Construction Products Reform: The Burden of Proof Shifts to Manufacturers and Suppliers (Guest Article)

By Brittany Harris, Co-founder and CEO, Qflow, which uses AI to enable construction teams to cut carbon and waste from the construction process.

The Construction Products Reform (CPR) Whitepaper¹, published in February 2026, has landed with real impact. For manufacturers and suppliers, it is the document that changes the operating model.

Read More...

CPR responds directly to the failings exposed by the Grenfell Tower tragedy: poor product data, misleading certification and a regulatory framework that was never designed for safety first. The General Safety Requirement, expected to come into force in late 2027, will pull every product into scope. That reform is long overdue, and most manufacturers I speak with agree.

What changes for manufacturers and suppliers

The substance of CPR puts manufacturers and suppliers in a different place to where they sit today. Product information has to be relevant, evidence-backed and accessible. Test data must support performance claims. Information that affects certificate validity must be disclosed. Mandatory digital product information, unique identifiers and QR codes linked to live performance data all become the norm rather than the exception.

For some, that is a manageable extension of how they already operate. For others, it will involve a meaningful change. Either way, the burden of proof on what a product is and what it does sits more squarely with the people who make and supply it.

Accountability does not stop at the factory gate

A central ambition of CPR is to make accountability clear across the full product lifecycle, from manufacture through to installation. Importers, distributors, designers and contractors all carry responsibility downstream. Yet the manufacturer still sets the baseline. The information you publish is what the rest of the chain relies on.

Where that information lands matters as much as how it is produced. A QR code on a product label is a starting point. Its value depends on whether the data behind it survives the journey to a delivery on site, and whether it can be reconciled with what was actually specified and installed.

The 'as-built' gap

For many products, the hardest issue in the chain is the gap between what was specified and what gets installed. Everyone knows that substitutions happen. But by the time anyone tries to verify the product on site against the specification, it is often too late to reconcile.

That is where 'as-built' data earns its place. Digital tools like Qflow help site teams capture each delivery digitally at the gate and link it back to specification, which is also how manufacturer data informs a credible Golden Thread of traceability, rather than disappearing at the point of handover.

Why acting now is worth it

The consultation closed in May. The lead time to H2 2027 is finite. Organisations that act now to build proper data capture and genuine traceability into how they operate will be in a stronger position when enforcement begins.

There is a quieter benefit too. As CPR moves from paper to practice, clients, principal contractors and regulators will increasingly look for hard evidence as opposed to assurance theatre. The manufacturers and suppliers who are ready and able to provide it will stand out against their competitors.

Notes:
1. https://www.gov.uk/government/consultations/construction-products-reform-white-paper/construction-products-reform-white-paper

Construction Products Reform