Historically, the EU’s Construction Products Regulation (CPR) has focused on ensuring construction products, such as building materials and fire safety products for buildings, meet technical and safety standards. A new version has now been adopted, paving the way to include environmental requirements (known as environmental essential characteristics).

 

Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products, came into force on 7^th January 2025 and will replace the previous version of the CPR (Regulation (EU) 305/2011) over time.

 

There are 2 key changes introduced by the updated Regulation:

• Harmonised standards for construction products will be further developed to include environmental requirements which will apply from 8^th January 2026.
• A digital product passports (DPP) system covering construction products will be introduced by the European Commission.

The new rules will impact manufacturers of construction products, as well as other economic operators who place these products on the EU market (including Northern Ireland), with requirements to ensure that products are sustainable, and that consumers are provided with increased environmental information.

 

Whilst the new version of the CPR won’t have an immediate impact on most organisations, it’s recommended that those who manufacture or supply construction products in the EU and/or Northern Ireland ensure they are familiar with and prepare for changes in requirements.

 

Digital product passports systems

 

The Regulation requires the EU Commission to establish a digital products passports (DPP) system for construction products. The system will hold key information on products, their technical specifications and environmental data. This will make it easier for users to check they are using compliant products and access information on the environmental impact of products.

 

Manufacturers will be required to comply with the requirements of the digital passport system for construction products within 18 months of its implementation.

 

Environmental essential characteristics

 

Harmonised standards will be developed and expanded to include environmental requirements.

The first requirements which relate to climate change effects will apply from 8^th January 2026, with additional environmental requirements applying from 9^th January 2030 and 2032.

 

It is expected that the first products impacted by updated standards will be those most associated with environmental impacts such as concrete and steel.

 

Environmental Essential Characteristic	Date from which Harmonised Technical Specifications will Cover Characteristics
• Climate change effects – total. • Climate change effects – fossil fuels. • Climate change effects – biogenic. • Climate change effects – land use and land use change.	8th January 2026
• Ozone depletion. • Acidification potential. • Eutrophication aquatic freshwater. • Eutrophication aquatic marine. • Eutrophication terrestrial. • Photochemical ozone. • Abiotic depletion – minerals, metals. • Abiotic depletion – fossil fuels. • Water use.	9th January 2030
• Particulate matter. • Ionising radiation, human health. • Eco-toxicity, freshwater. • Human toxicity, cancer. • Human toxicity, non-cancer. • Land use related impacts.	9th January 2032

Important note for LUS subscribers:

We have added a new profile code in the environment register for subscribers that this new legislation is relevant for.

 

You can add the ‘Manufacture and supply of construction products’ profile code in your register setup by following the steps here.

 

This will automatically add the entry for Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products in your register if you have the EU selected as an applicable jurisdiction, as well as any additional future environment legislation relating to construction products.

Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (EUDR) is intended to minimise global deforestation, reduce greenhouse gas emissions and prevent biodiversity loss.

EUDR sets rules on products being placed on the EU market or being exported from the EU if they are produced from commodities which pose a risk of deforestation anywhere in the world. The Regulation covers a wide range of products listed in Annex I and is particularly relevant for the food and timber industries.

The 7 relevant commodities covered under EUDR are:

• cattle;
• cocoa;
• coffee;
• palm oil;
• rubber;
• soya; and

Originally intended for implementation at the end of 2024 the EU Parliament voted on 14^th November 2024 to make amendments to EUDR, extending the implementation deadlines to:

• 30^th December 2025 for medium and large organisations; and
• 30^th June 2026 for micro and small enterprises.

In addition to delaying implementation dates, the EU Parliament also agreed to include less stringent requirements when importing products from countries classified as ‘no risk’. The EU’s benchmarking of countries for EUDR is scheduled to be finalised by 20^th June 2025.

N.B. EUDR replaces the EU Timber Regulation (Regulation (EU) 995/2010) expanding requirements and the scope of products covered. Timber product types not covered under the EU Timber Regulation but now covered under EUDR are exempt from EUDR provided they were produced before 29^th June 2023. Products covered by the EU Timber Regulation produced before 29^th June 2023 are covered by that regulation until 31^st December 2027, after which point they are covered by EUDR.

EUDR Rules

The rules apply directly to organisations established in any EU country who place products on the market or export them (EU operators and traders), but is relevant to all organisations within the entire supply chain, regardless of where in the world they are based.

EU operators and traders must ensure that relevant products and commodities are:

• deforestation-free;
• produced legally in the country of production; and
• covered by a due diligence statement.

EU operators and traders must prove products are compliant through the collection of information, documents and data and using this assess the risk of products being non-compliant. This includes being able to trace products and commodities back to their source. Records must be kept for 5 years.

Non-EU organisations who manufacture and supply relevant products and commodities up the supply chain will need to support EU organisations by providing evidence to prove where goods originated from, that they are deforestation-free and have been produced legally. Exporting relevant products and commodities to the EU which cannot be verified for compliance runs the risk of the goods being stopped by customs, or rejected by EU customers.

Additional information on EUDR can be found on the European Commission website here.

Lithium batteries are a common feature in our modern world, powering everything from mobile phones to vehicles.

 

Given the potential safety and environmental risks posed by batteries, we’re regularly asked about the key requirements for safe transportation, storage and disposal.

 

In this article we will look at the key requirements to minimise risk and ensure compliance.

 

Transportation

 

Lithium ion batteries with a nominal capacity exceeding 100 Wh and lithium metal batteries containing over 2g of lithium are classed as dangerous goods (Class 9), as such there are strict requirements for transporting them via road, air, sea and rail.

 

Simplified requirements apply for other lithium batteries that do not reach these thresholds.

 

The rules for transporting dangerous goods are complex, with duties placed on those who send, transport, and receive dangerous goods. Requirements include strict special instructions and packaging instructions, which must be applied when transporting batteries. 

 

The appointment of a Dangerous Goods Safety Advisor (DGSA) is required for any activities involving the transportation of dangerous goods.

 

General requirements for shipping and transporting batteries include that they must:

• be labelled correctly, using the relevant battery label based on the UN classification, and where required, a class 9 dangerous goods label;
• only be transported by those licensed if classed as dangerous goods; and
• be carried in accordance with legal requirements, adhering to special provisions and packaging instructions.

 

The UN classifications for the transport of lithium batteries are:

• Lithium ion batteries
  • UN 3480 – batteries shipped by themselves
  • UN 3481 – batteries shipped in equipment, or packed with equipment
• Lithium metal batteries
  • UN 3090 – batteries shipped by themselves
  • UN 3091 – batteries shipped in equipment, or packed with equipment