Construction product marking - CE and UKCA compliance

What changed and why it matters

If you manufacture, import, or distribute construction products in Great Britain, you need to understand which marking your products must carry, what technical documentation is required, and which body enforces compliance.

The government had planned to require UKCA marking for all construction products, phasing out CE marking. That mandatory switchover was abandoned: since September 2023, government policy has been that CE marking continues to be recognised for construction products on the GB market until further notice, with UKCA marking voluntary. On 8 January 2026 the Construction Products (Amendment) Regulations 2025 came into force, keeping that recognition workable as the EU moves to its new Construction Products Regulation (EU) 2024/3110 - products complying with the new EU regime are treated as satisfying the GB requirements.

Construction products have their own marking regime, separate from the broader CE recognition framework covering 21 other product categories under the Product Safety and Metrology etc. (Amendment) Regulations 2024. You need to follow the construction-specific rules rather than general product marking guidance.

Who this affects

These rules apply to any business that places a construction product covered by a harmonised European standard on the Great Britain market. That includes:

• Manufacturers producing construction products in the UK or abroad
• Importers bringing construction products into Great Britain
• Distributors making construction products available on the GB market
• Construction firms specifying and purchasing products for projects

If you only purchase and install construction products (rather than placing them on the market), the marking rules do not create direct obligations on you. However, you should verify that your products carry valid marking and an accompanying Declaration of Performance, as using non-compliant products may create liability under building regulations and contract law.

The Construction Products (Amendment) Regulations 2025

The Construction Products (Amendment) Regulations 2025 (SI 2025/1172) amend retained Regulation (EU) No 305/2011 -- commonly known as the Construction Products Regulation or CPR -- and the Construction Products Regulations 2013 as they apply in Great Britain. The key effect is that compliance with the new EU Construction Products Regulation (EU) 2024/3110 is treated as satisfying the GB regime, creating a dual pathway as the EU migrates to its new framework. Continued recognition of CE marking itself stems from the existing GB framework and the September 2023 "until further notice" policy; UKCA marking is not mandatory.

However, the detail matters for your compliance strategy. The snippet below sets out the specific provisions, including the impact on different types of economic operator and the position on dual marking.

What this means in practice

The practical effect depends on your role in the supply chain:

If you are a manufacturer, you can continue testing and certifying your construction products against harmonised European standards (hENs) using EU notified bodies. You do not need to seek UKCA certification from a UK Approved Body unless you choose to. If you already hold UKCA certification, it remains valid and you may use it.

If you are an importer, you can continue bringing CE marked construction products into GB without converting them to UKCA. You must still verify that each product has a valid Declaration of Performance and that the CE marking has been applied correctly. Your name and contact details must appear on the product or its packaging.

If you are a distributor, you must verify that construction products you make available on the market bear either CE or UKCA marking and are accompanied by a Declaration of Performance. You do not need to perform your own conformity assessment, but you have a due diligence obligation to check that documentation is in order.

Why the government reversed course

Mandating UKCA marking would have required manufacturers to duplicate testing and certification against standards that are currently aligned with EU harmonised standards. The reversal recognises that accepting CE marking reduces costs without compromising product safety.

How construction products differ from other product categories

Construction products sit outside the main CE recognition framework. The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696) extended indefinite CE recognition for 21 product categories such as machinery, pressure equipment, and low voltage electrical equipment. Construction products were explicitly excluded because they are governed by separate legislation.

The practical outcome is similar -- CE marking continues to be recognised -- but the legal basis is different. This distinction matters if you are audited or challenged on compliance. You should be able to point to the correct instrument:

• Construction products: the retained CPR and the September 2023 continued-recognition policy, with SI 2025/1172 adding recognition of the new EU CPR 2024/3110 from 8 January 2026
• Other product categories: SI 2024/696 (Product Safety and Metrology etc. (Amendment) Regulations 2024)

Harmonised standards, designated standards, and the CPR

The Construction Products Regulation operates through standards. For the CE route, these are harmonised European standards (hENs) published by the European Committee for Standardisation (CEN). For the UKCA route, the GB regime operates through designated standards - standards designated by the Secretary of State for use in Great Britain, which currently mirror the CEN harmonised standards. If a harmonised or designated standard exists for your product type, you must draw up a Declaration of Performance based on testing against that standard before placing the product on the market.

These standards are performance-based. They require you to declare how your product performs against defined essential characteristics -- such as fire resistance, thermal conductivity, or structural strength -- rather than prescribing a single acceptable level. The specifier or end user decides whether the declared performance meets their project requirements.

If no harmonised or designated standard covers your product, voluntary assessment routes exist: a European Technical Assessment (ETA) from an EU Technical Assessment Body supports CE marking, and a UK Technical Assessment (UKTA) from a UK Technical Assessment Body supports UKCA marking.

Declaration of Performance requirements

The Declaration of Performance (DoP) is the foundation of the construction product marking system. You cannot affix a CE or UKCA mark to a construction product without first drawing up a DoP. The DoP is more than an administrative document -- it is the legally binding declaration of how your product performs against the essential characteristics defined in the applicable harmonised standard.

Getting the DoP wrong is a common compliance failure. The Office for Product Safety and Standards (OPSS) can issue compliance notices, withdrawal notices, and recall notices for products that do not have a valid DoP or that carry marking without one.

Common DoP mistakes to avoid

Based on OPSS enforcement activity and industry experience, the most frequent DoP problems are:

• Missing DoP entirely -- Products carry CE marking but no DoP exists. This is a direct breach of the CPR.
• Incomplete essential characteristics -- The DoP omits performance data for one or more essential characteristics required by the harmonised standard. You must declare performance for all characteristics relevant to the intended use, even if the value is "no performance determined" (NPD).
• Outdated AVCP reference -- The DoP references an old assessment and verification system that no longer matches the current harmonised standard.
• No English language version -- When placing products on the GB market, the DoP must be in English. Providing only a foreign-language version is non-compliant.
• Failure to supply with product -- The DoP must accompany the product, either in paper form or electronically. Having it available only on request (without proactive provision) does not meet the requirement.

Enforcement and what to do next

OPSS enforcement powers

The Office for Product Safety and Standards (OPSS), part of the Department for Business and Trade, enforces the Construction Products Regulation in Great Britain. OPSS has the power to:

• Issue compliance notices requiring you to bring products into conformity
• Issue withdrawal notices requiring you to stop making products available on the market
• Issue recall notices requiring you to retrieve products already distributed
• Conduct market surveillance including product testing and document checks

Construction product safety is an OPSS enforcement priority. If you receive a documentation request, respond promptly with your Declaration of Performance, test certificates, and evidence of the assessment and verification system applied.

What you should do now

Whether the 2025 amendment affects you depends on where you were in the transition process. Consider the following:

• If you were planning to switch to UKCA marking -- You can halt that process. CE marking remains fully valid. If you have already invested in UKCA certification, that certification is not wasted; you can use UKCA marking voluntarily or dual-mark your products.
• If you were already using CE marking -- Continue as before. No action is required provided your Declarations of Performance are up to date and your products comply with the applicable harmonised standards.
• If you import construction products -- Verify that your supply chain documentation (DoPs, test certificates, conformity assessment records) is complete and accessible. OPSS may request this documentation at any time.
• If you specify or purchase construction products -- Request Declarations of Performance from your suppliers and verify that products carry valid CE or UKCA marking. Keep copies for your project records.

Future reform

Broader reform of the construction products regulatory framework is under way in response to the Grenfell Tower Inquiry. Following the February 2025 Construction Products Reform green paper, the government published the Construction Products Reform White Paper on 26 February 2026. Its headline proposal is a national construction products regulator within the Office for Product Safety and Standards (OPSS), and a consultation on a new General Safety Requirement for construction products ran from 25 February to 20 May 2026. No Bill has yet been introduced, so the current framework continues to apply, but expect legislation to follow - monitor OPSS and MHCLG announcements.