Regulatory tracker

UK construction product digital requirements

What is law now, what the government has committed to, what has been consulted on, what can reasonably be expected and what is only speculation — each with a primary source and the date we last checked it.

The five statuses

Every statement carries exactly one. They are not blurred, and they are not ranked by how likely something feels.

LAW
In force now, with a citation to the instrument that creates the duty.
GOVERNMENT COMMITMENT
Government has publicly committed to do it. It is not yet law.
CONSULTATION
Formally consulted on. The outcome is not yet decided, or not yet legislated.
EXPECTED
Reasonably expected from official signals, but with no formal commitment behind it.
SPECULATION
Industry commentary or our own inference. Treat it as an opinion, not a plan.

Entries also carry a confidence level. Anything we have not yet read at source is marked Awaiting verification so you can weight it accordingly.

LAW

In force now, with a citation to the instrument that creates the duty.

Construction Products Regulation as it applies in Great Britain

LAWGB

Regulation (EU) No 305/2011 continues to apply in Great Britain as assimilated law. Chapter II covers the declaration of performance and UK marking, and Chapter III sets the obligations of manufacturers, importers and distributors. It has been amended several times since EU exit, most recently by the Construction Products (Amendment) Regulations 2025.

Implications

Where a fire doorset or a component is covered by a designated standard, the manufacturer must declare performance against that standard, hold the supporting technical documentation, and operate factory production control appropriate to the assessment and verification system that applies.

Relevance to fire-door products

Fire Product Record organises the product revisions, configurations, performance claims and evidence that sit behind a declaration, and keeps a record of which evidence supported which claim at any date. It does not draw up declarations and does not determine whether a product complies.

Applicability

The legislation.gov.uk page shows the latest revised GB version, which includes Articles 16A to 16C added after EU exit. For any historical declaration, read the point-in-time version that applied on the date it was drawn up.

Construction Products Regulations 2013 (SI 2013/1387)

LAWUK

These Regulations create the domestic offences, enforcement powers and market surveillance regime behind the Construction Products Regulation. Part 2 covers offences, suspension notices, forfeiture, prohibition notices and notices to warn; Part 3 covers enforcement powers, test purchases, entry and search, appeals and compensation. They have been amended since, including by SI 2022/712 and SI 2025/1172.

Implications

Enforcement is directed at products and at the operators who place them on the market. What makes an enquiry manageable is being able to produce, quickly, the documents behind a claim and the product revision they relate to.

Relevance to fire-door products

An evidence pack exports one product version with its claims, the evidence supporting them and a hash of the record, so an enquiry can be answered with the record as it stood on a given date rather than as it looks today.

Applicability

The contents page was read for structure. Read the in-force text as amended before relying on any particular regulation.

Declaration of performance for GB construction products

LAWGB

A manufacturer placing a construction product covered by a designated standard on the GB market must draw up a declaration of performance and mark the product. The declaration must be supplied with the product or made available in line with the regulation. GOV.UK guidance notes that manufacturers supplying both markets may need declarations that meet the GB and EU requirements separately.

Implications

Tie each declaration to a specific product revision and to the evidence supporting each declared characteristic. When a component, a supplier or a test changes, consider whether the declaration has to be reissued rather than quietly edited.

Relevance to fire-door products

Declarations are held as evidence records against the product version they belong to, so a superseded declaration stays in the history instead of being overwritten, and claims that depended on it are flagged for review.

Applicability

Guidance page last updated 21 May 2025 when checked. The guidance is not the law; the duties themselves sit in the assimilated Regulation (EU) No 305/2011.

Designated standards for construction products

LAWGB

The government publishes the designated standards for construction products as a notice of publication plus a consolidated list. Version 2 of the consolidated list is dated 26 September 2025. Unlike most UK product regimes, use of a designated standard is mandatory where one covers the product.

Implications

Check which designated standard, if any, covers each product you make, and which edition is cited. The cited edition can be older than the current British Standard, and the citation, not the newest edition, is what the regime turns on.

Relevance to fire-door products

Standards are held as versioned records, and each product version is linked to the standards it was tested, classified, assessed or certified against, so a change in a cited edition can be traced to the products that depend on it.

Applicability

The list is amended by notices of publication. Check the current version before relying on any citation recorded here.

UKCA and CE marking for construction products in GB

LAWGB

Following the announcement of 2 September 2024, CE marking continues to be recognised when placing construction products on the GB market, with no end date. UKCA marking, using UK approved bodies, remains available as the alternative. GOV.UK guidance states that the longer-term future of CE recognition is conditional on wider reforms.

Implications

There is no marking deadline to plan around at the moment, but record which route each product actually uses. A product marked CE and a product marked UKCA carry different documentation and name different bodies.

Relevance to fire-door products

Certificates and declarations are recorded per product version with the issuing body and validity dates, so the two routes stay distinguishable in the record and in exports.

Applicability

The government has said any future change to CE recognition would carry a minimum two-year transition; that statement was seen in secondary reporting and is not verified here from a primary source.

Construction Products (Amendment) Regulations 2025 (SI 2025/1172)

LAWGB

Made on 6 November 2025 under section 146 of and Schedule 11 to the Building Safety Act 2022, these Regulations came into force on 8 January 2026. They amend the assimilated Regulation (EU) No 305/2011 and the Construction Products Regulations 2013 so that compliance with the corresponding provisions of the new EU Regulation (EU) 2024/3110 can be relied on in Great Britain, and so that enforcement applies to products taking that route.

Implications

A manufacturer already moving to the new EU regime does not have to run two entirely separate conformity routes for GB. Record which route each product uses, because the declaration, the marking and the supporting documents differ.

Relevance to fire-door products

Because identifiers, declarations and certificates are held per product version with their issuer, a product following the EU route and one following the GB route can be told apart in the record and in any export.

Applicability

The amendments touch Articles 16A to 16C and Articles 59A to 59B of the assimilated regulation. Read the amended text rather than this summary before relying on the equivalence route.

Building Safety Act 2022: construction products provisions

LAWUK

Part 5 of the Act contains the construction products provisions: section 146 (construction products) with Schedule 11 (construction products regulations), and sections 147 to 149 on liability relating to construction products and to cladding products. Schedule 11 is the power under which construction products regulations are made, including the 2022 and 2025 amendments.

Implications

Most of the coming change is expected to arrive as regulations made under Schedule 11 rather than as a new Act, so secondary legislation is what to watch. The liability provisions also matter: they reach back to past supply of products.

Relevance to fire-door products

Keeping a durable, dated record of which claims were made, on what evidence and for which product revision is the practical answer to questions asked years after supply. The audit log and immutable published record snapshots exist for that.

Applicability

Commencement of individual sections varies. Check the commencement information on legislation.gov.uk for any section you rely on.

National regulator for construction products (within OPSS)

LAWUK

The national regulator for construction products sits within the Office for Product Safety and Standards, which took the role on in April 2021 and is accountable to MHCLG ministers. It leads market surveillance, coordinates local authority enforcement, and carries out product testing, site inspections and reviews of technical documentation. The Construction Products (Amendment) Regulations 2022 made the Secretary of State an enforcement authority, which gave the regulator direct enforcement powers.

Implications

Requests for technical documentation are specific and time-bound. Know where the test report, classification report, field of application and factory production control records for a given product revision are, and who approved the claim.

Relevance to fire-door products

Evidence records carry status and expiry, claims are linked to the evidence that supports them, and exports produce a single pack for one product version. That is about answering questions quickly, not about demonstrating compliance.

Applicability

Guidance page last updated 22 July 2026 when checked. The government has separately consulted on a single construction regulator that would take on these construction product functions; its consultation document was published on 17 December 2025.

Which fire doorsets have a designated standard route

LAWGB

EN 16034:2014 is a designated standard for fire resisting and smoke control characteristics, but the consolidated list records that it "shall only be applied together with either EN 13241:2003+A2:2016 or EN 14351-1:2006+A2:2016". EN 14351-1 covers windows and external pedestrian doorsets. EN 14351-2, which covers internal pedestrian doorsets, does not appear on the designated standards list.

Implications

External fire doorsets can be marked under EN 16034 with EN 14351-1. Internal fire doorsets generally have no designated standard route, so they are not UKCA or CE marked, and performance rests on test evidence, classification, field of application and third-party certification instead. Check the route product by product rather than assuming one answer for the range.

Relevance to fire-door products

Each product version records the standards it was tested to, classified to, assessed to or certified under, so a marked external doorset and an evidence-based internal doorset look different in the record instead of being flattened into one shape.

Applicability

Verified against the consolidated list of designated standards, version 2 dated 26 September 2025, and the BSI record for BS EN 14351-2:2018. The list changes; re-check before relying on it. This entry describes the coverage of the list, not advice on the route for any particular product.

Northern Ireland: EU construction products rules under the Windsor Framework

LAWNI

EU construction products rules apply in Northern Ireland under the Windsor Framework, so Regulation (EU) 2024/3110 was notified to the Assembly as a replacement EU act. The Windsor Framework Democratic Scrutiny Committee held an inquiry in January 2025, reported on 23 January 2025, and concluded that the conditions for the Stormont brake were not met.

Implications

Products for the Northern Ireland market follow the EU regime, including in time the EU digital product passport. A manufacturer selling into both GB and NI may hold two sets of documents for what is otherwise the same product.

Relevance to fire-door products

Because declarations, certificates and identifiers are recorded per product version with their issuer, a GB set and an NI or EU set can sit side by side against the same product without being confused.

Applicability

The precise mechanics of how and when 2024/3110 takes effect in Northern Ireland, including any applicability motion under Article 13(4), were not verified beyond the Committee's report. Confirm with MHCLG or the Assembly's EU law scrutiny tracker before relying on this.

Regulation (EU) 2024/3110: the new EU Construction Products Regulation

LAWEU

The new EU Construction Products Regulation applies from 8 January 2026, except for a list of articles and annexes that applied from 7 January 2025 and Article 92, which applies from 8 January 2027. Article 94 repeals Regulation (EU) No 305/2011 with effect from 8 January 2026, but keeps a long list of its provisions alive until 8 January 2040 for products still covered by the old harmonised standards.

Implications

For EU-facing products this is a long transition rather than a cliff edge: the two regimes run side by side for years. Record which regulation each product follows, because the declaration, the marking and the documentation differ between them.

Relevance to fire-door products

Fire Product Record holds standards, declarations, certificates and identifiers per product version, so products on the old route and products on the new route stay distinguishable in the record and in exports.

Applicability

Dates read directly from the entry-into-force article and Article 94 of the Official Journal text. This regulation also applies in Northern Ireland under the Windsor Framework; see the Northern Ireland entry in the UK tracker.

EU declaration of performance and conformity

LAWEU

Under the new regulation the declaration of performance becomes a declaration of performance and conformity. Articles 13 to 16 cover drawing it up, exemptions, its content and how it is supplied, and Article 15 requires the model set out in Annex V. The declaration is also the first item the digital product passport has to carry, under Article 76(2).

Implications

For EU-facing products the declaration becomes a structured document on a fixed model, and it becomes the anchor of the digital product passport. Holding the underlying data as data, rather than only as a finished PDF, is what makes the later step cheap.

Relevance to fire-door products

Declarations are held as evidence records against a product version, and the underlying claims, characteristics and supporting evidence are held separately, so the same material can be exported in more than one shape.

Applicability

Article and annex numbers read from the Official Journal text. This entry does not attempt to summarise the content requirements of Annex V; read it directly before drafting a declaration.

EU construction digital product passport

LAWEU

Articles 75 to 79 create a construction digital product passport. Article 75 requires the Commission to set the system up by delegated act. Article 76 lists what a passport must contain, including the declaration of performance and conformity, general product information, instructions for use and safety information, technical documentation, the label and unique identifiers, and requires it to be connected to one or more data carriers. Article 79 applies the ecodesign regulation's rules on unique identifiers, data carriers and the passport registry.

Implications

The obligation is time-shifted, not immediate: Article 22(7) gives manufacturers 18 months from the entry into force of the Article 75(1) delegated act to make a passport available, and the system may be used voluntarily in the meantime. The work that pays off now is holding the declaration, instructions, safety information and technical documentation as structured, current records tied to a product identifier.

Relevance to fire-door products

Fire Product Record structures the same underlying material and exports it as versioned JSON. It does not produce an EU digital product passport, it is not connected to the EU system, and its schema is not the EU schema.

Applicability

We did not verify from a primary source whether the Article 75(1) delegated act had been adopted by 2026-09-08; secondary commentary suggests it had not, and points at delegated acts in 2027. Treat the 18-month clock as not started until that is confirmed on EUR-Lex.

EU digital product passport registry (ESPR framework)

LAWEU

The Commission's digital product passport registry went live on 20 July 2026 under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, with a test environment, a user interface and an API. The Commission says the registry will also support product groups covered by other EU legislation that requires passport registration, including construction products. The first registration deadline named is 18 February 2027, for certain large batteries.

Implications

This is the plumbing that the construction passport is expected to reuse: unique identifiers, data carriers and a central registry of identifiers. Nothing is required of construction product manufacturers by this announcement.

Relevance to fire-door products

Context only. Fire Product Record does not register anything with the EU registry and makes no claim of EU passport conformity.

Applicability

Included as context for the EU direction of travel. The ESPR itself is Regulation (EU) 2024/1781; construction products are principally handled under the new Construction Products Regulation rather than under ESPR product rules.

GOVERNMENT COMMITMENT

Government has publicly committed to do it. It is not yet law.

Government response to the Grenfell Tower Inquiry Phase 2 report

GOVERNMENT COMMITMENTUK

The government responded to the Inquiry's Phase 2 report on 26 February 2025. Of the 58 recommendations, 49 are accepted in full and the remainder in principle. A single construction regulator is accepted in principle, but the government says it is not appropriate for that regulator to carry out testing and certification or to issue certificates of compliance, because it would create a conflict of interest.

Implications

Two commitments bear directly on product records: test results relied on when placing a product on the market should be accessible and free of charge, and manufacturers should disclose testing information when the regulator asks. Both assume you can find the test that supports a given claim.

Relevance to fire-door products

Claims are linked to the test, classification or assessment they rest on, and evidence can be marked public metadata or public document, so what is publishable is a deliberate decision rather than an accident of where a file was stored.

Applicability

This is a commitment, not law. The green paper published alongside the response also floated a "Construction Library"; no such library has been legislated or launched.

Removal of the BS 476 national classes from Approved Document B

GOVERNMENT COMMITMENTUK

On 2 September 2024 the government confirmed it would remove the national classes, the BS 476 series, from Approved Document B in England, leaving BS EN 13501 as the single classification route. Reaction to fire and roofs were given a six-month transition, which ran out on 2 March 2025. Fire resistance was given five years, taking it to 2029.

Implications

Fire resistance evidence to BS 476-22 still supports Approved Document B specification for now, but new testing should be planned around BS EN 1634-1 and BS EN 13501-2. A product whose only fire resistance evidence is a BS 476-22 report needs a plan well before the 2029 amendment.

Relevance to fire-door products

Standards are versioned records linked to product versions, and an alert is raised where a product still relies on a standard marked superseded, so a BS 476 dependency can be found across a range rather than one product at a time.

Applicability

Circular 01/2025, published 2 March 2025, describes the 2025, 2026 and 2029 amendments to Approved Document B. The exact day in 2029 was not verified from a primary source. Approved Document B is statutory guidance for England, not legislation, and the position in Wales, Scotland and Northern Ireland differs. BS 476-22:1987 itself remains a current British Standard.

CONSULTATION

Formally consulted on. The outcome is not yet decided, or not yet legislated.

Construction Products Reform Green Paper (2025)

CONSULTATIONUK

The green paper consulted on system-wide reform of the construction products regime, including extending regulation to products with no designated standard, reform of testing and certification, and stronger enforcement. It ran from 26 February 2025 to 21 May 2025 and drew 195 responses. The summary of responses was published on 25 February 2026, alongside the White Paper.

Implications

The green paper is now history rather than live policy, but the summary of responses is worth reading: it records where the sector pushed back, particularly smaller manufacturers asking for phased implementation and proportionate routes.

Relevance to fire-door products

Nothing here is a requirement. It is the origin of the direction of travel that the White Paper and the general safety requirement consultation now set out.

Applicability

Status remains CONSULTATION rather than GOVERNMENT_COMMITMENT: proposals in a green paper are not commitments, and the government's actual response is the White Paper.

Construction Products Reform White Paper (February 2026)

CONSULTATIONUK

The White Paper responds to the green paper and sets out the government's reform package. On information it says construction product information must be made available digitally, that the government will "work with industry to develop digital standards to promote consistency across product information", and that it supports "digital product records, digital identifiers and associated requirements to support traceability". It was itself consulted on from 25 February to 20 May 2026.

Implications

The direction is clear enough to prepare for: structured product information, made available digitally, tied to identifiers. The detail is not settled. Nothing in the White Paper is a legal requirement, and the paper says implementation needs both primary and secondary legislation and is subject to parliamentary time.

Relevance to fire-door products

Getting identifiers, product versions, claims, evidence and publishing decisions into a structured shape is useful work whatever schema is eventually specified. Fire Product Record exports a versioned JSON record and a printable record for that purpose; the schema is ours, not an official one.

Applicability

The consultation closed on 20 May 2026 and no government response or summary of responses had appeared on the consultation page when checked on 2026-09-08. The White Paper page was last updated 30 March 2026.

General safety requirement for construction products (consultation)

CONSULTATIONUK

Published alongside the White Paper, this consultation proposes a proportionate, risk-based general safety requirement for construction products that no designated standard or technical assessment covers. Proposals include a manufacturer risk assessment, product information that is "accurate, up-to-date, clear, legible and in easily understandable language", labelling with the manufacturer's name and address, a unique product identifier and "a data carrier linking the product to its digital product information, e.g., a QR code", and retention of records for ten years.

Implications

If your internal fire doorsets sit outside the designated standard route, this is the regime most likely to reach them. The practical asks are a documented risk assessment, product information kept current, an identifier per product, and records you can still produce a decade later.

Relevance to fire-door products

Identifiers, versioned product information, QR codes that resolve to a published record, and an immutable publication history with a hash are how the software already works. That is preparation, not compliance: none of it is required yet and the final rules may differ.

Applicability

The consultation states an intention to make regulations by the end of 2026 with the requirement in force in late 2027. That is a stated intention, not law. The consultation closed on 20 May 2026 and the page said feedback was being analysed when checked on 2026-09-08. The figure of about 63% of the market refers to products with no designated standard.

EXPECTED

Reasonably expected from official signals, but with no formal commitment behind it.

Unique product identifiers and QR data carriers in the UK

EXPECTEDUK

The White Paper and the general safety requirement consultation point the same way: a unique product identifier, and a data carrier such as a QR code linking the product to its digital product information. Neither is a legal requirement in the UK today, and no identifier scheme has been mandated or endorsed by government.

Implications

Choosing an identifier scheme now carries little risk provided you record which scheme each identifier belongs to and keep it stable across product revisions. Avoid identifiers that encode meaning you may later need to change, such as a supplier or a size range.

Relevance to fire-door products

External identifiers are held per product family or version with their type, issuer and validity, and QR codes are generated against the stable public record address rather than against a document, so the target survives republication.

Applicability

Marked EXPECTED rather than CONSULTATION because the live consultation covers only products outside the designated standard route; a general identifier duty across all UK construction products has not been proposed in that form. There is no UK government identifier registry.

Products critical to safe construction

EXPECTEDUK

The White Paper says all products will be subject to regulatory requirements through one of two routes, a designated standard or the general safety requirement, and lists products critical to safe construction among the reforms that need primary legislation. No list, definition or date has been published.

Implications

If such a category is created, expect more prescriptive requirements on testing, information and traceability for fire-resisting products. Nothing to act on yet beyond keeping evidence and its links to claims in order.

Relevance to fire-door products

The record already distinguishes tested, classified, assessed and certified performance, which is the distinction any higher-risk category is likely to lean on.

Applicability

Our reading that fire doorsets are a likely candidate for such a category is inference, not a government statement. Nothing has been legislated and no timetable has been given.

SPECULATION

Industry commentary or our own inference. Treat it as an opinion, not a plan.

There is no settled UK construction product passport

SPECULATIONUKAwaiting verification

As at the last check there is no UK construction product passport: no published schema, no government registry or API, and no legal duty to produce one. The White Paper describes making product information available digitally and developing digital standards with industry, and it describes the EU digital product passport as part of the EU regime, not the UK one. This entry is our own assessment of the position rather than a government statement.

Implications

Treat any supplier claim of "UK DPP compliance" or an "official UK construction product passport" with caution: there is nothing to comply with yet. What is worth doing is structuring product information so it can be exported into whatever schema is eventually specified.

Relevance to fire-door products

Fire Product Record exports a versioned JSON record under the schema tag fire-product-record/v1. That schema is ours. It is not a government schema and it is not connected to any government or EU system.

Applicability

Marked SPECULATION because it is our inference from the absence of any published UK scheme, not a positive statement by government, and marked inferred because an absence cannot be verified by reading a single source. Re-check whenever a government response to the February 2026 consultations appears.

BSI Identify and the BSI UPIN

SPECULATIONUK

BSI Identify issues a persistent identifier, the BSI UPIN, for construction products using digital object identifier technology, and holds it in a free, enduring, searchable registry where the manufacturer controls the product information. BSI presents it as an answer to the Hackitt review's call for an identification system giving every component a unique and persistent code. It is a voluntary commercial scheme with no regulatory status.

Implications

If you register products, keep the UPIN alongside your internal reference and be clear which product revision it points at. A persistent identifier is only as good as the currency of the information behind it.

Relevance to fire-door products

bsi_upin is one of the identifier types the record supports, stored with its issuer and validity so it sits alongside GTINs, internal references and manufacturer codes.

Applicability

Marked SPECULATION because a voluntary scheme fits none of the four regulatory statuses; nothing here is a legal requirement. The identify.bsigroup.com site could not be fetched because of a TLS certificate chain error, so details come from BSI's own press release. The expansion of the UPIN acronym was not verified from a primary source.

GS1 GTIN and GS1 Digital Link

SPECULATIONINTERNATIONAL

GS1 UK promotes the GTIN as a common product identifier and GS1 Digital Link as a way of carrying that identifier in a QR code that resolves to a web address, optionally with batch or serial data. GS1 UK ties this to the Building Safety Act 2022 and the golden thread of information. These are voluntary industry standards with no status in UK construction product law.

Implications

Merchants and contractors increasingly ask for GTINs as a commercial condition. If you hold GTINs, record them against the product they identify rather than in a spreadsheet, and decide deliberately whether a QR code should resolve to a product record or to one specific revision.

Relevance to fire-door products

gtin is a supported identifier type, and generated QR codes resolve to the stable public record address, so the code printed on a label keeps working as new revisions are published.

Applicability

Marked SPECULATION for the same reason as other voluntary schemes. gs1.org returned HTTP 403 when fetched, so the GS1 UK pages were used instead. Nothing here is required by UK law.

Questions we get asked

Does the UK require Digital Product Passports for construction products?

No. There is no requirement in the law of Great Britain for a construction product to carry a digital product passport, and no published UK schema or register. The requirement people are usually thinking of is an EU one. Where an entry below describes an EU instrument, its jurisdiction says so.

Is a QR code on a construction product required by law?

Not in Great Britain. The Construction Products Regulation as it applies here requires identification and accompanying information; it specifies no data carrier. A data carrier does appear in the EU regime, and specifiers and certification schemes may ask for one contractually.

Why do the statuses matter so much?

Because most confusion in this area comes from treating a proposal as a duty. A consultation is not a commitment, a commitment is not a law, and a trade-press prediction is neither. Every entry here carries exactly one status and the source it came from.

How often is this updated?

Each entry shows the date we last checked its source. If an entry has not been checked recently, that is visible rather than hidden. Nothing here is a substitute for reading the source yourself.

Get the underlying data in order

Whatever the UK settles on, it will ask about identity, version, declared performance, supporting evidence and scope. That work is useful now.

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