Westminster Policy News & Legislative Analysis

UK clarifies CE reliance for construction products from Jan 2026

Great Britain will adjust how EU‑assessed construction products can be accepted on the domestic market from 8 January 2026. The Construction Products (Amendment) Regulations 2025 (SI 2025/1172) update retained rules to confirm when CE‑marked products assessed under EU law can be treated as meeting GB obligations. The instrument is listed on legislation.gov.uk as published on 11 November 2025.

The measure updates definitions so references to the “EU Construction Products Regulation” now expressly include both Regulation (EU) No 305/2011 and the recast Regulation (EU) 2024/3110. The EU recast entered into force on 7 January 2025 and becomes generally applicable on 8 January 2026, so the UK cross‑references are aligned to that timetable.

For manufacturers, Article 16A is revised to recognise two compliance routes when relying on EU law. A manufacturer may continue to use processes and documentation under Regulation (EU) 305/2011 or apply the assessment and verification system under Regulation (EU) 2024/3110. Declarations of performance and conformity prepared to Articles 13 and 15 of the EU recast may accompany products placed on the GB market, with the Article 15(6) information travelling with the declaration.

Importer provisions in Article 16B are adjusted on the same basis. Where an importer relies on EU compliance, they must verify that the manufacturer has carried out the applicable EU assessment and drawn up a declaration of performance and conformity, and that required information accompanies the product, including the labelling and documentation referenced in Articles 22 and 24 of the EU recast.

Article 16C confirms equivalent treatment for distributors relying on EU rules. Distributors should ensure products are accompanied by a declaration or a reference to the manufacturer’s declaration of performance and conformity and that documentation required under Article 25 of the EU recast is available before making products available in GB.

Market surveillance provisions are updated so that “formal non‑compliance” and “other non‑compliance” now extend to failures connected with Regulation (EU) 2024/3110, such as not drawing up the EU declaration of performance and conformity or missing documentation. Trading standards remain responsible for enforcement in Great Britain under the Construction Products Regulations 2013.

Consequential amendments to the Construction Products Regulations 2013 align definitions and documentation rules so that reliance on the EU recast falls within the existing GB enforcement framework. The 2013 Regulations apply in England, Wales and Scotland, confirming the territorial scope for these measures.

Timing matters for planning. The EU’s recast CPR becomes generally applicable on 8 January 2026, while the current CPR (305/2011) continues in parallel for an extended transition. EU material indicates that Regulation 305/2011 will not be fully repealed until 2040, meaning both frameworks will co‑exist for many years.

Movements into or within Northern Ireland follow EU law under the Windsor Framework. The Northern Ireland Assembly has listed Regulation (EU) 2024/3110 for scrutiny, confirming its relevance there; businesses supplying NI should therefore continue to follow the EU regime rather than the GB reliance model outlined here.

For compliance teams, the practical steps are clear. Update technical files to include EU 2024/3110 declarations where available, ensure accompanying information travels with shipments, review labels and digital documentation against the EU recast, and confirm importer and distributor checks are documented ahead of the 8 January 2026 commencement.