Construction Products Reform White Paper 2026: What Architects Need to Know

The construction products regulatory landscape is undergoing one of its most significant changes since the Grenfell Tower tragedy.

Published by the UK Government on 25 February 2026, the Construction Products Reform White Paper sets out a comprehensive package of reforms intended to address systemic weaknesses in the way construction products are tested, assessed, marketed, supplied and monitored.

For architects, this is particularly important. While the reforms do not turn architects into product regulators, they will change the evidence, information and responsibilities surrounding product specification and selection.

Why are construction products being reformed?

The reforms can be traced directly back to the Grenfell Tower fire in June 2017.

The Grenfell Tower Inquiry Phase 2 report, published in September 2024, identified systemic failures within the construction products regulatory system. It found that weaknesses in the existing framework had allowed manufacturers to exploit the system and that public safety had not been adequately protected.

Two further reviews also contributed to the reform programme:

• Dame Judith Hackitt's review

• The Morrell-Day Review into product testing and certification

Both highlighted significant problems with the existing approach to testing, certification and marketing construction products.

One particularly significant issue is the scale of the regulatory gap.

Government-commissioned research by the Adroit Consortium suggests that only around 37% of construction products currently on the UK market have a designated standard.

This means that approximately 63% sit outside the existing regulatory regime.

The Government first responded with the Construction Products Reform Green Paper in February 2025.

The White Paper, published on 25 February 2026, represents the next major step in that reform programme.

A new two-route regulatory framework

One of the central proposals is the introduction of a two-route regulatory framework covering construction products.

Route A: Products covered by designated standards

Route A applies to products regulated by designated standards or technical assessments.

These products will continue to be subject to requirements around:

• Declaring product performance

• Demonstrating compliance

• Providing relevant product information

• Applying the appropriate product marking

The Government also intends to maintain consistency with the reformed EU Construction Products Regulation 2024where this aligns with UK objectives, helping to reduce trade friction while maintaining safety standards.

Route B: Products without designated standards

Route B is arguably the more significant change.

It covers products that are not currently covered by a designated standard or technical assessment.

These products would come within a proposed General Safety Requirement (GSR) for the first time.

This is important because it is intended to close the gap affecting the approximately 63% of products currently outside the regulatory framework.

The General Safety Requirement would create a mandatory, risk-based and proportionate duty on manufacturers to ensure their products are safe before placing them on the market.

What is a "safe" construction product?

Under the proposed General Safety Requirement, a product would be considered safe where, under normal or reasonably foreseeable conditions of use, it does not present a risk to people's health or safety or where any risk is reduced as far as reasonably possible in accordance with the intended use of the product.

Importantly, safety would not simply be assessed by looking at the physical product in isolation.

Factors would include:

• The product's characteristics, composition and intended use

• How the product is presented

• Product instructions

• Its interaction with other products

• The people who may handle or be exposed to it

• Its lifecycle and duration of use

• How it is stored and transported

This represents a much more holistic approach to product safety.

What will manufacturers and suppliers need to do?

The General Safety Requirement would place greater responsibilities on manufacturers and other economic operators.

Manufacturers would need to undertake mandatory risk assessments, identify safety risks associated with intended and reasonably foreseeable use, and take proportionate measures to eliminate or control those risks.

They would also need appropriate factory production controls, clear and accurate product information, and evidence to support any safety claims they make.

Traceability is another important part of the proposed reforms.

Products would need to include information such as:

• The manufacturer's registered name and address

• A unique product identifier

• A data carrier, such as a QR code, linking to digital product information

Manufacturers and importers would also need to retain relevant risk assessments, product documentation and safety incident records for 10 years after the product was last supplied.

The responsibilities would not stop with manufacturers.

Importers and distributors would also have duties to ensure products are safe, that the necessary documentation is available, and that storage and transportation do not compromise product safety.

The Government intends to introduce the new requirements through secondary legislation under the Building Safety Act 2022, with the aim of introducing regulations by the end of 2026 and bringing them into force in late 2027, subject to parliamentary time.

Products critical to safe construction

Alongside the two-route framework, the White Paper proposes enhanced requirements for products considered critical to safe construction.

These are products where failure could result in death or serious injury.

The national regulator would have the ability to apply additional measures where simply complying with a designated standard is not considered sufficient to ensure safe use.

This has a direct relevance for architects.

The White Paper proposes enhanced obligations for Building Regulations Principal Designers and contractors in relation to the selection and installation of critical products.

The RIBA has raised concerns about this approach, particularly around the need to recognise that responsibility for product selection can be distributed across the wider design and construction team rather than being concentrated on one individual role.

This is an important distinction.

Product selection is rarely the responsibility of one person alone.

Architects, engineers, contractors, specialist subcontractors and suppliers may all influence which products ultimately make their way into a building.

The regulatory framework therefore needs to reflect how projects actually operate.

The move towards digital product information

Another major area of reform is product information and digitalisation.

The White Paper proposes that construction products should have clear and accessible information covering areas such as:

• General characteristics and intended use

• Technical specifications

• Installation guidance

• Safe use, disposal and maintenance

• Environmental performance

• Declarations of performance and conformity

• Unique identifiers and versioning

• Certification and assessment information

• Safety evidence, warnings and test results

• Storage and transportation guidance

But the bigger change is the move towards digital product information.

Product labels would include unique identifiers linked to up-to-date information through digital labels, such as QR codes.

The Government is also exploring the introduction of Digital Product Passports, or an equivalent system, for products covered by designated standards.

The longer-term objective is to make product information interoperable, accessible and capable of being maintained over time.

A national digital construction library

The White Paper also proposes a national digital construction library.

This follows a recommendation from the Grenfell Tower Inquiry that designers, particularly those working on higher-risk and complex buildings, should have access to reliable information about construction products to support safe design decisions.

The proposed library could provide access to information including:

• Product information

• Fire safety reports

• Academic research

• Test data

• Other evidence needed to support safe product selection

For architects, this could be a significant development.

Instead of relying on fragmented manufacturer information, archived documents or outdated product literature, practices could have access to a more centralised source of information to help select, verify and record product evidence.

It also reinforces the importance of the golden thread of information within the wider building safety framework.

Reforming testing and certification

The White Paper also proposes changes to the testing and certification system.

Currently, Conformity Assessment Bodies (CABs) assess whether products meet specified requirements, with UKAS responsible for accreditation.

The proposed reforms would introduce a licensing regime for UK Conformity Assessment Bodies, requiring them to be licensed by the national regulator and to act in the public interest.

The Government also intends to develop additional public-sector testing capacity to support enforcement and research.Third-party certification schemes would also be subject to greater oversight and transparency.

Another important proposal is the introduction of baseline competence requirements for those involved in designing, testing and manufacturing construction products. This effectively extends the principle of competence further back into the product development chain.

Stronger enforcement

The reforms also strengthen the role of the national regulator for construction products.

The Office for Product Safety and Standards (OPSS) has operated as the National Regulator for Construction Products since 2021.

The White Paper proposes enhanced powers around:

• Market surveillance

• Investigation

• Enforcement action

• Potential civil monetary penalties

Enforcement would remain a shared responsibility between the national regulator and local authority trading standards.

There is also a wider structural change on the horizon.The Government has proposed a Single Construction Regulator, bringing together the functions of the national regulator for construction products and the Building Safety Regulator. This follows the first recommendation of the Grenfell Tower Inquiry Phase 2 report, with a transitional approach expected before functions are fully transferred.

So, what does all of this mean for architects?

Perhaps the most important point is that architects are not becoming product regulators.

However, the evidence environment in which architects specify, review and approve products is changing significantly.

1. Product specification will need to be more evidence-based

Architects should increasingly expect to see evidence supporting product claims.

This means checking that products have the appropriate markings, that declarations of performance are available where required, and that relevant safety information accompanies the product.

The direction of travel is clear:

Marketing claims alone will not be enough.

2. Practices will need better product information systems

As product information becomes increasingly digital, practices will need to consider how information is:

• Accessed

• Checked

• Stored

• Updated

• Shared

• Traced throughout the project lifecycle

This becomes particularly important for higher-risk buildings, where the ability to demonstrate the basis for design and specification decisions is fundamental to the golden thread approach.

3. Product substitutions need careful scrutiny

Product substitutions are another area where architects need to remain vigilant.

If a contractor or supplier proposes an alternative product, particularly where the original product is critical to safe construction, the proposed substitution needs to be carefully assessed.

Architects should also consider whether their appointments and contracts provide the appropriate rights to review and reject substitutions that do not satisfy the required safety criteria.

4. Competence and CPD will remain important

The regulatory landscape around construction products is becoming more complex.

The White Paper also references BSI PAS 2000:2026, Construction Products: Bringing Safe Products to Market, which provides a framework for manufacturers demonstrating that reasonable steps have been taken to ensure products are safe.

There are also proposed environmental assessment requirements that would progressively introduce declarations against 19 essential environmental characteristics, including areas such as climate impact and water use.

For architects, this means continuing professional development will be essential not necessarily to become specialists in every construction product, but to understand what evidence to look for, where responsibilities sit and when further specialist advice is required.

The bigger picture

The Construction Products Reform White Paper should not be viewed in isolation.

It is part of a much wider transformation of the UK's building safety framework.

The Building Safety Act 2022 introduced new duties around building safety, competence, the Principal Designer role and the golden thread of information. The Construction Products Reform White Paper extends this regulatory thinking further down the chain into the products themselves.

The underlying principle is becoming increasingly clear:

Safe buildings require safe products, reliable information and competent decision-making throughout the entire lifecycle.

For architects, that means being able to demonstrate not only what product was specified, but increasingly why it was selected, what evidence supported that decision, and whether the product ultimately installed is the product that was assessed and approved.

Key takeaways

• The Construction Products Reform White Paper was published on 25 February 2026.

• It responds to systemic failures identified following the Grenfell Tower Inquiry.

• The proposed framework introduces two regulatory routes for construction products.

• The proposed General Safety Requirement would bring currently unregulated products into the regulatory regime.

• Approximately 63% of construction products currently sit outside a designated regulatory framework.

• Product specification is becoming increasingly evidence-based.

• Digital product information, QR codes and potentially Digital Product Passports will become increasingly important.

• A national digital construction library is proposed to improve access to reliable product information.

• Safety-critical products would be subject to enhanced requirements.

• Product substitutions will require greater scrutiny.

• Testing and certification bodies would face stronger oversight and licensing requirements.

• Competence requirements would extend further into the construction product supply chain.

• The reforms form part of the wider Building Safety Act and golden thread framework.

• Regulations are intended to be introduced by the end of 2026, with the new regime expected to come into force in late 2027, subject to parliamentary time.

Ultimately, the Construction Products Reform White Paper represents a significant shift towards greater accountability, transparency and evidence across the construction product supply chain.

For architects, the message is not that we need to become product regulators.

It is that we need to become increasingly informed, critical and evidence-led when specifying and reviewing the products that make up our buildings.