Law in force
Materials must suit the circumstances they are used in
Building work in England must be carried out with adequate and proper materials which are "appropriate for the circumstances in which they are used", are adequately mixed or prepared, and are "applied, used or fixed so as adequately to perform the functions for which they are designed".
Why it matters for product evidence
This is the duty the evidence has to satisfy. It is written about the circumstances of use on a real project, not about the product considered on its own. A document that describes the product but not the circumstances has not finished the job.
Law in force
A product mark is not a statement that the product suits your use
A UKCA or CE mark on a construction product records that the manufacturer takes responsibility for the product conforming to its declared performance. The government's own description is blunt about the limit: "the presence of a mark does not provide assurances as to the suitability of a product for a specific use".
Why it matters for product evidence
This is the most common evidence gap we see. A mark, a certificate and a data sheet can all be genuine and current and still not reach the question a project is actually asking.
Law in force
Declared performance is tied to a declared intended use
Where a product is covered by a designated standard or a UK technical assessment, the manufacturer draws up a declaration of performance. It states the intended use or uses, the essential characteristics set by the technical specification, and the performance of at least one of them.
Why it matters for product evidence
Reading a declaration of performance properly means reading what it was declared for. The intended use is not a formality at the top of the page. It is the boundary of what the declared figures support.
Watch
A large part of the market sits outside the product regulations
Research carried out for government found that between 29% and 61% of UK construction products fall under a designated standard, with a central estimate that "around 37% of the UK market is regulated under the Construction Products Regulations". Products outside that scope, and outside technical assessment, are not subject to those mandatory requirements.
Why it matters for product evidence
It changes what you should expect to be handed. Outside that scope there is no mandatory declaration of performance, so the evidence offered is voluntary in origin and its scope is set by whoever commissioned it.
Proposed, not law
Construction products reform: where it actually stands
The Construction Products Reform White Paper (CP 1515) and the consultation on a General Safety Requirement (CP 1516) were both published on 25 February 2026 and both closed on 20 May 2026. In its September 2026 progress report the government said it intends to publish responses to both consultations later in the year, and to bring forward legislation "when Parliamentary time allows".
Why it matters for product evidence
Proposals are not requirements. Nothing in the White Paper changes what evidence a project needs today. It is worth tracking because it signals what manufacturers and specifiers will be asked for later.
Proposed, not law
A General Safety Requirement is proposed for products outside the current regime
The proposed General Safety Requirement would apply to construction products not covered by a designated standard or technical assessment. As consulted on, it would require manufacturers to identify and assess safety risks connected to a product's intended and reasonably foreseeable conditions of use, and to supply defined product information, installation guidance and safety information.
Why it matters for product evidence
If it is made law, a large part of the market that currently issues no mandatory declared performance would have to state what a product is for and what its risks are. That is the same question a project asks, written into the regime.
Proposed, not law
Testing and certification: proposals to license the bodies that certify
Government has set out concerns about conformity assessment bodies, including conflicts of interest, transparency and inconsistent testing, and has proposed licensing all UK conformity assessment bodies and requiring the national regulator to approve third-party certification schemes. In September 2026 it confirmed it does not intend the regulator itself to test and certify products, and will strengthen oversight of certification bodies instead.
Why it matters for product evidence
A certificate carries the authority of the scheme behind it. Until the proposed changes land, schemes differ in scope, in what they check and in what they publish, so what a certificate covers still has to be read rather than assumed.
Proposed, not law
Traceability: linking what was installed back to what was assessed
Government describes fragmented digitalisation, poor access to standardised product data and "limited product traceability from manufacture to installation". Its stated ambition is digital product records, digital identifiers and associated traceability requirements, developed with industry.
Why it matters for product evidence
Traceability is the practical side of evidence. Where nobody recorded which product, which batch and which version of the documents were used, the evidence trail has to be rebuilt later from whatever survives. Keeping a clear source, version and decision record is the cheapest point in the job to fix that.
Watch
Products work as systems; the regime is still product-shaped
The government's own diagnosis: "Safety depends not just on individual products but on how they interact as part of a system in buildings and infrastructure projects. Current regulations do not adequately address system-level risks or the role of those designing and specifying buildings, installing, or using products."
Why it matters for product evidence
Most questions that reach us are about a build-up, not a product. Evidence is usually produced product by product, so the interfaces, the fixings, the substrate and the order of layers are frequently the part nobody has documented.
Law in force
Substitution changes the evidence, not only the product
Where a specified product is swapped for another, regulation 7 still has to be satisfied by whatever is actually built. Under the reform proposals, a party substituting a specified product would be treated as taking on specifier and designer responsibilities for that decision.
Why it matters for product evidence
Substitution is usually handled as a procurement decision and only later discovered to be an evidence decision. The replacement has its own declared performance, its own intended use and its own tested build-ups, and they rarely match the original line for line.
Law in force
Competence is a legal requirement on all building work in England
Anyone carrying out building work or design work must have the skills, knowledge, experience and behaviours necessary, or, if not an individual, the organisational capability, to carry out that work in accordance with all relevant requirements.
Why it matters for product evidence
Deciding whether a document supports a proposed use is a technical judgement, and the regulation applies to the person making it. It is a good reason to write down what the evidence supports and where it stops, rather than leaving the judgement undocumented.