ZEPHIR

Construction Products Regulation 2024: assess applicability for each product family before any prospecting

6 min read

The main part of the 2024 Construction Products Regulation has applied since 8 January 2026, but product families migrate individually after a new harmonised standard is cited. For suppliers, this phased timetable creates different commercial situations depending on the product, standard, use and coexistence period.

A shared timetable, separate migrations

8 January 2026 marks the application of the main part of the regulation. However, this date does not mean that all product families immediately fall under the new framework. Each family migrates individually following the citation of a new harmonised standard. The situation must therefore be assessed product by product.

A coexistence period may apply depending on the relevant product family. This coexistence may continue until 2039, but this is not the same deadline for all products. The cited standard and applicable period must be verified for each product reference. A general reading of the timeline is not sufficient to determine the position of a manufacturer or integrator.

The new framework provides for environmental characteristics and a digital passport. Whether they apply depends on the product family's effective migration to the new framework. Manufacturers must therefore link these matters to an identifiable family and standard rather than treat them as a uniform development across the entire sector.

Qualification must start with the product and its use

Being part of the construction sector is not, in itself, enough to conclude that a company is directly affected. The purchased or manufactured reference, its product family, the cited standard and its use must be identified. The coexistence period must also be established. This qualification distinguishes a current situation from a migration that is still to come.

The same principle applies to downstream integrators. A manufacturer of systems, facades, windows, networks, insulation or building equipment may incorporate a component belonging to an identifiable family. Its exposure then depends on the component, standard and use concerned. The mere presence of its products in construction is not sufficient to qualify the requirement.

Commercial preparation must therefore begin with a precise product analysis. Segmentation based solely on sector or material remains insufficient. It must be supplemented by the reference, family, cited harmonised standard, applicable coexistence period and end use.

The offers and buyers to target

Several categories of suppliers may be relevant. These include foundries manufacturing parts or products for construction, as well as manufacturers of metal components incorporated into construction products. Extruders and plastics manufacturers may also serve these applications. Manufacturers of profiles and composite components for construction and infrastructure complete this scope.

Potential buyers include manufacturers of systems, envelopes, networks or building equipment that purchase cast parts. They may also be facade contractors, industrial joinery companies, main contractors or construction product integrators. Manufacturers of windows, facades, networks and insulation solutions are also among the companies to qualify. For components intended for infrastructure, system manufacturers and infrastructure companies may be targets.

The contacts indicated by this signal are primarily technical management, procurement managers and product managers. The choice of contact depends on the component's role in the system being purchased or manufactured. Qualification must link the supplier's offering to a specific product line and to the buyer's role in the decision.

What this changes for suppliers

The regulation's phased application may create needs among manufacturers and integrators preparing to migrate a product family. It may also lead a buyer to reassess the components it integrates and the associated information. However, this development does not prove that a supplier panel is open. Existing approved suppliers may absorb the requirement.

Before any discussion, we recommend checking the purchased part, whether the supplier panel is open and the supplier's civil-sector capabilities. The product family, cited standard, coexistence period and use must be confirmed in parallel. Qualification based solely on the sector, material or a programme cannot establish a commercial opportunity. At most, it indicates potential alignment with the requirement.

Prospecting must therefore start from a specific integration case. The supplier must be able to show which component it manufactures, which product it is integrated into and which type of buyer can assess it. Contact with technical management, procurement or the product manager becomes relevant once these points have been established. This method concentrates commercial effort on companies whose product family and standard can be identified.

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