Construction Products Europe rejects the repeal of the Regulation (EU) No 305/2011 (Construction Products Regulation – CPR) and considers it must be the core regulatory framework for the construction sector in Europe.

Following extensive consultations with members and other stakeholders, Construction Products Europe feels confident that it is possible, through pragmatic solutions and within a reasonable timeframe, to resolve the CPR implementation issues under the current legislative framework. Should critical issues remain unresolved, a focused revision of the CPR could be considered during the next European Parliament term of office.

Both the CPD and the CPR have been the regulatory framework for construction products in the last three decades. The established system was the key to remove barriers to trade and as a result the European market for construction products is facilitated . The combination of the Declaration of Performance (DoP) and CE marking has been demonstrated to be an effective way to communicate regulated information from construction products using a common European technical language. Moreover the level playing field for construction products is developed through harmonised standards (hEN) and European Assessment Documents (EAD).

Advantages of the CPR and consequences of the repeal

Thanks to the CPR the construction industry benefits from common test methods, design rules, etc. Member States, manufacturers, contractors, architects, engineers, etc. have invested considerable resources in the implementation of the CPR and also transformed the way they work to align to the regulatory requirements.

CPR harmonised technical language is facilitating:

• convergence of National building codes;
• spread of best practices;
• innovation and research under a broad European scope;
• development of communication tools such as Building Information Modelling (BIM).

Repeal of the CPR would penalise such developments.

Not only are hEN and EAD important tools under the CPR, assessment and verification of constancy of performance (AVCP) systems also contribute to a level playing field for construction products. 

One of the main drivers for the competitiveness of the European industry has been the strong support of standardisation through its link to regulatory requirements. Standards will remain valid after a repeal of the CPR but companies will be discouraged to invest their resources on its development because their implementation will depend on agreements and will not be supported as a principle.

The repeal of the CPR would send us back to the previous century, barriers to trade will be back and the considerable investment would be squandered.

Proposals

Construction Products Europe calls for joint and constructive efforts from EC, Member States, CEN and EOTA to solve operational issues and to guarantee that National and European regulations work together as a comprehensive and reliable system. Discussions should be based on the respect of the subsidiarity principle i.e. Member States regulate construction works at National level while the market is benefiting from a European approach to the exchange of declared performance of construction products.

Instead of repealing the CPR, Construction Products Europe requests swift and pragmatic solutions to tackle the most urgent problems, in particular citation of harmonised standards and any other issue slowing down or blocking the implementation of the CPR.