Construction products reform, and what goes into your buildings

Ask a building manager what their building is made of and you will usually get an answer at the level of a category. Cladding. Insulation. Fire doors. Sealant.

Ask which product, by which manufacturer, to which specification, installed when and by whom, and the answer thins out quickly.

That gap is the subject of the reform now working its way through government, and it is worth understanding before it arrives.

Two thirds of the market sits outside the regime

The Construction Products Regulations only bite on products for which a designated standard exists. Everything else is, in regulatory terms, unregulated.

The scale of that is larger than most people assume. MHCLG's central estimate is that around 37% of the UK construction products market is covered by the current regime. The Morrell-Day Review put it more bluntly, estimating that roughly two thirds of construction products on the market fall outside it altogether.

This is not a loophole for obscure items. It covers ordinary things that decide how a building behaves in a fire or in weather, simply because no designated standard happens to exist for them.

What the White Paper proposes

The government published the Construction Products Reform White Paper on 26 February 2026, following the Green Paper of February 2025 and the response to the Grenfell Tower Inquiry Phase 2 report. The consultation ran for twelve weeks and closed on 20 May 2026. Legislation is expected to follow.

The central proposal is a risk-based General Safety Requirement. Rather than regulating only products that have a standard, the GSR would apply a duty across all construction products, proportionate to the risk each one carries. A product with no designated standard would no longer be a product with no obligations.

Alongside it, the White Paper sets out stronger enforcement, clearer allocation of responsibility along the supply chain, and a long-term direction towards a single construction regulator.

The part that is easy to miss

Most of the commentary has focused on manufacturers, testing houses and certification bodies, which is reasonable. That is where the failures documented at the Inquiry sat.

But the White Paper also makes digitalisation and traceability structural rather than optional. Product information is to be available digitally against common standards, with identifiers and traceability requirements intended to make it possible to work out where a product went and who is accountable for it. The government has said it intends to stay aligned with the EU's digital product passport work where that suits its own objectives.

Traceability only works if somebody at the far end of the chain is holding the record. For a building in occupation, that somebody is the person managing it.

The question this is really about

Strip the policy language away and the reform is trying to make one question answerable: if this product turns out to be unsafe, which buildings contain it.

Today that question is usually answered by a fire drill. Somebody sends an email round, somebody else goes through a filing cabinet or a folder of handover PDFs, and a surveyor is booked to go and look. It takes weeks, and the answer is a probability rather than a fact.

The reform does not fix that for buildings already standing. New duties on manufacturers do not retrospectively populate your records. What changes is the expectation. Once product identifiers and digital declarations are normal at the point of supply, "we do not hold that information" reads differently than it does now.

What is worth doing this year

None of this requires waiting for the legislation. The work is clerical, cheap, and almost entirely about capture discipline.

Record products at the level they are sold. Not "insulation" but the manufacturer, the product name and the specification, with the batch or reference where it exists. A category is not a record. A product with a name is.

Capture at the point of works, not by survey afterwards. The cheapest moment to know what went into a building is the week it went in, while the contractor is still on site and the delivery notes still exist. A retrospective survey five years later costs more and tells you less.

Keep the evidence that comes with the product. Declarations of performance, test certificates, fire classifications, installer competence records and guarantees. These arrive as paper or PDF at handover and are the first thing to be lost at a change of managing agent.

Tie the product to a place. "Fire doors, type X" is useful. "Fire doors, type X, floors 4 to 9, north core" is what you need when a safety alert names a specific product and you have to scope the work.

Treat the handover pack as a starting point, not an archive. It is the single largest source of product information most managers will ever receive, and it is usually filed once and never queried again.

Where this sits in SAMRISK

Product records are the part of the golden thread most likely to be missing, because they are created by somebody else during works and handed over once.

Construction products and their specifications sit in materials as properties of the building, so what a building is made of is a field you can query across a portfolio rather than a line in a survey PDF. Declarations of performance, test certificates, fire classifications and guarantees belong in documents, attached to the property and to the material rather than to the year they arrived.

Installed products with a service life, a specification and an inspection interval behave like assets, so they sit in items with the servicing running as recurring work in maintenance. Where a product is installed or replaced during works, the record is created alongside the job in contractors and permits, which is the point at which the delivery note and the installer sign-off actually exist. Location comes from building plans, so a product is tied to a floor and an elevation rather than to the building as a whole.

The periodic sweep that checks the record still matches the building runs as an audit, remediation from a safety alert is a task with an owner and a date, and for a higher-risk building the whole picture feeds the safety case.

The point

The White Paper is aimed at the people who make and sell construction products, and that is where it will bite hardest.

The consequence for everyone else is smaller and more permanent. The direction of travel is that a building's materials become data, held against the building, expected to be current, and expected to be produced on request.

Nobody is going to ask you for it this year. The buildings where the answer exists in 2030 will be the ones where somebody started writing it down while the contractor was still on site.

Sources: Ministry of Housing, Communities and Local Government, Construction Products Reform White Paper, published 26 February 2026, GOV.UK, consultation open 25 February 2026 to 20 May 2026; MHCLG, Construction Products Reform Green Paper 2025, GOV.UK, for the estimate that around 37% of the UK construction products market is covered by the current regime; Independent Review of the Construction Products Testing Regime (Morrell-Day Review), 2023, for the estimate that around two thirds of products fall outside it; Grenfell Tower Inquiry Phase 2 report and the government response, 2025.