SME- FRIENDLY IMPLEMENTATION OF ENVIRONMENTAL SUSTAINABILITY REQUIREMENTS UNDER CONSTRUCTION PRODUCTS REGULATION (EU) 2024/3110
Small Business Standards (SBS) and the European Builders Confederation (EBC) welcome the European Commission’s commitment to integrating environmental sustainability into the legal framework governing construction products. While the objectives of the revised Construction Products Regulation (EU) 3110/2024 (hereinafter “the new CPR”) are broadly supported, the modalities of implementation, particularly as regards sustainability, raise important economic and technical challenges for all manufacturers, but especially for SMEs.
The integration of environmental sustainability into the CPR represents an opportunity to support the EU’s climate and environmental objectives. However, implementation must remain realistic and inclusive. A rigid, one-size-fits-all approach risks discouraging SME participation, increasing compliance costs, and distorting market outcomes.
We call for a system that is transparent, practical, and proportionate, that recognises the diversity of business models in the construction sector and offers fair opportunities for SMEs to comply. This includes access to affordable data, flexibility in verification methods, recognition of shared declarations, and tools that are designed with SMEs in mind.
SME users should also be taken into consideration, as they rely on environmental information that is both reliable and affordable to guide their purchasing and design decisions. If data is inflated due to worst-case assumptions or fragmented across an excessive number of product types, it becomes less useful and harder to interpret. This not only increases costs but also undermines trust in the system. Ensuring that environmental declarations are proportionate, comparable and accessible is essential for SME users to engage meaningfully in sustainable construction practices and support the CPR’s objectives.
We remain committed to contributing constructively to this process and encourages the Commission, the Member States, and other stakeholders to ensure that SME-specific impacts are considered at every stage of implementation.
Read the full position paper below:
