New CPR framework

New CPR framework raises the bar for how construction products are declared.

For the first time, manufacturers of construction products have a concrete working plan showing when new harmonised standards will take effect across product families. But the timeline is only part of the story – the more fundamental change is in how products must be declared and documented.

26/03/26

For manufacturers of construction products, the revision of the Construction Products Regulation (CPR) has been on the horizon for years. What is new is that the framework is now becoming concrete. With the first CPR working plan now published for the period 2026-2029 – with implementation deadlines extending to 2032 – companies can see not only when their product families are expected to move forward, but also how the underlying logic of market documentation is changing.

“The individual concepts are familiar to most people, but what many do not yet know is that performance, conformity and sustainability are now being linked together in a way they have not been before,” says Allan Christensen, Operational Manager at DBI Certification.

From DoP to DoPC

Most manufacturers in scope of CPR know the Declaration of Performance (DoP) – the document that describes a product's essential technical characteristics. Under the updated CPR framework, that declaration expands into a Declaration of Performance and Conformity (DoPC).

The distinction matters because it fundamentally expands what manufacturers must declare and document. Where the DoP focus on measurable technical performance, the DoPC introduces two additional elements: Conformity with product-specific requirements, and environmental sustainability. For many manufacturers, this means that documentation which today sits outside the regulatory framework will need to become part of it.

Merete Poulsen, Senior Consultant at DBI Certification, explains the distinction:

“Performance is what the product can do related to fire, acoustics, load-bearing, etc. Conformity is different as it covers requirements that are not about function but about compliance with specified conditions. Take an emergency push button: The function is that it triggers an alarm when pressed, but the standard also requires it to be red so it is easy to recognise in an emergency. That is a conformity requirement that has nothing to do with whether it works.”

Sustainability enters the regulated framework

Many manufacturers already produce Environmental Product Declarations (EPDs) or CO₂ reports but today these sit outside the harmonised regulatory framework. What is changing is that calculation methods are being standardised within product categories, and the documentation will need to be formally verified.

“Today, there are countless different standards you can use to calculate environmental impact. It varies from country to country. That is being harmonised. The new standards will specify exactly how the calculation must be done and on what basis, and then it will need to be verified – including a visit to the production site to confirm that what is in the report actually reflects what is happening in production,” says Merete Poulsen.

For many manufacturers, this is not a question of starting from scratch. It is a question of ensuring that existing environmental data meets the new harmonised requirements and can withstand third-party scrutiny.

A stronger link between test and product

CPR also places greater emphasis on traceability between test results and the specific product placed on the market. Under parts of the current system, it has been possible to test one product configuration without the same level of formal traceability to the product actually sold. The revised framework tightens this through stronger product identification requirements.

“Test results need to be tied to the identified product. If you change a component – insulation, for example – that change will need to be assessed, and you will not be able to make changes after the fact without going back through the process,” says Merete Poulsen.

A further development is the emerging Digital Product Passport (DPP). Final details are still being worked out, but the direction is clear: product declarations, certificates and verification documents will need to be registered in a structured, accessible format – giving authorities the ability to verify compliance and supporting market surveillance across the EU.

The journey starts now

Within DBI Certification's areas of expertise, doors and windows are among the first product families expected to reach mandatory CE marking around 2029, with several other product families following in subsequent years.

“Different manufacturers will face very different implications depending on their products and their current documentation. What we can offer is helping companies understand what these changes mean for their specific situation – not in general terms, but for their product. That conversation is worth starting well before the deadlines arrive,” says Allan Christensen.