The European Steel Association (EUROFER) broadly welcomes the Commission’s proposal for a revised Construction Products Regulation (CPR) and supports the following elements in particular:

• Alignment with the Ecodesign for Sustainable Products Regulation (ESPR) proposal is essential for the steel sector which supplies to many different market sectors, with many steel products having ‘dual use’ in several applications including construction.
• The setting of minimum environmental performance requirements covering a broad spectrum of criteria will help create a level playing field in the construction market, that recognises environmentally sustainable products, without being undercut by lower performing products.
• The proposal also helps enforce the single market and a level playing field by preventing different environmental requirements in each member state.
• The potential of setting minimum requirements for Green public procurement will help drive the environmental sustainability of products.
• The limitation of requirements for reused products (under certain circumstances), must ensure the performance properties of the product are still matching the conditions of the original DoP and in accordance with other relevant CPR requirements.
• The role of harmonised technical specifications (standards) is retained to support the setting of product essential characteristics.
• The clarification of procedures and coordination in the area of voluntary European assessment documents (EAD) will help avoid unnecessary overlaps with harmonised standards.
• Reinforcing market surveillance will help enforce a level playing field for manufacturers.

EUROFER has identified the following clarifications and improvements that should be addressed during the co-decision procedure:

• Delegated acts
• Green public procurement
• Product requirements
• Additional environmental obligations of manufacturers
• Digital Product Passports
• Other sustainability aspects.

The full text of the position paper on the revision of Construction Products Regulation 2022/0094 (COD) is available below.