Consultation outcome

Construction Products Reform Green Paper: summary of responses

Updated 25 February 2026

Introduction

This document provides a consolidated summary of the analysis of responses to the Construction Products Reform Green Paper consultation. It outlines key points for individual questions and overall themes. In addition, it provides quantitative data on consultation respondents, including overall response number, types of respondents, size of respondent organisation, and a list of national representatives and trade bodies / associations that responded.

This consultation summary has been published alongside the Construction Products Reform White Paper, which responds to the Construction Products Reform Green Paper consultation.

Overview of consultation responses

The consultation was open for 12 weeks, running from 26 February 2025 to 21 May 2025. It contained 58 questions, including 29 Yes/No questions. Responses were received via online survey and email.

The consultation received 195 responses overall. 157 responded on behalf of organisations with 38 respondents answering in a personal capacity. Some respondents answered consultation questions only, some respondents provided a general narrative response only without answering any consultation questions, and some responses which were a combination of the two.

In addition, we reached more than 750 representatives through our engagement programme during the period of consultation.

Table 1: Number of respondents by profession

Types of Respondents	Number (Organisations)	Number (Personal Capacity)
Architectural	4	5
Builder/Contractor	4	0
Building Control Approved Inspector/Registered Building Control Approver	1	1
Central Government	2	0
Commercial/Procurement	0	1
Conformity Assessment Body	9	3
Designer	1	7
Developer	1	0
Distributor	2	0
Housing Association	1	0
Installer/Subcontractor	1	0
Local Authority/Local Government/Regional Government	7	2
Manufacturer	34	7
National Representative or Trade Body/Association	48	1
Professional Body or Institution	8	1
Regulator	1	0
Research/Academic Body or Institution	1	3
Technical Assessment Body	4	0
Other	28	4
Not Applicable	0	3

Table 2: Size of organisations that responded (excludes those who responded in a personal capacity)

Size of Organisation	Number	Percentage
Large (250+ Employees)	56	35.7%
Medium (50-249 Employees)	27	17.2%
Small (10-49 Employees)	31	19.7%
Micro (1-9 Employees)	25	15.9%
Not Answered	18	11.5%

Table 3: List of national representatives and trade bodies /associations that responded

• Approved Cables Initiative
• Association of Specialist Fire Protection
• Bathroom Manufacturers Association (BMA)
• BEAMA
• British Cables Association
• British Constructional Steelwork Association
• British Plastics Federation
• British Plastics Federation - Pipes Group
• British Woodworking Federation
• Build UK
• Building Engineering Services Association (BESA)
• Buildings Merchant Federation
• Ceramics UK
• Chartered Institute of Architectural Technologists
• Chartered Trading Standards Institute (CTSI)
• Construction Leadership Council (CLC)
• Construction Products Association (CPA)
• Council for Aluminium in Building
• Door & Hardware Federation
• Electrical Contractors’ Association (ECA)
• Electrical Distributors’ Association
• Energy and Utilities Alliance (EUA)
• Engineered Panels in Construction (EPIC)
• European Fire Sprinkler Network
• European Resilient Flooring Manufacturers’ Institute
• Federation of Environmental Trade Associations
• Glass and Glazing Federation
• Guild of Architectural Ironmongers
• Gypsum Products Development Association
• Industry Competence Steering Group (ICSG)
• Insulation Manufacturers Association
• Mineral Products Association (MPA)
• Mineral Wool Insulation Manufacturers Association (MIMA)
• National Federation of Roofing Contractors
• National Fire Chiefs Council (NFCC)
• Single Ply Roofing Association
• Stove Industry Association
• The Alliance for Sustainable Building Products
• The Architectural and Specialist Door Association (ASDMA)
• The British Measurement and Testing Association (BMTA)
• The Finishes and Interiors Sector (FIS)
• The Lighting Industry Association (LIA)
• The Rooflight Association
• Thermal Insulation Contractors Association
• Timber Development UK
• UK Resilient Flooring Association (UKRFA)
• UKGBC Limited
• Wood Panel Industries Federation

How we approached our analysis in this summary

This document provides a summary of the consultation responses received. It does not attempt to capture every point made.

Quantitative analysis of individual questions is based on 187 responses and does not include responses from eight who provided narrative feedback on themes or chapters. However, their comments were included in the thematic qualitative analysis and overall response number.

A number of respondents chose not to answer some Yes/No questions. For the statistical summary we set out both the breakdown based on the overall number of respondents and the breakdown based on only those who responded to the question, excluding those that did not answer.

Some respondents provided qualitative responses to Yes/No questions, but did not provide a yes or no. These responses have been captured in the “qualitative response only” category.

Consultation general analysis

Sector-wide problem recognition

Overall analysis indicated that the sector keenly recognises the systemic problems in the construction products industry and understands its inherent complexity. Concurring with the problem definition set out in the green paper, a number of respondents defined the present regulatory framework as fragmented, with disjointed overlapping responsibilities and inconsistent enforcement, creating gaps in accountability. A number noted that the result has been a failure to ensure safe products, or to hold those who fail to meet expected standards to account. It was also roundly acknowledged that these and wider failures are prevalent, spanning the entire construction product lifecycle. This recognition of the widespread problems, fragmented regulation and gaps in accountability were also highlighted by stakeholders we engaged with during the consultation.

System-wide problems

System-wide concerns raised by respondents included:

• The insufficient regulatory coverage of products, with respondents pointing to gaps where key products fall outside of the regulatory regime, resulting in potential safety risks.
• The sector’s over-reliance on Conformité Européenne/UK Conformity Assessed (CE/UKCA) marking (frequently misunderstood as indicating safety when they signify compliance with standards that support harmonised trade).
• The frequent use of misleading product information by manufacturers, and the implications of this for appropriate specification and safe use.
• A lack of enforcement by regulatory bodies, owing to limited capacity and resources, which allows non-compliant and unsafe products to remain on the market. Linked to this respondents cited the need for transparent, unambiguous and timely guidance from regulators.
• The widespread lack of competence across the supply chain, and an associated culture of prioritising cost over safety and quality, which acted as major contributory factors to unsafe practices. This was also emphasised during engagements, with stakeholders calling for structured training and career development to help address competence, especially for small and medium-sized enterprises (SMEs) and those in specialised sectors.
• The fundamental issues around testing and certification, including a lack of transparency, inconsistent methods, and the use of ‘golden samples.’ They stressed that this, alongside the danger that commercial interests compromise testing bodies, heavily undermined the integrity of testing and certification.
• The need to improve the traceability, transparency, and lifecycle management of construction products, through use of digital product passports and machine-readable data. During engagement participants highlighted issues with industry’s level of preparedness for digital product passports.

Broad support for reforms

Responses suggested that there is clear support for reform across the sector: from manufacturers, trade bodies/associations, representatives of key professional bodies and those in the testing and certification regime.

Respondents made key asks, including:

• Stronger, clearer, and more enforceable regulations.
• Independent oversight of testing and certification.
• Mandatory, risk-based testing for products critical to safe construction.
• Publicly accessible databases of test results and product performance data.

Implementing reform

There was apprehension from some stakeholders about over-regulation and the potential for this to stifle innovation and efficiency. These stakeholders advocated for a balanced, risk-based approach to regulation.

To allow for this and wider change, almost all key industry bodies responding to the consultation and participating in engagement, showed a readiness to support taking forward reforms. Many expressed commitment to ongoing collaboration with government and wider industry stakeholders, to shape a regulatory system that is clear, proportionate, and resilient.

Respondents also outlined the need for a systems-based approach to reform. Emphasis was placed on assessing safety in context, including looking at how products interact within systems rather than considering them in isolation.

Respondents identified implementation as critical. They highlighted the need for this to be done without undue delay, but for the introduction of obligations to be phased, costed and realistic to avoid overwhelming the sector. During green paper engagement, representatives from across the sector called for continued collaboration between government and the construction industry to ensure progress.

Chapter 2: An overview of the problems

Question 1

Do you agree with this problem definition? (As set out in Chapter 2) [Yes/No]. Please explain your answer.

154 respondents provided a response to this question. 33 respondents did not provide a response.

Question 1	No. Of Responses	% of all Respondents	% of Ques. 1 respondents
Yes	130	69.5	84.5
No	19	10.2	12.3
Qualitative Response Only	5	2.7	3.2
Not Answered	33	17.6	-

Many respondents emphasised that systemic failures had caused the Grenfell Tower tragedy rather than just individual faults. Some were keen to emphasise that not all actors within the industry operated like those identified during the Grenfell Tower Inquiry Phase 2 Report and that there were responsible actors in the industry.

Respondents also stressed the complex nature of buildings. Whilst provision can be made for the safety of construction products, how they are used and the safety of buildings depends more on the architects, engineers and tradespeople who are doing the building.

Many respondents highlighted the widespread lack of competence across the supply chain which undermines safety. Respondents also underlined the culture of prioritising cost over safety.

Respondents referred to the current regulatory framework as disjointed, with overlapping responsibilities and inconsistent enforcement, leading to confusion and gaps in accountability.

Respondents said that regulatory bodies often lack the capacity, resources, or will to enforce standards, allowing non-compliant or unsafe products to remain on the market unchecked. Notably, this was underlined by some manufacturers.

Question 2

Are there particular functions that the sector does well that should be protected or encouraged? [Yes/No]. Please explain your answer.

140 respondents provided a response to this question. 47 respondents did not provide a response.

Question 2	No. Of Responses	% of all Responses	% of Ques. 2 respondents
Yes	107	57.3	76.4
No	21	11.2	15.0
Qualitative Response Only	12	6.4	8.6
Not Answered	47	25.1	-

Many respondents regarded third-party certification and accreditation as essential for product safety and performance assurance, especially in fire protection and structural applications.

The Code for Construction Products Information (CCPI) was frequently cited as a positive initiative promoting transparency, accuracy, and accountability in product information. Many recommended further support for CCPI and mentioned that increased uptake would be positive for the sector.

Several respondents also referred to innovation and sustainability, highlighting that the sector excels in developing sustainable materials and that it maintains effective reporting systems for sustainability, including Environmental Product Declarations (EPDs) and Life Cycle Assessments (LCAs). It was commonly highlighted that these efforts support net-zero goals and should be incentivised.

Industry-led training initiatives and competence frameworks were also frequently referred to by respondents as improving installer and specifier knowledge. Respondents underlined that continued support for these programmes is vital for safety and quality.

Chapter 3: Our vision of reform

Question 3

What, if any, other potential overlapping rules, regulations or guidance should we consider when designing the construction products regulatory regime?

134 respondents provided a response to this question. 53 respondents did not provide a response.

Many respondents supported aligning UK regulations with EU Construction Products Regulation (EU-CPR), International Organisation for Standardisation (ISO), and international standards to avoid duplication, reduce trade barriers, and ensure clarity.

Respondents called for consolidation of overlapping regulations (for example, Building Safety Act, Construction (Design & Management), REACH, CE/UKCA marking) to streamline compliance and reduce confusion. For example, some (including manufacturers) highlighted contradictions between building regulations, certification schemes and designated standards.

Many respondents also highlighted that clear guidance and phased implementation are critical to avoid disruption.

There was an emphasis on competence across all roles—procurement, specification, installation, and maintenance. Respondents highlighted that national training schemes and Continuous Professional Development (CPD) are needed to ensure informed decision-making and safe substitutions.

Mandatory third-party certification and independent oversight (for example, UK Accreditation Service (UKAS), CCPI) were widely recommended by respondents.

Chapter 5: Scope and definitions of reform

Question 4

Do you agree that the UK should adopt a definition that is consistent with the revised The EU Construction Products Regulation (EU-CPR), for construction products in the UK regulatory regime? [Yes/No]. Please explain your answer.

150 respondents provided a response to this question. 37 respondents did not provide a response.

Question 4	No. Of Responses	% of all Responses	% of Ques. 4 respondents
Yes	134	71.7	89.3
No	9	4.8	6.0
Qualitative Response Only	7	3.7	4.7
Not Answered	37	19.8	-

There was broad support for aligning the UK’s definition with the revised EU-CPR to ensure consistency, reduce trade barriers, and simplify compliance.

A number of responses specifically referenced or alluded to the need to avoid divergence with the EU, and the potential negative impacts of divergence, such as increased complexity, costs, and reduced competitiveness.

There were positive references to trade with the EU and/or supporting supply chains, which would be aided by a consistent definition.

There were, however, a significant number of responses which highlighted potential risks to adopting the EU regime. These included the potential exclusion of product systems and potential inclusion of products which do not have a functional impact on a building’s performance. They also noted a range of caveats to consistency, such as avoiding additional cost burdens to UK manufacturers, the need to ensure clarity of responsibilities, and whether there was a need to go further than the EU to ensure a sufficient focus on safety.

Question 5

Is there a need to further clarify the regulatory approach to systems of products and or Modern Methods of Construction (MMC)? [Yes/No]. Please explain your answer and propose any additional clarifications.

140 respondents provided a response to this question. 47 respondents did not provide a response.

Question 5	No. Of Responses	% of all Responses	% of Ques. 5 respondents
Yes	123	65.8	87.9
No	9	4.8	6.4
Qualitative Response Only	8	4.3	5.7
Not Answered	47	25.1	-

A significant proportion of responses demonstrated strong support for the requirement for clearer definitions, especially regarding what constitutes a “system,” “kit,” and “product”.

Responses highlighted the need for clarity on responsibilities and liabilities throughout the supply chain for product systems. For example, product systems may comprise of products spanning multiple manufacturers who may not have intended, or be aware that, their products would be incorporated into these systems.

Another strong theme that emerged is the need for either dedicated testing for product systems or to take a holistic approach to ensuring product safety within systems. This reflects views expressed that individual product testing is insufficient and that interactions between components can significantly affect performance.

Another theme was building regulations and the Approved Documents. Some respondents noted the need to ensure a clear distinction between construction product regulations and building regulations concerning products and systems used in construction. Current building regulations and guidance were noted as being suited to traditional construction techniques and insufficient with regard to Modern Methods of Construction (MMC).

Some respondents also noted a lack of industry competence, including installation skills, and the impact that this can have on safety. They called for improved documentation to provide more information regarding specification, installation, maintenance and educational initiatives.

Question 6

Does the proposed definition of ‘economic operator’ (as set out in Chapter 5) capture all of those who are responsible for ensuring that products are safe when they are placed on the market? - Please explain your answer.

143 respondents provided a response to this question. 44 respondents did not provide a response.

Question 6	No. Of Responses	% of all Responses	% of Ques. 6 respondents
Yes	87	46.5	61.3
No	43	23.0	30.3
Qualitative Response Only	13	6.4	8.5
Not Answered	44	24.1	-

There was broad support for the definition of ‘economic operator’ proposed in the green paper. However, many respondents took a wide-ranging approach to answering this question, offering views on who should be subject to duties after the product has been placed on the market. Of those, the most common theme was the need to ensure full coverage of duties and obligations throughout the journey of a product, with many referencing the need to ensure that obligations are placed on designers, specifiers and installers.

A number of respondents considered that online marketplaces were an omission from the definition that needed to be rectified.

Several respondents considered that there was a lack of awareness and understanding of the term ‘economic operator’ at present. Some stated that economic operators may not be aware that they had taken on responsibilities under the existing regulations, for example where products are rebranded and the responsibilities pass from one to another.

A small number called for guidance or illustrative examples to aide understanding, such as when products are reused.

Chapter 6: Product requirements – a regulatory approach based on safety risk

Products to be covered by a general safety requirement

Question 7

Would the approach detailed above enable a proportionate approach to regulating the safety of products not covered by a designated standard or subject to a technical assessment?

148 respondents provided a response to this question. 39 respondents did not provide a response.

Question 7	No. Of Responses	% of all Responses	% of Ques. 7 respondents
Yes	100	53.5	67.6
No	39	20.9	26.0
Qualitative Response Only	9	4.8	6.1
Not Answered	39	20.9	-

The majority of respondents supported the proposal to introduce a general safety requirement for products not covered by a designated standard or subject to a technical assessment. Manufacturers and industry stakeholders supported introducing a risk-based general safety requirement (GSR) to address regulatory gaps, especially for products not covered by designated standards. They emphasised the need for the GSR to be proportionate to risk.

Manufacturers and certification bodies expressed concern about over-reliance on self-declared compliance, advocating instead for third-party certification, particularly for high-risk products, citing examples from Germany (Deutsches Institut für Bautechnik - DIBt) and France (Avis Technique).

Importers, distributors and installers highlighted confusion around their regulatory responsibilities, calling for clearer definitions and structured accountability frameworks. There were widespread calls across the sector for consistent guidance and centralised oversight from government.

Technology providers and larger construction firms strongly endorsed the use of digital tools like product passports and unique identifiers, viewing them as essential for managing lifecycle data, improving transparency, and enabling timely safety updates

SMEs, which dominate the construction product supply chain, voiced concern about navigating complex new requirements. They requested phased implementation, training, and proportionate compliance pathways to ensure they’re not disproportionately burdened by reforms.

Question 8

What are the implications, if any, that could arise from introducing obligations on importers and distributors to check product information and associated responsibility for the storage and transportation of construction products under a General Safety Requirement (GSR)?

114 respondents provided a response to this question. 73 respondents did not provide a response.

There was widespread support, from manufacturers and regulators, for clearly defined, shared responsibilities across the supply chain under a GSR, including the need for third-party certification and robust enforcement mechanisms.

Concerns were expressed from importers and distributors about their technical capacity to ensure compliance, with calls for mandatory training and sector standards to boost competence

High importance was placed on logistics – distributors and suppliers stressed the impact of environmental factors on product safety, highlighting the need for clear guidance on proper storage and transportation methods.

There was strong backing from respondents for digital tools like product passports and traceability systems from tech providers and larger firms, with emphasis on using international standards to maintain the “golden thread” of product information.

There was widespread support, from manufacturers and regulators, for clearly defined, shared responsibilities across the supply chain under a GSR, including the need for third-party certification and robust enforcement mechanisms.

Concerns were expressed from importers and distributors about their technical capacity to ensure compliance, with calls for mandatory training and sector standards to boost competence

SMEs and trade groups raised concerns about compliance costs and market consolidation, urging phased implementation, targeted financial support and safe harbour protections to help smaller businesses adapt.

Products covered by a designated standard: The role of technical assessment

Question 9

What role should technical assessment play in a future regime?

135 respondents provided a response to this question. 52 respondents did not provide a response.

A large number of respondents supported the continued use of technical assessments (TAs), for products not covered by designated or harmonised standards. Respondents viewed TAs as an important mechanism for ensuring safety, performance, and regulatory compliance—especially for innovative or bespoke products.

Many highlighted the role of TAs in supporting innovation and facilitating market access, including UKCA and CE marking. Several noted that TAs offer a flexible and structured route to compliance, particularly for complex systems such as MMC and fire doors.

There was widespread support for reform of technical assessments. The most common recommendation was to establish a UK equivalent to the European Organisation for Technical Assessment (EOTA) to coordinate TABs and standardise processes. Many also called for mutual recognition of EU European Assessment Document (EADs) and European Technical Assessment (ETAs), mandatory use of TAs for products critical to safe construction, and greater standardisation and transparency.

Some respondents also recommended integrating TAs with digital product passports and expanding their scope to include environmental and site-specific performance. Others called for stronger oversight and clearer competency requirements for assessors.

The approach to products critical to safe construction

Question 10

What requirements should apply to products and systems that are critical to safe construction? - Please explain your answer.

144 respondents provided a response to this question. 43 respondents did not provide a response.

There was strong consensus that installers of products critical to safe construction must be properly trained under approved schemes and operate in controlled environments. Many respondents advocated for third-party certification (e.g., Assessment and Verification of Constancy of Performance 1+ (AVCP 1+)) that includes ongoing surveillance, production control, and periodic retesting.

Several respondents emphasised the need for a clear, nationally regulated definition of “products critical to safe construction.” Some called for the national regulator to oversee certification schemes and enforce compliance.

There was significant support for testing not just individual products but entire systems, including assessments of long-term performance, maintenance needs, and material degradation over the product lifecycle.

Some responses stressed the importance of validating product compatibility with adjacent materials and ensuring system-level performance. There were also many calls to strengthen the link between building regulations and guidance, with legal consequences - including criminal proceedings - for non-compliance.

Several respondents strongly supported making all product data, such as test results, limitations, and installation instructions, publicly accessible and auditable. Suggestions included using digital product passports and a centralised construction products library to enhance traceability and transparency.

Obligations across all products on how they are selected and installed

Question 11

What types of requirements could be placed on those responsible for building works to enable them to meet safety obligations in relation to the specification, selection and installation of construction products?  Please explain your answer

142 respondents provided a response to this question. 45 respondents did not provide a response.

The majority of respondents stressed the need for mandatory training and competency frameworks for all roles in product specification and installation. They also called for product-specific training, third-party certification for systems of products critical to safe construction, and clear legal duties across the product lifecycle to ensure traceability and accountability.

Several respondents raised concerns about uncontrolled product substitutions. Respondents supported formal change controls, safety re-evaluations, and competency control sign-offs. They also urged a system-level approach to safety, ensuring that product changes should not compromise overall performance, with some recommending peer reviews for critical decisions.

There was strong backing for digital tools like product passports and QR tagging to enhance traceability. Respondents called for updates to Regulation 7 of building regulations to reflect modern practices and stressed the importance of consistent enforcement, auditing, and penalties to maintain safety standards.

Some respondents urged manufacturers to stay engaged throughout building projects, offering clear safety information and verified advice. Concerns about weak building control practices led to suggestions like banning mid-project control body / approved inspector changes and standardising inspections for better oversight.

To support long-term safety, a few respondents proposed development lifecycle audits, maintenance plans, and thorough building handovers. Many called for a cultural shift from cost-cutting to prioritising safety and competence. While many supported current initiatives, concerns about cost and access led to calls for free, accessible safety standards.

Question 12

What, if any, significant implications are there from implementing safety requirements for the specification, selection and installation of construction products and how could they be managed? - Please explain your answer.

126 respondents provided a response to this question. 61 respondents did not provide a response.

A key concern was the current skills gap in the construction industry and widespread lack of consistent training and qualifications across the construction supply chain, particularly among designers, specifiers, and installers. Many respondents called for mandatory continuing professional development, accredited training, and national upskilling initiatives. Alongside this, many stressed the need for a cultural shift, from prioritising cost to embedding safety-first thinking across all roles and responsibilities.

While most agreed that safety improvements are necessary, some respondents highlighted the financial and administrative burdens they could impose, especially on SMEs. Costs related to training, certification, and compliance were seen as significant. Suggestions to manage these included phased implementation, government support, and applying requirements proportionally based on risk.

Several respondents emphasised the importance of clear legal responsibilities across the construction process, from manufacturers to installers. Stronger regulatory oversight was widely supported, with calls for clearer guidance, more resources for regulators, and enforcement mechanisms such as random inspections, third-party certification, and penalties for non-compliance.

Concerns were raised about unsafe product substitutions and value engineering, with recommendations for formal change control and justification processes. While some feared overregulation could hinder innovation, others advocated for flexible, system-level standards that encourage safe and creative solutions.

Question 13

What other regulatory regimes and measures exist to support the safe installation of products in civil engineering works? Are there any duplications or gaps? Please explain your answer.

58 respondents provided a response to this question. 129 respondents did not provide a response.

The response rate to this question was poorer than other questions within Chapter 6.

Several respondents were of the view that regulatory overlap and complexity hinder compliance. In particular, they flagged confusion between overlapping regimes such as Construction (Design and Management) Regulations and the Building Safety Act, recommending a more streamlined and coherent regulatory structure.

Manufacturers and specifiers raised challenges about product-level safety oversight and traceability. They identified gaps for bulk materials and emphasised the need for better lifecycle documentation, digital records and traceability tools.

There is widespread support for a coordinated approach to reform. Respondents from various sectors called for collaborative action between the government, regulatory bodies, and industry leaders to assess current measures, identify any shortcomings, and establish a cohesive system that ensures the safe installation of civil engineering works.

Third party certification

Question 14

Do you agree that minimum requirements for third-party certification should be required? [Yes/No]. Please explain your answer.

146 respondents provided a response to this question. 41 respondents did not provide a response.

Question 14	No. Of Responses	% of all Responses	% of Ques. 14 respondents
Yes	136	72.7	93.1
No	8	4.3	5.5
Qualitative Response Only	2	1.1	1.4
Not Answered	41	21.9	-

An overwhelming majority of respondents believed that introducing minimum requirements to third-party certification schemes was essential to ensure consistency, transparency, and trust going forward.

There was very strong support for third-party certification schemes to be brought under regulatory oversight for the first time, with calls for the national regulator to play a new role in setting, monitoring and enforcing requirements.

A number of responses signalled the need for certification bodies to be independent, impartial, and free from commercial conflicts of interest, and ideally accredited to international standards, therefore raising the bar in quality of and trust in the schemes.

There was also strong support by those who responded for a greater measure of transparency for the product certification process and the means to trace the product, with certificates being available on a publicly accessible register; this in turn would bring trust and confidence in the production and installation of construction products.

Respondents placed emphasis on collaboration between trade associations, manufacturers, and regulators to co-develop robust and practical certification schemes, with the aim of introducing minimum requirements and standardisation. Many respondents advocated that the robustness of certification schemes could be increased by using international standards. There was also some support in responses for the schemes to made mandatory, with a small number claiming that they should be mandatory specifically for products critical to safe construction.

Question 15

Should upfront approval from the national regulator be required for third-party certification schemes? [Yes/No] Please explain your answer.

138 respondents provided a response to this question. 49 respondents did not provide a response.

Question 15	No. Of Responses	% of all Responses	% of Ques. 15 respondents
Yes	112	59.9	81.2
No	21	11.2	15.2
Qualitative Response Only	5	2.7	3.6
Not Answered	49	26.2	-

A recurring theme from respondents was the need for clarity regarding what schemes contained. The majority believed that the best way this could be achieved was through the introduction of enforcing minimum standards.

The overwhelming majority of responses advocated for mandatory upfront approval of third-party certification schemes. A large number of respondents thought that this would ensure consistency and comparability across schemes, rigour in schemes’ composition and a greater level of trust with the schemes themselves.

Upfront approval of certification schemes was identified by a number of respondents as a means to enhance legal defensibility and market credibility, and that it would assist specifiers, clients and contractors’ trust in the certifications they rely on.

While many supported upfront approval, both those who expressed “yes” and “no” to the question held concerns about the increase in bureaucracy, possible delays, and additional cost burdens the proposal could bring.

Multiple responses highlighted that the specific roles on upfront approval, of the United Kingdom Accreditation Service (UKAS) and the national regulator for construction products, would need to be clarified with the sector.

Question 16

What could help increase the take-up of these types of schemes?

134 respondents provided a response to this question. 53 respondents did not provide a response.

The most frequent suggestion respondents gave to increase take-up of third-party certification schemes was to mandate their use. It was further suggested that legislation should be used to enforce compliance and penalise non-adherence.

A significant number of those who indicated that schemes should be mandated were more specific, suggesting that schemes should be mandatory for products critical to safe construction only.

Respondents frequently raised procurement and market incentives. A number of responses stated that certification could be promoted as a competitive advantage and the use of the procurement framework could be deployed to drive demand. Other respondents suggested that insurers could offer reduced premiums for certified products.

A significant number of responses flagged cost and accessibility of the schemes as issues in relation to SMEs.

Building trust and confidence was another frequent theme. There was clear indication in the responses that further requirements on, and greater oversight of, third-party certification schemes were required. Respondents suggested that these could take the form of monitoring and auditing the certified bodies and conformity assessment bodies that carried out the schemes.

Product information and labelling

Question 17

What information would support you to choose the best product that will be safe in its intended use and its normal and foreseeable conditions of use?

135 respondents provided a response to this question. 52 respondents did not provide a response.

Respondents provided a wide range of suggestions about what information would be necessary for selecting and installing the right products. Six categories of information were identified:

• product identification and traceability
• product uses
• performance and testing
• certification
• installation
• maintenance and end of life

Some of the suggestions consisted of information already required – or planned – under the EU-CPR (though noting the need for consistency and quality of that information); but other suggestions proposed additional types of information, or information provided at a much greater depth than is currently available.

Two recurring and significant asks of new, or not readily available information were:

• ways to identify and trace products, including the use of unique product identifiers, batch numbers, and traceability to factory of origin
• much greater information on product uses and limitations, and richer detail on the installation approaches required to achieve stated performance standards

Respondents also focused on the need for product information to be of high quality, properly certified, verified, up to date, and accessible (paper and digital). This included views on how information should be digitised to ensure interoperability with other systems and standards, consistent calls for standardisation of format and labelling, asks to not overburden the sector by ensuring requirements were proportionate with risk and aligned with the EU-CPR where appropriate, and reminders that information should be appropriately presented for different audiences (technical, installers, residents).

There was broad agreement on the above among different sectors. However, manufacturers and trade associations were most engaged in this question, with a significant minority of architects and CABs. Few builders, designers, contractors, developers, or distributors gave a substantive answer.

Marketing

Question 18

Are you aware of instances where current marketing legislation has been insufficient to take action against misleading marketing practices? - If yes, please provide details.

129 respondents provided a response to this question. 58 respondents did not provide a response.

Question 18	No. Of Responses	% of all Responses	% split for Q18
Yes	58	31.0	45.5
No	60	32.1	46.5
Qualitative Response Only	11	5.9	8.5
Not Answered	58	31.0	-

Approximately half of respondents who answered the question reported some lack of clarity or scope in the regulations. This included the view that a broader scope is needed, and that regulations should be amended to cover specification and installation, online marketplaces and other third-party apps or websites, and performance and quality as well as safety.

Many of those who answered “yes” did not then go on to describe issues with the legislation itself and instead gave other examples of where, in their view, action should have been taken but was not. There were some key themes to these examples:

• advertising or other communications making claims without sufficient, clear technical evidence of the specific use case, out of date evidence, or in some cases a complete lack of evidence or verification
• the use of vague or ambiguous language, misuse of quasi-technical terms, and omission of information to evade scrutiny making the regulations difficult to enforce in practice, even if technically sufficient

Many respondents – whether they answered “yes” or “no” – pointed to a lack of enforcement, investigative or surveillance capacity - citing limited resources, complex regulatory landscape, capability, and expertise - as a key barrier to effective action.

Others cited broader barriers to action, including:

• a lack of understanding of existing regulations
• industry culture and competence
• a lack of clear responsibilities to act when poor behaviour is witnessed
• a lack of supporting guidance on what constitutes appropriate advertising, use of evidence and technical terms
• weak sanctions

A significant minority noted there were no issue with current regulations.

Installation Skills

Question 19

How is industry addressing gaps in construction product installation competence?

Question 20

What more can be done to support the improvement of competence in the construction products industry?

121 respondents provided a response to question 19. 66 respondents did not provide a response to question 19.

141 respondents provided a response to question 20. 46 respondents did not provide a response to question 20.

These questions have been presented together due to the clear and direct links between them. Analysis covers responses across both questions.

Manufacturers and trade bodies were the most active respondents for both questions. The topic most frequently commented on related to technical guidance and bespoke training by industry and trade association initiatives, including enhanced memberships. Competency frameworks, competency tracking and professional schemes were also popular themes amongst manufacturers, trade bodies and Conformity Assessment Bodies.

Many respondents referred to the development of competency frameworks, with the majority highlighting the work of the Industry Competence Steering Group (ICSG), bespoke manufacturer training offers and other industry-led initiatives (e.g., certification schemes led by trade bodies such as the Association for Specialist Fire Protection) and collaborative efforts like the Joint Competence Initiative and Build UK’s Common Assessment Standard.

Only a small number of respondents stated that industry was not addressing gaps in construction product installation competence, although many noted significant barriers to installation competence, including not learning from past incidents and fragmentation and inconsistent effort across the sector. Many called for the government to consolidate existing efforts (especially for SMEs), support implementation of competence frameworks, and embed competence as a core principle of building safety, backed by regulatory action.

The most popular suggestions in response to question 20 on how to improve competence were the need for improved training offers, including manufacturer installation training, guided learning, Continuous Professional Development (CPD) and improvements to national schemes like the Construction Skills Certification Scheme. The other most notable suggestions were the use of competency frameworks and competency tracking, with the majority highlighting the work of the ICSG, and the use of installer, supplier or maintenance schemes.

Many respondents highlighted the need for clearer guidelines on legislation and on competency expectations.  Some linked this to standardised frameworks or new mandatory requirements (like third-party accreditation for competence) especially for products critical to safe construction. Many also called for stricter enforcement action, auditing for existing standards and penalties for incompetence or incorrect installation.

Chapter 7: Clear accessible information

Test data and data sharing

Question 21

What test information is necessary to facilitate appropriate selection, safe installation, and demonstrate that claims made can be evidenced?

139 respondents provided a response to this question. 48 respondents did not provide a response.

Respondents overwhelmingly stressed the need for test data to be clear, relevant, and reflective of real-world conditions. Many called for transparency about what was tested, how, and under what conditions - long with any limitations - so that designers, specifiers, and installers can make informed decisions.

There was strong support for third-party assessments by accredited, independent bodies. And for these to not only verify test results but also provide installation guidance, extended application reports, and ongoing audits to ensure product performance and manufacturing consistency.

Many advocated for a centralised digital platform with standardised formats to simplify comparison across products. Some respondents recommended tiered access, offering detailed technical data to professionals and regulators, with simplified summaries to others, to balance usability with technical depth.

While transparency was widely supported, some respondents cautioned against public release of raw test data due to risks of misinterpretation and competition issues. They preferred summarised, third-party verified performance claims to be public, with full data accessible to regulators and qualified professionals.

Some concerns were raised about non-specialist users misinterpreting complex data. Several respondents called for clearer summaries, better training, and expert interpretation. They also emphasised the importance of system-level testing and maintaining traceable, version-controlled records throughout a product’s lifecycle.

Question 22

What, if any, significant constraints might prevent disclosure of all test data and how could they be mitigated?

131 respondents provided a response to this question. 56 respondents did not provide a response.

The most prominent constraints cited were risks to intellectual property being compromised and commercial sensitivity concerns. Many respondents considered that disclosure of proprietary information could result in others gaining insights into product performance and potentially copying designs. Some noted that these risks could act as a deterrent to innovation. A small number of respondents felt that public safety should override any commercial interests.

A number of respondents were explicit in their support for greater transparency but felt that the key was ensuring that information shared was at the level that is useful and understandable to the individual viewing it.

Many respondents said that considerable expertise was required to use test information properly. Some stated that disclosure of full test reports could create risks that non-experts draw incorrect conclusions, such as regarding the suitability of a product for a particular use.

Digital solutions

Question 23

What information would it be useful to include on a construction library and who would benefit?

147 respondents provided a response to this question. 40 respondents did not provide a response.

The majority of respondents spoke positively of the proposal to develop a construction library and contributed suggestions for its development and use; but also pointed out numerous challenges with its implementation and upkeep.

It was also clear that there were several different interpretations of what a construction library might ultimately look like. This ranged from a comprehensive product database, to a hub and spoke model, to more limited and specific repositories of reports and other information.

Respondents who supported the library suggested a wide range of stakeholders that would benefit from its use; for example, one respondent noted “the Library must serve multiple user groups including designers, specifiers, contractors, regulators, manufacturers, asset managers, and the general public”.

Concerns were shared about implementation of the library including noting the “mammoth task” of compiling and updating a library containing all products, legal and confidentiality issues, funding and administrative burdens on manufacturers, trust and verification of data.

Some respondents did not support the development of a library. Reasons for this included:

• not seeing a benefit or disagreeing that the library will solve the issues it purports to. Instead, respondents suggested that these would be solved through better regulations, enforcement, or industry codes of practice around data
• overlap with existing industry databases, removing a need for a library
• other solutions that would better or more cost-effectively address the issues

Question 24

What benefits or challenges could digital labelling or EU Digital Product Passports (DPPs) bring?

134 respondents provided a response to this question. 53 respondents did not provide a response.

The majority of responses to the benefits and challenges of digital labelling came from manufacturers, national representatives and trade bodies. Most responses highlighted improved accessibility to information and improved traceability to support the golden thread as key benefits. Linked to this, many responses noted the potential for enhanced safety and compliance and emphasised how such initiatives could support a circular economy. Many also voiced support for alignment to EU regulations and DPPs but stated the need for more information on DPPs before any decisions were made.

Wide-ranging challenges were also communicated. The greatest concern was about data ownership and integrity, including the maintenance and verification of information. Responses also highlighted data standardisation, interoperability issues and implementation challenges including cost, resource and logistical issues to labelling products. Another concern that was noted was the risk of digital exclusion due to the inconsistency of digital capability across the sector.

Some highlighted the increased risk of fraud, explaining that companies could link information from a digital label to the wrong product. Further risks were cited around cybersecurity, intellectual property and fragmentation if multiple services were used. The risk to the loss of information, for example being on site with limited access to digital services, was also stressed.

Traceability

Question 25

Are the proposals we have outlined (in Chapter 7) to improve access to product information enough to support traceability?

133 respondents provided a response to this question. 54 respondents did not provide a response.

Question 1	No. Of Responses	% of all Responses	% of Ques. 25 respondents
Yes	64	34.2	48.1
No	59	31.6	44.4
Qualitative Response Only	10	5.3	7.5
Not Answered	54	28.9	-

While respondents generally agreed to the principle and benefits of the proposals, many raised similar concerns on the scale and type of implementation challenges, including tracing and maintaining information across the value chain. Therefore, the split in respondents’ answering ‘yes’ or ‘no’ potentially reflects their perceived level of delivery risk rather than a disagreement on the benefits and challenges.

Many stated the importance of digital integration and interoperability across services (including making use of existing initiatives like BSI Identify, GS1 and encouraging sign up to the CCPI). Digital tracking using Quick Response codes or Radio Frequency Identification was highlighted as needed, especially for products critical to safe construction or UKCA / CE marked products. It was noted that tracing products that are assemblies of several components or subject to repeated maintenance would be a challenge. Linked to digital integration was an overall consensus for alignment with EU Digital Product Passports.

Many responses raised concerns about implementation challenges, the need for ongoing quality management and the cost to industry. Some highlighted the complexity of construction product supply chains and the need for better information sharing, including direct contact with manufacturers. A few responses linked this to support for the construction library to share best practice and contact details, although cautioned against using it as a replacement for contact with manufacturers. Several responses called for government support through mandates, clear guidance, SME support, and stronger enforcement such as penalties and random audits.

National representative or trade bodies / associations made up the largest share of respondents, focusing on digital integration, government guidance, supply chain collaboration, and common standards. Manufacturers, professional bodies, and conformity assessment bodies also contributed significantly, with emphasis on implementation, guidance, and quality control. Designers and local authorities contributed proportionately less and mainly addressed implementation, collaboration, and digital integration.

Product marking

Question 26

Should digital labelling be available as an alternative to the A United Kingdom Conformity Assessed (UKCA) mark? Please explain your answer.

133 respondents provided a response to this question. 54 respondents did not provide a response.

Question 26	No. Of Responses	% of all Responses	% of Ques. 26 respondents
Yes	71	38.0	53.4
No	56	29.9	42.1
Qualitative Response Only	6	3.2	4.5
Not Answered	54	28.9	-

Stakeholders widely agreed that digital labelling should enhance, not replace, physical marks like the UKCA or CE marks. A number of respondents stated that physical labels provide immediate, visible assurance of compliance, especially in environments with limited digital access, such as construction sites, and that removing them could erode trust and hinder product selection.

Many respondents were enthusiastic about the added value digital labelling could provide beyond static physical marks. Reasons given included that digital systems can offer rich, accessible information to support product specification, such as installation instructions, maintenance guidance, and lifecycle tracking. This enhanced transparency was seen by several respondents as a major step forward to improve traceability, accountability, and enable informed decision-making across a product’s lifespan.

Many expressed caution about relying solely on digital systems, citing risks like broken links, data loss if manufacturers go out of business, and digital exclusion.

There was a strong desire for regulatory clarity, consistency, and interoperability between digital and physical systems. Some advocated for a phased, voluntary transition to digital labelling, supported by robust infrastructure, standardisation, and government-backed databases to ensure long-term reliability.

The current UKCA mark was viewed by some respondents as burdensome, with limited added value compared to the current CE mark. Suggestions included pursuing mutual recognition with the EU, redefining the UKCA’s purpose, or phasing it out in favour of a harmonised approach with Europe.

Question 27

Is there a role for government in establishing voluntary product marks, for example to demonstrate a higher standard has been met? Please explain your answer.

141 respondents provided a response to this question. 46 respondents did not provide a response.

Question 27	No. Of Responses	% of all Responses	% of Ques. 27 respondents
Yes	77	41.2	54.6
No	52	27.8	36.9
Qualitative Response Only	12	6.4	8.5
Not Answered	46	24.6	-

Respondents cautiously supported a government role in voluntary product marks - but only if schemes are transparent, independently verified, and clearly distinguished from mandatory marks like UKCA or CE. A number considered that the government should focus on setting criteria, accrediting competent bodies, and ensuring any new mark signals genuinely higher standards in safety, sustainability, or performance.

Many respondents felt that when well-designed and credible, voluntary marks can help manufacturers stand out, encourage innovation, and raise industry standards. Further, they are seen as tools to promote excellence - not just compliance - by incentivising performance beyond legal minimums and supporting broader goals like net zero, and export competitiveness.

Many respondents warned that introducing new marks could add to the already complex array of certification schemes. Some were concerned that without clear communication and coordination, new marks risk duplicating existing efforts, confusing users, and imposing unnecessary costs - especially on smaller manufacturers.

Rather than creating new marks, many suggested the government should endorse or accredit existing, high-quality, voluntary schemes. Respondents cited that this approach would reduce duplication, build on established trust, and support informed decision-making through official recognition, procurement incentives, or integration with digital tools.

Several felt that voluntary marks could add real value in areas not covered by current designated standards. However, they noted that successful implementation would require strong governance, market incentives, and clarity of purpose. Some argued the government should instead focus on enforcing existing rules and educating the market, warning that poorly executed schemes could dilute trust.

Chapter 8: Assurance and oversight of testing and conformity assessment

Conformity assessment and accreditation

Question 28

Do you consider that the measures set out above would provide sufficient oversight of conformity assessment? [Yes/ No] Please propose any further measures you consider may be necessary.

130 respondents provided a response to this question. 57 respondents did not provide a response.

Question 28	No. Of Responses	% of all Responses	% of Ques. 28 respondents
Yes	86	46.0	66.2
No	30	16.0	23.1
Qualitative Response Only	14	7.5	10.8
Not Answered	57	30.5	-

Consultation respondents expressed broad support for stronger oversight, with many responses offering views on additional measures. Within this, CABs themselves were mostly supportive of the need for greater oversight.

A number of respondents cited the need for any new measures to be properly enforced, including regular audits, and several highlighted the importance of competence of auditors and UKAS to support the introduction of any new measures.

The importance of addressing the risk of conflicts of interests within CABs was highlighted by a number of respondents, as was the importance of consistency of CABs’ interpretation of standards and the need for a universal application of them by CABs.

Several respondents agreed with the proposals in principle but considered that more detail on the measures was needed.

Question 29

Should the government have the ability to recognise conformity assessment activity undertaken by conformity assessment body (CABs) established outside of the UK? [Yes/No]. Please explain your answer.

136 respondents provided a response to this question. 51 respondents did not provide a response.

Question 29	No. Of Responses	% of all Responses	% of Ques. 29 respondents
Yes	115	61.5	84.6
No	16	8.6	11.8
Qualitative Response Only	5	2.7	3.7
Not Answered	51	27.3	-

Consultation respondents expressed strong support for this proposal, citing it as a route to address capacity issues, support the bringing of products to market, and provide greater flexibility for manufacturers.

But many respondents highlighted that this should only be if overseas CABs are properly overseen, with sufficient safeguards and controls in place, for example assurance that those CABs are subject to equivalent requirements.

Many respondents expressed support for a mutual recognition agreement (but most were silent on with whom).

Question 30

What support do UK CABs need to invest, grow and improve their skills?

81 respondents provided a response to this question. 106 respondents did not provide a response.

The majority of respondents stressed the importance of government support, to ensure the long-term viability and competitiveness of UK CABs. This included calls for investment, training programmes, and regulatory clarity.

Many responses also pointed to the need for a level playing field, with concerns raised about inconsistent standards, undercutting by less competent bodies, and the lack of recognition for UK CABs in international markets.

A common theme across responses was the need for a stable and predictable regulatory environment. Several respondents noted that ongoing uncertainty around UKCA and CE marking had stalled investment and reduced confidence in the system.

Several respondents also highlighted the need for better career pathways, apprenticeships, and technical training to address the shortage of qualified assessors, auditors, and testers. Some called for a national skills framework or government-backed training schemes to build capacity in the sector.

Some respondents offered other suggestions such as, including mandatory third-party certification for products critical to safe construction, improved oversight of CAB performance, and closer collaboration between government, industry, and academia to support innovation and competence development.

Question 31

What more is needed to address the failings identified with respect to the United Kingdom Accreditation Service (UKAS) and the accreditation process?

95 respondents provided a response to this question. 92 respondents did not provide a response.

Some respondents considered that the proposals contained in the green paper were sufficient, but many provided their own proposals in response to this question.

The most common themes proposed were the need for greater transparency and independent oversight of UKAS’s activities (examples given included publishing an annual report of its activities in relation to construction products) and the need for more technically skilled people within UKAS. A greater focus on recruitment and capacity building was cited as a way to improve outcomes and to address concerns that UKAS’s work was too slow.

Several respondents felt that the role of UKAS needed to be made clearer. A number of respondents considered that there was a need for a route of escalation for concerns about the service they received from UKAS.

The British Standards Institution

Question 32

What are the strengths and weaknesses of the standards development process, and where could it improve?

125 respondents provided a response to this question. 62 respondents did not provide a response.

The most common theme was concern about the slow pace of standards development. Many respondents described the process as too lengthy and bureaucratic, making it difficult to respond to emerging risks, technologies, or regulatory needs in a timely manner.

The majority of respondents highlighted that the current standards development process has several strengths, particularly its consensus-based approach, technical rigour, and alignment with international standards.

Several respondents praised the inclusive nature of the process, noting that it allows for broad stakeholder input and helps ensure that standards are technically sound and widely accepted. Many also highlighted the value of international alignment, particularly with European Committee for Standardisation (CEN) and International Organisation for Standardisation (ISO), in supporting trade and regulatory coherence.

Many of the responses raised concerns about limited representation on standards committees, particularly from SMEs, public interest groups, and newer entrants to the market. Some noted that the process is often dominated by larger commercial players, which can lead to imbalances in influence and outcomes.

Other frequently mentioned issues included the high cost of accessing standards, lack of transparency in decision-making, and limited public understanding of how standards are developed and used. Several respondents also questioned the independence of the process, particularly where commercial interests are involved.

Question 33

What opportunities are there for government and the national regulator to work more collaboratively with the British Standards Institution (BSI)?

105 respondents provided a response to this question. 82 respondents did not provide a response.

The most common theme that emerged was the need for stronger strategic alignment between the British Standards Institution (BSI) and government. Many respondents suggested formal governance mechanisms to ensure that standards development is closely tied to regulatory and policy priorities.

Another common theme that emerged was funding and commissioning of standards, particularly in areas relating to products critical to safe construction and emerging technologies. Many respondents felt that government should take a more proactive role in prioritising standards for areas such as sustainability, digital transformation, and MMC.

Several respondents called for increased participation from government and regulators on BSI technical committees, especially for standards relating to products critical to safe construction. There was also support for broader representation from SMEs, academia, and public interest groups to ensure standards reflect diverse perspectives.

Several respondents had concerns over transparency and accessibility of standards. Many participants suggested improving public access to standards relating to products critical to safe construction, potentially through government funding, and publishing clear rationales for technical decisions.

A smaller number of responses focused on the integration of BSI standards with building regulations and Approved Documents, noting that closer alignment would improve enforceability and practical application. Some also highlighted the need for feedback loops and post-certification monitoring to ensure standards deliver real-world safety and performance.

Question 34

Should mandatory standards be free to access? [Yes/ No] If yes, please provide suggestions on how this could be achieved, including funding

152 respondents provided a response to this question. 35 respondents did not provide a response.

Question 34	No. Of Responses	% of all Responses	% of Ques. 34 respondents
Yes	117	62.6	77.0
No	22	11.8	14.5
Qualitative Response Only	13	7.0	8.6
Not Answered	35	18.7	-

Respondents agreed that mandatory standards - especially those tied to safety and legal compliance - should be freely accessible to ensure transparency, fairness, and public safety.

Respondents highlighted that high costs of standards are a significant barrier, particularly for SMEs, as they have to purchase multiple standards and the costs can add up. This limits compliance and safety: respondents said that if HMG wants more take up of standards it should facilitate access to them.

Respondents argued that if a standard is legally binding, it should be treated like legislation - freely accessible to all.

A significant minority of respondents did however advise against free access. Their concerns included loss of revenue for BSI, which funds operations through standard sales; risk of misuse by unqualified users; and international copyright and licensing issues.

Respondents argued that standards are often developed with the crucial aid of unpaid volunteer experts. Organisations that contribute to the development of standards could at least be given those standards for free when complete.

Testing capacity

Question 35

Do you agree that an increase in public and private sector testing capacity is required?  Please explain your answer. If yes, please include information on the gaps this might address.

144 respondents provided a response to this question. 43 respondents did not provide a response.

Question 35	No. Of Responses	% of all Responses	% of Ques. 35 respondents
Yes	124	66.3	86.1
No	15	8.0	10.4
Qualitative Response Only	5	2.7	3.5
Not Answered	43	23.0	-

Many responses explicitly endorsed the idea of increasing public testing capacity. These respondents suggested that public testing could help with capacity issues, proactively ensure testing methods are updated, provide greater surveillance testing and provide more transparency.

Respondents said that there was a lack of testing capacity available in the UK, resulting in high testing costs and long lead and turnaround times. This especially impacts SMEs. Respondents reported that this makes it difficult to innovate and bring new products to market, as the high testing costs disincentivise new solutions and iterating on previous designs. Respondents said that increasing testing capacity would consequently reduce costs, facilitate innovation and allow the industry to respond quicker to reform.

Respondents highlighted that with current capacity, the testing system would not be able to cope with the increased testing demands proposed by the green paper.

Research and development (R&D)

Question 36

What should the government’s role be in supporting R&D in relation to construction products and the wider built environment? Please explain your answer.

127 respondents provided a response to this question. 60 respondents did not provide a response.

Many respondents expressed views about how the government could support R&D carried out by private firms. Many respondents said that they were happy with the current situation, where product manufacturers receive tax credits for performing R&D. However, the majority of respondents felt that there was scope for the government to lead and promote R&D within the construction products industry.

Some respondents said that there was insufficient incentive for investment into R&D from private manufacturers, and that the government could create further financial incentives for private firms to innovate.

Respondents also suggested that the government step in and actively coordinate R&D within the industry. Government could do this by developing forums to link manufacturers, academia, regulators and other parties together to share information on standards and increase accessibility to expertise. Government could also outline to industry what technologies should be focussed on.

Respondents also said that it would be useful to the industry to have a national institution that would perform publicly-led-and-funded research into the built environment, in a similar vein to the role that the BRE performed before it was privatised in 1997. The research this institution would perform could help inform new standards and regulations to ensure they stay up to date with innovation. Respondents felt that the work performed would not just be for the benefit of Government or regulation but also the entire industry.

Chapter 9: Regulating the market

Functions of the national regulator

Question 37

Do you agree with the proposed regulator functions that we have laid out? [Yes/No]. Please explain your answer.

132 respondents provided a response to this question. 55 respondents did not provide a response.

Question 37	No. Of Responses	% of all Responses	% of Ques. 37 respondents
Yes	114	61.0	86.4
No	15	8.0	11.4
Qualitative Response Only	3	1.6	2.3
Not Answered	55	29.4	-

The most common view that emerged was the need to ensure the regulator is adequately resourced and staffed with technically competent staff. Many respondents stressed that without sufficient funding, expertise, and digital capability, the regulator would struggle to enforce standards or respond effectively to safety concerns.

A significant number of respondents raised concerns about how the proposed functions would be implemented in practice. They highlighted the need for clear guidance, realistic timelines, and coordination with existing bodies to avoid fragmentation and ensure effective delivery.

Several respondents called for stronger market surveillance and enforcement, particularly to address misleading marketing and non-compliant products. Some suggested that existing bodies such as the Office for Product Safety and Standards (OPSS) and Trading Standards should be better funded to support this.

A small number of respondents emphasised the importance of meaningful consequences for non-compliance. They supported penalties, including criminal liability in severe cases, and suggested publicising enforcement actions to act as a deterrent.

Some respondents highlighted the need for proportionate and transparent regulation. They called for fairness in enforcement, clear communication of decisions, and an accessible appeals process to maintain trust and accountability.

Question 38

We want to consider options for regulator cost recovery. Which of the regulator functions set out could be an opportunity for cost recovery? Please explain your answer.

93 respondents provided a response to this question. 94 respondents did not provide a response.

Many respondents were supportive of recovering costs from those found to be non-compliant. Many respondents felt that the regulator should be able to recover investigation and enforcement costs where breaches are identified, with fines used as an additional deterrent. This approach was seen as fair and proportionate, ensuring that those who break the rules bear the financial burden.

A number of respondents proposed the introduction of a levy or tax on construction products or projects. Suggestions included a percentage of product cost or a fixed charge per project, with calls for transparency and fairness in application, including exemptions or reduced rates for SMEs.

Several respondents expressed concerns about unintended consequences of cost recovery mechanisms. These included the risk of discouraging compliance, suppressing innovation, or disproportionately impacting smaller firms. Some warned that excessive fees could be passed on to consumers.

Some respondents recommended drawing on existing regulatory models such as those used by the Health and Safety Executive (HSE) or Ofgem. These were seen as tested frameworks that could offer licensing fees, enforcement charges, or statutory levies without adding unnecessary complexity.

A small number emphasised the importance of proportionality and fairness in cost distribution. Suggestions included tiered fee structures based on company size, turnover, or risk profile to avoid overburdening SMEs.

Roles and responsibilities of the regulators

Question 39

How much surveillance and enforcement of the construction products sector can, and should local authority trading standards (LATS) be responsible for? Please explain your answer.

105 respondents provided a response to this question. 82 respondents did not provide a response.

A number of respondents were against or sceptical about LATS being responsible for regulating construction products, including all local authority/local or regional government respondents.

A similar number of respondents thought there could be a role for LATS to play. This included suggestions for a role in local surveillance, routine enforcement cases, regulating only those products sold directly to consumers, or some other role that would complement that of the national regulator. Several people noted the need for join up between LATS and the national regulator.

Many respondents thought LATS lacked the resources and expertise to effectively regulate construction products. Some also noted the power imbalance between LATS and multinational product manufacturers, the complexity and high cost of testing to support enforcement activity, and the risk of regional variations in enforcement, should LATS maintain their enforcement responsibilities.

Question 40

Should National Trading Standards (NTS) play a role in overseeing or supporting enforcement of the construction products regime? Please explain your answer. If yes, please include what role you think National Trading Standards should play.

121 respondents provided a response to this question. 66 respondents did not provide a response.

Question 40	No. Of Responses	% of all Responses	% of Ques. 40 respondents
Yes	66	35.3	54.4
No	45	24.1	37.2
Qualitative Response Only	10	5.3	8.3
Not Answered	66	35.3	-

The views shared were varied and nuanced, and we suspect some respondents misinterpreted the term ‘National Trading Standards’ (NTS) to mean LATS, or the national regulator for construction products.

Some respondents were unclear about the added value of NTS. Respondents noted the risk of duplication or added complexity in the system, that NTS lacks statutory enforcement powers, and that it is focused on consumer products. Multiple respondents thought that the national regulator should lead enforcement. Some thought NTS should play a limited role only.

Other respondents noted the benefits of NTS playing a role, including that it is well placed to aggregate intelligence, that it could ensure a consistent approach across regions, and that it has experience in tackling complex supply chains, and in cross-border and national-level enforcement.

Many respondents expressed concerns about LATS lacking the skills and resources to regulate construction products. Some suggested NTS could provide relevant training and support to LATS.

Question 41

Should the national regulator play a stronger role in enforcement of misleading marketing? Please explain your answer.

132 respondents provided a response to this question. 55 respondents did not provide a response.

Question 1	No. Of Responses	% of all Responses	% of Ques. 41 respondents
Yes	120	64.2	91.6
No	6	3.2	4.6
Qualitative Response Only	6	2.7	3.8
Not Answered	55	29.9	-

Quite a few respondents noted the risks associated with misleading marketing of construction products, or the need for greater scrutiny or oversight of marketing claims.

A few respondents made the case for visible enforcement and many raised regulator skill or resources, noting this would be required to deliver effective oversight of marketing.

Some respondents suggested other regulators have a potential role in this space, including the Competition and Markets Authority (CMA), the Advertising Standards Authority (ASA), and LATS, with respondents pointing to the regulators’ existing roles, powers and experience. However, many of these respondents flagged a need to coordinate activity, to avoid duplication or gaps, and maximise effectiveness, with a couple of suggestions for the national regulator to lead this coordination.

Several respondents expressed scepticism about the role of LATS or had the view that there was no contribution for LATS to make to enforcement in this space.

Several respondents argued that there needed to be a clear framework for enforcing against misleading marketing, which could include a clear definition of what constitutes misleading marketing, guidance and support for the sector, and a route for appeals.

Question 42

How could the Office for Product Safety and Standards (OPSS) as the national regulator for construction products, the Building Safety Regulator (BSR), local authority trading standards (LATS) and building control bodies best join up their responsibilities and work together? Please explain your answer.

96 respondents provided a response to this question. 91 respondents did not provide a response.

Many of the respondents mentioned the importance of regulators having clear roles and scope of responsibilities, noting the risk of gaps and duplication, and that these roles should be clearly communicated to the sector. Many respondents also described the roles that different regulators should have at the different stages of a product’s lifecycle.

Respondents made practical suggestions on how regulators could work together, including: the creation of a forum, protocol or taskforce to support communication and co-ordination of activity between regulators; the coordination and streamlining of regulators’ surveillance systems; and regulators having joint training programmes to support their activity.

Many respondents supported having a single organisation to address fragmentation challenges. Some proposed the amalgamation of functions generally while some suggested having an overarching authority, or specifically, a single authority responsible for construction products regulation.

Multiple respondents were sceptical of the contribution LATS could make to surveillance and enforcement activity, or thought only the national regulator for construction products should regulate construction products, while others suggested regulators needed to align their values, objectives or strategies, in order to address fragmentation.

Some respondents, particularly national representatives / trade bodies & associations raised the issue of regulators needing to engage and bring in industry, for example through trade associations, the Construction Leadership Council, or the CCPI. The issues most raised by local authorities/local government/regional government were around the role of local versus national regulators.

Question 43

Which regulatory authorities should play a role in ensuring compliance with our proposed obligations around product use? - Please explain your answer.

98 respondents provided a response to this question. 89 respondents did not provide a response.

Many respondents thought that building control bodies should play a role, noting that their role in the current system to ensure compliance with the building regulations made them well placed to take on the proposed new role. A few respondents said the current enforcement approach of building control was weak.

Many respondents were of the view that there was a role for the Building Safety Regulator (BSR), with some arguing it should lead compliance, and / or that it should have a specific role in overseeing products used in Higher Risk Buildings (HRBs).

Many respondents thought there was a role for the national regulator for construction products, which sits within OPSS, with some views that it should lead compliance. Some respondents noted that it housed the necessary technical expertise, and that it would be best placed to ensure products were placed on the market with the required (and accurate) product use and installation information. Some also suggested it should coordinate the triaging of stakeholder reports and concerns about product use, and the work of other regulatory authorities in the sector (national and local).

Some respondents said there was a role for LATS, notably, in managing local surveillance, while others argued there was no role for LATS as they lacked the necessary expertise.

Reporting and surveillance was a key theme in the responses. Suggestions for improving this included introducing or updating duties for reporting to regulators, greater information sharing between regulators, harnessing the experience of regulatory professionals, and having a single point of contact for the sector and public to report concerns.

Some respondents observed that there will need to be different roles for different authorities across the lifecycle of products, and some proposed a shared role between the BSR and national regulator for construction products. A few respondents pointed to the need to consider the operation of the regime in the devolved nations.

Surveillance

Question 44

Do you believe the approaches to reactive and proactive surveillance as set out will be effective in monitoring the market? [Yes/No]. Please explain your answer and note any additional approaches you think we should consider.

126 respondents provided a response to this question. 61 respondents did not provide a response.

Question 44	No. Of Responses	% of all Responses	% of Ques. 44 respondents
Yes	98	52.4	77.8
No	20	10.7	15.9
Qualitative Response Only	8	4.3	6.3
Not Answered	61	32.6	-

Several respondents noted the value of combining proactive and reactive surveillance. There was notable support for a system for stakeholders to report issues or concerns to regulators, with various related suggestions, including reporting anonymity or a protected route for whistleblowers, active promotion by regulators, a role for organisations such as trade associations and fire and rescue services, and formal recording of reports.

There were many suggestions around various types of tools, particularly digital solutions, to support the surveillance process including making use of CCPI processes, digital product passports, the OPSS product alerts and recall system, digital systems to support intelligence-sharing between regulators, and the construction library.

Many people said that industry had a role to play in surveillance, including through monitoring, proactive reporting, or triaging of specific issues and trends in their sector.

On the topic of regulators, many respondents flagged the need for appropriate regulator resources and/or expertise to carry out effective surveillance backed by sufficient enforcement. There was support for having clear roles and responsibilities and coordinated surveillance across different regulatory authorities in the sector, and for intelligence sharing to support this work.

Manufacturers in particular supported the proposed approach to surveillance and were particularly supportive of a (potentially anonymous) reporting process, accessible by all stakeholders. Many national representative or trade bodies / associations made the point that industry should contribute to market surveillance, and that regulators require the right resources and/or skills to carry out surveillance and investigations.

Enforcement

Question 45

We are considering options to expand the scope of who can be liable for an offence, so that it could include individuals and associated companies. Do you agree with this proposal? [Yes/No]. Please explain your answer.

106 respondents provided a response to this question. 81 respondents did not provide a response.

Question 45	No. Of Responses	% of all Responses	% of Ques. 45 respondents
Yes	91	48.7	85.8
No	14	7.5	13.2
Qualitative Response Only	1	0.5	0.9
Not Answered	81	43.3	-

The proposal with the most support from respondents was expanding liability to improve accountability and drive cultural change across the sector. Respondents felt this would deter misconduct and promote safer practices

Many respondents highlighted that complex corporate structures can obscure responsibility. They supported extending liability to parent and associated companies to close accountability gaps.

Several respondents emphasised the need for fairness and proportionality. They called for safeguards to protect individuals acting in good faith and for liability to be clearly defined and role-specific. Several respondents emphasised that liability should target those who knowingly engage in misconduct.

Some respondents cited existing legislation such as the Health and Safety at Work Act 1974, which already allow for prosecution of individuals as well as companies, noting it could be useful to consider these principles.

Interventions and sanctions

Question 46

We have set out proposed interventions and sanctions available to the national regulator. Do you think these will enable the national regulator to effectively manage non-compliance in the sector? [Yes/No]. Please explain your answer.

101 respondents provided a response to this question. 86 respondents did not provide a response.

Question 46	No. Of Responses	% of all Responses	% of Ques. 46 respondents
Yes	89	47.6	88.1
No	10	5.3	9.9
Qualitative Response Only	2	1.1	2.0
Not Answered	86	46.0	-

Many respondents agreed that the proposals would provide a strong deterrent to poor behaviour in the industry, particularly fines and imprisonment as a sanction for non-compliance. Some highlighted the importance of strong sanctions to create a better industry culture, noting that without strong consequences, bad actors could continue to operate in the industry unchecked.

Many respondents suggested that the effectiveness of the proposed framework hinges on the regulator being adequately resourced, including the right skills, competence and expertise. Suggestions included sufficiently skilled staff with the right technical competence to understand the sector and manage non-compliance, and training programmes and ongoing development to ensure regulators stay familiar with evolving technologies and standards. This was raised several times both by national representatives or trade body associations, and manufacturers.

On a similar topic, many respondents highlighted that while having the right powers and sanctions in place is an important first step, they must be applied actively, consistently and visibly to have impact, as reluctance to enforce could undermine the credibility of the regime. Some suggested that enforcement action should be publicised to increase impact.

Many respondents also called for a proportionate enforcement approach. Proportionality was seen as essential to maintaining industry confidence and ensuring fairness, and some respondents raised this amid concerns about sanctions reaching too far if not properly checked. This theme was raised by a variety of respondents, including national representatives or trade body associations, manufacturers, CABs, building control and architects.

Question 47

We have set out our intention to explore regulatory powers to limit individuals’ activities in the construction sector, in line with provisions in other regulatory regimes such as food safety. Do you agree with this proposal? [Yes/No]. Please explain your answer.

105 respondents provided a response to this question. 82 respondents did not provide a response.

Question 47	No. Of Responses	% of all Responses	% of Ques. 47 respondents
Yes	94	50.3	89.5
No	6	3.2	5.7
Qualitative Response Only	5	2.7	4.8
Not Answered	82	43.9	-

Respondents recognised that the powers would represent a strong deterrent to poor behaviour in industry and uphold industry integrity and accountability by preventing the risk of repeat offences. Particular support was shown for a power that targets deliberate non-compliance and those who knowingly produce and sell unsafe products.

Many respondents highlighted that the parameters of such a power would need to be clearly defined to ensure proportionality, transparency and fairness. Again, many suggested that such a power should target those who have acted negligently, recklessly, or with intent to deceive or endanger, rather than those who have made genuine mistakes.

Some respondents highlighted that this power could prevent a practice that currently occurs in the industry, whereby individuals can liquidate companies, change company names or registrations, or ‘phoenix’ companies to evade responsibility. It was suggested that at present, there is little to prevent companies from doing this.

Many respondents raised the point that these powers would act as a strong deterrent, including those from technical assessment bodies, professional institutions, national representative or trade body / associations, manufacturers and conformity assessment bodies.

The majority of the 105 answers came from manufacturers and trade associations. Across these two groups, agreement was high that we should explore powers to limit individuals’ activity in the industry: 90% of manufacturers that provided a response agreed, and so did 85% of national representatives or trade bodies. Both sets of stakeholders pointed towards such powers acting as a strong deterrent and supported the notion of clearly defined powers.

Question 48

What, if any, additional measures should we consider to strengthen the powers of regulatory authorities, beyond those we have outlined in this chapter?

55 respondents provided a response to this question. 132 respondents did not provide a response.

Many respondents did not provide additional suggestions, and instead noted their agreement with the proposals, stating nothing further was needed.

Several suggested that rather than additional measures, visible enforcement would have a positive impact on industry. Suggestions included regulators using their powers more often, and publicising enforcement action. Some specifically suggested ‘naming and shaming’ bad actors, to inform the market and act as a deterrent.

As in question 47, several suggested that for powers to be effective, they must be backed with resources, expertise, and enforcement capacity, which was noted as an issue at present.

Several suggested a need for additional surveillance and reporting. Suggestions included mandatory product registration and traceability, mandatory reporting of product-related litigation, and DPPs to support surveillance. Some also suggested a need for protection for whistleblowers, to encourage reporting of safety concerns.

Civil Redress

Question 49

If you have suffered a financial loss as a result of building safety defects, have you considered taking action to seek redress from a construction products manufacturer via sections 148 and 149 of the Building Safety Act? [Yes/No]. If yes, did you face any difficulties? Please explain your answer.

65 respondents provided a response to this question. 122 respondents did not provide a response.

Question 49	No. Of Responses	% of all Responses	% of Ques. 49 respondents
Yes	0	0.0	0.0
No	61	32.6	93.8
Qualitative Response Only	4	2.1	6.2
Not Answered	122	65.2	-

Consultation analysis was limited across this question, as of the total respondents, only 12 provided a qualitative response.

Some respondents highlighted that pursuing redress under the Building Safety Act 2022 is prohibitively expensive, time-consuming and complex.

There was some disagreement about supply chain responsibility. Two respondents suggested that focusing solely on manufacturers is too narrow, as other actors in the construction supply chain, such as designers and contractors, may also be responsible for defects. Another respondent suggested that redress mechanisms should include all affected parties. On the other hand, two respondents supported the principle of redress against manufacturers.

Two respondents emphasised the importance of proving causation before assigning blame or seeking redress, noting the difficulty in isolating a single product as the cause.

Question 50

If you have suffered a financial loss as a result of building safety defects, have you considered making a claim against a manufacturer via any other available routes, such as contractual routes? [Yes/No]. If yes, did you face any difficulties? Please explain your answer.

64 respondents provided a response to this question. 123 respondents did not provide a response.

Question 50	No. Of Responses	% of all Responses	% of Ques. 50 respondents
Yes	3	1.6	4.7
No	57	30.5	89.1
Qualitative Response Only	4	2.1	6.3
Not Answered	123	65.8	-

Analysis was limited across this question, as of the total respondents, only 12 provided a qualitative response.

Of the 12 qualitative responses, only one respondent suggested they had attempted to make claims against manufacturers with limited success. Others noted the barriers to legal action, with one noting the legal and contractual complexity as a significant barrier, especially for non-experts, and another noting difficulties arising from subcontractor insolvency and time lags between installation and a defect coming to light.

Some respondents pointed to the responsibility of others in the supply chain beyond manufacturers, such as specifiers and installers. Another response called for civil redress to include all affected parties, not just those with direct contractual relationships.

One respondent highlighted the lack of transparency with contractual routes, with some suppliers preferring private settlements to avoid legal and reputational risks. They highlighted that this limits broader industry learning, and made a suggestion for compulsory reporting of such settlements.

Question 51

Do you think that there are improvements that could be made to the current system to ensure that claims against manufacturers can be effectively pursued? [Yes/No]. If yes, please explain your answer.

83 respondents provided a response to this question. 104 respondents did not provide a response.

Question 51	No. Of Responses	% of all Responses	% of Ques. 51 respondents
Yes	54	28.9	65.1
No	19	10.2	22.9
Qualitative Response Only	10	5.3	12.0
Not Answered	104	55.6	-

Some respondents suggested that supply chain responsibilities and liabilities need to be made clearer, with some expressing frustration with the current ambiguity around accountability when things go wrong. This theme was raised by manufacturers, trade body/associations, professional institutions, CABs, and designers.

Views on who should take responsibility varied. Some respondents highlighted that manufacturers often distance themselves from liability once a product leaves their factories, leaving others, such as installers, to take on culpability. Others argued that if a product is misapplied or installed incorrectly, then fault should lie with the installer or other relevant supply chain actor rather than the manufacturer. Similarly, several respondents noted that as manufacturers lack sight of the final application of their products, it is essential that installers, designers and others take responsibility for correct usage. Another noted that importers and distributors should play a critical role, especially when manufacturers are located overseas.

Some respondents called for an alternative dispute resolution to improve the efficiency and effectiveness of building safety claims. Suggestions included introducing a fast-track service to expedite claims and enhance specialist knowledge within the courts, and establishing tribunal-based resolutions for cases that share common issues, supported by a standardised evidence framework.

Some respondents suggested that the government or the regulator should provide guidance and support with claims. This included suggestions for centralised advice and clear guidance on responsibilities, and a government-led claims support unit.

Some respondents suggested mandated insurance on manufacturers, such as bond schemes, or specialised insurance on certain products, to cover the costs of remediation if things go wrong.

Question 52

Do you think that there is anything additional that government should do to support effective redress against construction product manufacturers? [Yes/No]. If yes, please explain your answer.

77 respondents provided a response to this question. 110 respondents did not provide a response.

Question 52	No. Of Responses	% of all Responses	% of Ques. 52 respondents
Yes	43	23.0	55.8
No	28	15.0	36.4
Qualitative Response Only	6	3.2	7.8
Not Answered	110	58.8	-

This question raised similar themes to the previous question.

Some respondents pointed to the responsibility of others in the supply chain, including installers, designers and specifiers, importers and distributors, and engineers. Many of these noted the complexity of how construction products are used, meaning performance depends on factors such as installation, maintenance, and the building context. Suggestions were made for a holistic, system-wide approach that reflects this complexity.

Some respondents also suggested that government or the regulator should provide additional support with claims to reduce uncertainty, for example through technical guidance, template cases, and an online claims portal.

Chapter 10: Environment and sustainability

Question 53

Should these environmental aspects, as reflected in the revised EU Construction Products Regulation (EU-CPR), cover products subject to a designated standard or a technical assessment? [Yes/No].  Please explain your answer.

133 respondents provided a response to this question. 54 respondents did not provide a response.

Question 53	No. Of Responses	% of all Responses	% of Ques. 53 respondents
Yes	118	63.1	88.7
No	8	4.3	6.0
Qualitative Response Only	7	3.7	5.3
Not Answered	54	28.9	-

The majority of responses supported consistency with the environmental aspects reflected in the revised EU-CPR.

A range of benefits were raised across different responses including clear standards to align with, the benefits of supporting trade, preventing potential divergence and promoting the availability, consistency, and transparency of environmental data.

A concern raised was a need to address the potential for duplication of regulations and environmental information that may be required from economic operators if we do not maintain consistency with the EU. Some responses also raised the potential cost and resource burdens that could apply to economic operators, particularly SMEs if there is not a joined-up system.

There was support from both manufacturers and national representatives or trade bodies / associations for alignment with EU-CPR from an environmental perspective, to ensure consistency, reduce duplication and support trade.

A small number of respondents stated that safety is the primary concern and introducing environmental requirements may increase burdens on economic operators. The inclusion of environment and sustainability policy could also potentially undermine safety, as additional requirements may introduce greater complexities to already complex construction products.

Question 54

What, if any, approach might there be to measuring and/or mitigating the environmental impact for products brought into the regulatory regime through a general safety requirement and should this be mandatory or voluntary? Please explain your answer.

115 respondents provided a response to this question. 72 respondents did not provide a response.

An emerging theme from responses was support for a mandatory approach to measuring and mitigating the environmental impact of construction products. Respondents highlighted that voluntary measures could be insufficient and not deliver Net Zero goals. Consistency and data transparency was also highlighted, with an emphasis on the need for consistent standards.

There was also some support for mandatory Environmental Product Declaration/Life Cycle Assessment (EPDs/LCAs).

Some responses also outlined a voluntary approach to measure and mitigate the environmental impact of construction products. Respondents suggested that environmental performance should be market driven or optional, safety must remain the core focus and any new approaches should avoid increasing the regulatory burden on the sector.

As well as there being support for both mandatory and voluntary approaches, some responses referred to having a consistent and standardised way to measure and mitigate environmental impacts. Some responses outlined that, if an EPD/LCA is going to be produced (voluntarily), this should be done using the methodology of EN 15804.

Some responses highlighted the need to avoid burdens on SMEs and wider manufacturers. These respondents also emphasised the need to support or assist SMEs to meet obligations.

Question 55

Do you support the proposed actions above? (As set out in Chapter 10). [Yes/No]. Are there any other actions that could be taken and by whom (e.g. government/industry)? Please explain your answer.

127 respondents provided a response to this question. 60 respondents did not provide a response.

Question 55	No. Of Responses	% of all Responses	% of Ques. 55 respondents
Yes	95	50.8	74.8
No	16	8.6	12.6
Qualitative Response Only	16	8.6	12.6
Not Answered	60	32.0	-

For proposed action 1 (“Making software available to perform standardised life cycle environmental impact calculations”) there was some support for making software available. Concerns were also raised including duplication with existing commercial tools, cost burdens, data quality verification and consistency across platforms were often highlighted. There was support for government to fund access for SMEs to such software and for clear guidance and training.

For proposed action 2 (“Deposit Refund Systems”) there was some support in principle, especially for short-life modular products. However, many flagged practical challenges, such as issues for bespoke products (products that are custom-made or tailored for a specific project or client, rather than mass-produced or standardised items), intermediary sales and logistics.

For proposed action 3 (“Spare Parts Provision”) there was some support for the proposed action with some product types. However, it was not seen as practical for all, such as long-life and bespoke construction products. Responses suggested that time limits and product-specific approaches would be beneficial and emphasised the need for proportionate, product-specific requirements and maintaining safety standards.

For proposed action 4 (“Database of Reused Products”) there was some support in principle, but concerns around implementation, liability, and data management. Some of the recommendations included integrating existing platforms, government-backed certification and pre-demolition audits.

A few responses provided additional recommendations such as fiscal incentives and industry-government collaboration on standards and enforcement.

Chapter 11: Further evidence requirements

Question 56

Could you share any relevant information about the estimated size of the market as outlined in Chapter 1, and the construction products sector more broadly and its significance. If relevant to our wider reforms please refer to which part it is relevant to.

34 respondents provided a response to this question. 153 respondents did not provide a response.

There was quite a low response rate for this question, which potentially reflects the lack of evidence and data behind the size of the sector.

Of those that did respond, most didn’t provide quantitative estimates of the sector. They instead emphasised the size and importance of the sector, as well as highlighting the complexity of the industry as a whole.

A few of the quantitative estimates given were in reference to the Construction Products Association’s (CPA’s) estimates of the sector.

Many responses mentioned data behind specific sub-sectors. This included figures for the sprinkler industry, steel market, electrotechnical sector, doors/fire doors market, single ply roofing, electric cables and wiring industry, passive fire protection products sector, and the bathroom sub-sector.

Question 57

What direct or indirect costs could yourself, businesses and wider society have due to our proposed reforms? - Please explain your answer.

109 respondents provided a response to this question. 78 respondents did not provide a response.

A majority of responses mentioned potential costs in testing and training as a result of reforms. This was mostly brought forward by manufacturers, trade associations or professional bodies. Local authorities were more likely to mention costs in production and architects were focused on the design process becoming more difficult.

Some respondents also highlighted costs to wider society including whether complexities in the reforms could create issues for the supply chain or harm growth of the sector. As a significant industry, this could impact economic growth. Some responses also mentioned that potential higher costs could be passed onto consumers.

Some respondents noted EU alignment as a key area, with all responses supporting alignment to avoid the costs of divergence with the EU regime. Environmental aspects of the reforms were also raised, with concern on the additional burden that environmental obligations may place on the industry.

There was also concern from a number of respondents over the cost to CABs and local authorities of the reforms in a sector that is already struggling with capacity. The majority of these responses came from CABs or LATS themselves however this was also raised from other types of respondents.

Conversely, many respondents went outside of the proposed remit of the question to highlight benefits of the reforms. Around a quarter of responses discussed the benefits, ranging from improved safety and lower risk to a more efficient and competitive supply chain.

Question 58

Is there anything else you would like to inform us of, that you have not been able to through other questions in this publication? Please explain your answer.

88 respondents provided a response to this question. 99 respondents did not provide a response.

The nature of the question resulted in a diverse range of topics and areas being highlighted in consultation responses. We have noted several key areas below, but this is not an exhaustive list.

A common theme was the recognition that the current regulatory regime is inadequate and that a system-level approach is necessary. Some respondents stressed that reforms must be proportionate to the risk and that without effective implementation there were risks of higher costs and/or fewer products.

Many respondents noted the role that standards play, and will continue to play, in supporting compliance, accountability and enabling best practice through elimination of gaps in interpretation and providing clarity. Some noted that updates and changes to standards need to be faster, more transparent, visible and consistently enforced.

A number of responses communicated the need for transparency and responsibility throughout the system. This ranged from transparent data, product information, guidance, standards and clarity around implementation. Professional bodies, trade associations and national bodies suggested the stronger utilisation of industry networks to support development, outreach and implementation of reforms and future processes.

Some responses noted the need to improve education and upskill sectors to ensure a skilled and competent workforce across all areas. A few responses called for a national construction skills strategy.

Implementation was a common theme, with respondents noting the need to implement reforms with some urgency, though this should be balanced with clarity and competence with the implementation and the need in some cases for further detailed consultation.