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New EU Construction Products Regulation — The EMICODE® – a future-proof label for eco-friendly building

The new EU Con­struc­tion Products Reg­u­la­tion is inten­ded to help cre­ate a single European mar­ket for con­struc­tion products. How­ever, this is a pro­cess that will take years to com­plete. It is there­fore extremely help­ful for plan­ners and con­tract­ors in the build­ing industry that proven seals such as the EMICODE® label will con­tin­ue to provide a good bench­mark for product selec­tion.

On Janu­ary 7, 2025, “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.

Photo: © GEV/Iris Pohl

Since its found­a­tion in 1997, law­yer Klaus Winkels has been Man­aging Dir­ect­or of the Düs­sel­­dorf-based GEV Gemeinsch­aft Emis­sion­skon­trol­lierte Ver­legew­erkstoffe, Kleb­stoffe und Bauprodukte e. V (Ger­man Asso­ci­ation for the Con­trol of Emis­sions in Products for Floor­ing Install­a­tion, Adhes­ives and Build­ing Mater­i­als).

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11 Septem­ber 2025