics and the parties responsible for assessing them are outlined in Annexes ZA and/or ZZ of the applicable harmonized standard.

The compliance assessment usually requires several laboratory tests to ensure that performance relating to each characteristic matches the listed specifications.

To take an example, the compliance of polyethylene foam thermal insulation products is to be assessed against harmonized standard EN 16069:2012. This standard, in turn, lists several more specific standards for assessing individual characteristics. Some of the tests required to show that a product complies with EN 16069 – and therefore the Construction Products Regulation – include the following:

• Thermal resistance and thermal conductivity by EN 12667 or EN 12939

• Reaction to fire classification by EN 13501-1

• Water vapor transmission rate by EN 12086

• Sound absorption coefficient by EN ISO 354

Furthermore, the dimensions (width, length, thickness, etc.) and mechanical properties (compressive and tensile strength, etc.) of the thermal insulation product need to be assessed against additional standards listed in EN 16069. 

European Technical Assessment for products not covered by a harmonized standard

If a construction product is not (fully) covered by a harmonized standard, compliance can be evaluated through a European Technical Assessment (ETA). In this case, the applicable performance requirements are outlined in a European Assessment Document (EAD), which the European Organisation for Technical Assessment (EOTA) lists on its website.⁶ Similarly to harmonized standards, EADs outline the detailed performance requirements and test methods for specific types of construction products.

If there is no existing EAD that would fully cover the construction product, the manufacturer can request EOTA to create one.

Declaration of performance and CE marking for construction products

When bringing a construction product covered by a harmonized standard to market in the EU, the manufacturer must draw up a declaration of performance and attach a CE marking to the product.⁷ For non-standard products, these steps are voluntary – yet highly recommended –as the CE marking allows the product to be freely traded on the European internal market. 

The declaration of performance summarizes the product’s key properties, including its intended use(s), the harmonized technical specification (standard or EAD) that performance was assessed against, essential characteristics, and declared performance for each characteristic. By signing the document and subsequently affixing a CE marking to the product, the manufacturer assumes full responsibility for the product’s declared performance.

Testing of construction products according to the CPR

Measurlabs provides a wide range of laboratory tests to show that construction products meet the performance requirements outlined in the Construction Products Regulation and harmonized technical specifications. Some of our most popular services include:

• Reaction to fire tests and the fire classification report for EN 13501-1, including EN ISO 11925-2 (ignitability with a small flame), EN 13823 (single burning item test), and EN ISO 9239-1 (reaction-to-fire test for flooring). 

• Toxic substance emissions testing, including screening for formaldehyde and volatile organic compounds (VOC)

• Evaluation of acoustic performance, such as sound absorption capacity

We also offer consulting services to help develop a comprehensive testing plan that takes into account those requirements of the CPR that are relevant to your product, as well as any additional product development goals you may have. Do not hesitate to ask our experts for more information and a quote via the form below.