Summary
UK Government is currently inviting industry feedback on two major construction products reform consultations:
On 29th April, ASBP held an online workshop with its members to explore the proposals in detail and allow for discussion among ASBP members about the potential implications for the sector and how the industry might respond to the consultation.
ASBP has since submitted responses to both consultations which we will share in full later this month. We are urging all members to respond before the deadline on 20th May (11:59pm).
Note – You do not need to answer every question. A focused response covering the issues most relevant to your work will carry real weight.
This summary briefing covers: what ASBP said, why it matters to you, and exactly which questions to answer depending on your area of work.
Background: what is being consulted on?
Two consultations are open simultaneously:
The Construction Products Reform White Paper sets out the government’s policy direction for a wholesale redesign of UK construction products regulation. It proposes a new risk-tiered framework, a single construction regulator, stronger enforcement, and new environmental performance requirements. It has 11 questions.
The consultation on the General Safety Requirement for Construction Products (GSR) covers the detailed legal framework for all products not covered by a designated standard. This is the majority of construction products, including most bio-based, natural, surplus, reused, remanufactured and innovative sustainable materials. It has 21 questions.
Both are a direct consequence of the Grenfell Tower Inquiry Phase 2 Report and will affect everyone who manufactures, imports, distributes, specifies or installs new, surplus and/or reused construction products in the UK.
ASBP’s key positions: CPR White Paper
EPDs – We are calling for a mandatory trajectory with proper support. The White Paper proposes voluntary use of EN 15804+A2 as the EPD methodology for products not covered by a designated standard. We consider voluntary guidance alone insufficient. ASBP is calling for a published timetable transitioning to mandatory EPDs for all construction products, with a supported voluntary period of five to seven years. Support must include subsidised EPD production for SMEs, industry-average EPD programmes for product categories without them, access to reduced-cost tools, and dedicated training. We also called for specific guidance on EPDs for bespoke and made-to-measure products.
Enabling reuse – The policy objective to have safer construction products is, of course, correct. However, the mechanisms proposed unintentionally undermine another government objective. With commitments to reduce carbon emissions, transition to a circular economy and a target of net zero by 2050, the CPR and GSR need to consider in more detail the impact of a broad-brush reform where surplus and reused products are dealt with in the same way as new. Our responses therefore reflect the need for any reforms to be proportionate and supportive of innovation.
Accountability gaps need filling – We identified four areas where accountability is currently unclear: previously used products and the reuse supply chain; product substitution on site; online marketplace operators; and bio-based and innovative products without established test methodologies. In each case, the White Paper either creates an enforcement gap or risks placing an unfair burden on the wrong party in the supply chain.
The national testing facility must serve the whole market – We support the proposed national testing and research facility but called for it to explicitly include capacity for bio-based and natural materials testing, affordable access for SMEs, and development of test methodologies for novel sustainable products where current standards were not designed with these materials in mind. We also called for access to the facility for higher-risk reused products where some indicative retesting may be required.
SME transition support must be substantive – The cumulative compliance burden of new obligations (risk assessments, EPDs, product information systems, labelling and digital records) will be significant for small manufacturers. ASBP called for a full package of support measures and for transition periods that reflect the time genuinely needed to build compliance capability.
ASBP’s key positions: GSR
The reuse sector needs its own compliance pathway – ASBP does not agree that previously used products should face identical obligations to new products. Applying full GSR risk assessment requirements to salvage operators and reuse businesses is in many cases technically impossible and in most cases financially unfeasible, and would significantly obstruct circular economy activity. Compliance needs to be through reuse-specific guidance and assessments appropriate to the product type and intended use. Economic operators are referenced in both the CPR and the GSR. We called for a distinct “reuse economic operator” framework with proportionate obligations, and for a dedicated government working group to develop it before the regulations are finalised.
Bio-based and novel materials need explicit provision – The GSR’s risk assessment framework assumes conventional product categories and established test methods. For manufacturers of bio-based, natural or innovative materials, that assumption frequently does not hold. We called for specific guidance, explicit provision for alternative evidence pathways, and a commitment that the national testing facility includes bio-based materials assessment capacity.
Supply chain obligations are right, but guidance must follow – The proposals on importers, distributors and merchants are broadly appropriate. We called for merchant-specific guidance, clear liability frameworks that protect good-faith operators, and practical record retention guidance for SMEs.
Enforcement must be credible, proportionate and transparent – We support civil monetary penalties, cost recovery and undertakings as an alternative to prosecution. We asked for penalties calculated as a proportion of turnover for large operators, a publicly accessible enforcement register, and an independent appeals process accessible to businesses without legal representation.
Which questions should you respond to?
You do not need to answer every question. Focus on the areas most relevant to your business. Your direct experience of the market is what makes your response valuable.
Bio-based and natural materials manufacturers and specifiers
White Paper: Q1 (guidance for critical products), Q3 (national testing facility), Q6 (EPDs and non-designated standard products), Q7 (accountability gaps), Q9 (sequencing), Q11 (any other information). GSR: Q2 (overarching safety duty), Q3 (risk assessment proportionality), Q4 (product information criteria).
Reuse, salvage and circular economy supply chains
White Paper: Q7 (accountability), Q9 (sequencing and reuse provisions), Q10 (costs and benefits, specifically circular economy impacts). GSR: Q1 (previously used products, the most important question for this sector), Q3 (risk assessment), Q4 (product information for reused products), Q6 (record retention), Q13 (storage and transport obligations).
SME manufacturers
White Paper: Q1 (guidance content), Q3 (national testing facility and affordable access), Q6 (EPD support), Q8 (transition periods), Q10 (costs and benefits). GSR: Q3 (risk assessment proportionality), Q6 (record retention), Q14 (post-market monitoring), Q17 (civil monetary penalties and SME proportionality).
Distributors and merchants
White Paper: Q7 (accountability), Q8 (transition periods). GSR: Q10 (distributor obligations), Q11 (record retention), Q15 (duty to cooperate with enforcement).
Specifiers and principal designers
White Paper: Q1 (guidance on critical products), Q7 (accountability for substitution on site). GSR: Q4 (product information to support specification decisions).
Testing, certification and standards bodies
White Paper: Q2 (CAB licensing), Q3 (national testing facility), Q4 (partnership models for testing capacity).
Respond now
Deadline: Wednesday 20 May 2026 at 11:59pm.
Respond to the White Paper: https://consult.communities.gov.uk/building-safety/construction-products-reform-white-paper
Respond to the GSR: https://consult.communities.gov.uk/building-safety/consultation-on-the-general-safety-requirement
If you have questions or would like to share your own response with ASBP, contact richard@asbp.org.uk.