Statutory Inspections · Mandatory · Construction

Construction Products Compliance Register

A site-level register recording every significant construction product used on a project — its UKCA/CE markings, Declaration of Performance, test certificates, third-party approvals, and installation location. Mandatory for HRBs as part of the BSA 2022 golden thread. The Construction Products Reform White Paper (February 2026) proposes extending mandatory traceability to all projects. Focuses on structural safety, fire performance, and weathertightness products.

Last reviewed: 2 April 2026 — This guide reflects UK law as of this date. BSA 2022 / Construction Products Regulations 2013 remains current with no amendments enacted as of 2 April 2026. Next scheduled review: 2 April 2027.

Template reference	T20 Construction Products Compliance Register
Primary legislation	Building Safety Act 2022 (BSA) / Construction Products Regulations 2013 / OPSS enforcement
Driver	Grenfell Tower Inquiry recommendations — product traceability and accountability
Golden thread	Mandatory for Higher-Risk Buildings (HRBs) under BSA 2022 — digital record of all product information
Reform	Construction Products Reform White Paper (February 2026) proposes extending requirements to all projects
Enforcing authority	Office for Product Safety and Standards (OPSS) / Building Safety Regulator (BSR)

1. What It Covers

The Construction Products Compliance Register is a systematic record of every construction product installed on a project, documenting its manufacturer, specification, performance characteristics, test certification, marking, and the location in which it was installed. The register was driven by the Grenfell Tower Inquiry findings, which exposed catastrophic failures in the traceability and accountability of construction products — particularly cladding, insulation, and fire-stopping materials.

The Building Safety Act 2022 introduced the concept of the ‘golden thread’ of building information for Higher-Risk Buildings (HRBs) — buildings at least 18 metres or 7 storeys in height containing at least 2 residential units. The golden thread requires a digital record of all design and construction information, including detailed product information, that is maintained throughout the building's lifecycle. The Construction Products Compliance Register is a core component of the golden thread for HRBs.

The Construction Products Regulations 2013 (retained from the EU Construction Products Regulation) require manufacturers to issue a Declaration of Performance (DoP) and apply UKCA or CE marking to construction products covered by a harmonised standard. The Office for Product Safety and Standards (OPSS) is the enforcing authority for construction product safety and has the power to withdraw non-compliant products from the market. The Construction Products Reform White Paper published in February 2026 proposes extending mandatory product registration and traceability requirements to all construction projects, not just HRBs — making best practice today a legal requirement in the near future.

Link the product register to the O&M Manual and H&S File at handover

The Construction Products Compliance Register must be handed over as part of the O&M Manual and the Health and Safety File at project completion. For HRBs, it forms part of the golden thread that the Accountable Person must maintain throughout the building's life. For all projects, it provides the building owner with a definitive record of what was installed, where, and to what specification — essential information for future maintenance, alteration, and fire risk assessment.

2. Key Content

The following table sets out the information that must be recorded in the Construction Products Compliance Register for each product category and individual product installed.

Element	Detail
Project reference	Site name, address, and unique project reference. Building Safety Regulator reference (for HRBs). Principal contractor and principal designer details.
FOR EACH PRODUCT CATEGORY	Products grouped by category: structural frame, external wall system, insulation, fire-stopping, fire doors, roofing, windows and glazing, mechanical systems, electrical systems, internal linings, flooring, and any other safety-critical products. Each category is recorded separately with full product details.
Product name	Full commercial product name as stated by the manufacturer. Must match the product name on the Declaration of Performance and UKCA/CE marking.
Manufacturer	Full legal name and registered address of the manufacturer. Not the distributor, supplier, or installer — the actual manufacturer of the product.
Product reference / batch	Manufacturer's product reference number, batch number, and (where applicable) serial number. This enables traceability back to the specific production run in the event of a product recall or safety concern.
UKCA / CE marking	Confirmation that the product bears a valid UKCA mark (for products placed on the GB market) or CE mark (for products placed on the NI market or under transitional arrangements). Record the marking reference and the notified body number (where applicable).
Declaration of Performance	Reference number of the manufacturer's Declaration of Performance (DoP). The DoP sets out the essential characteristics of the product and the declared performance against each characteristic. A copy of the DoP must be retained in the register.
Performance characteristics	Key performance characteristics relevant to the product's intended use: fire reaction class, fire resistance, structural load capacity, thermal performance, acoustic performance, weather resistance, and any other characteristics specified in the project design.
Test certificate(s)	Reference to independent test certificates that support the declared performance. Test laboratory name and UKAS accreditation number. Test standard (e.g. BS EN 13501-1 for fire reaction, BS EN 1365 for fire resistance). Test date and validity.
Third-party approval	BBA (British Board of Agrément) certificate, LPCB (Loss Prevention Certification Board) approval, FM Approval, or equivalent third-party certification. Certificate reference and validity dates.
Location installed	Precise location within the building where the product was installed. Identified by floor, zone, room, element reference, and drawing reference. For fire-stopping, the specific compartment line and penetration reference.
Date of installation	Date the product was installed on site. Cross-referenced to site records and inspection records.
Installer	Name of the subcontractor or operative who installed the product. For fire-stopping and fire doors, confirmation that the installer holds the required third-party certification (e.g. FIRAS, IFC, BM TRADA).
Installation instruction compliance	Confirmation that the product was installed in accordance with the manufacturer's installation instructions. Any deviations from the manufacturer's instructions must be recorded with justification and approval from the designer.
FIRE-CRITICAL PRODUCTS	Additional detail for fire-critical products (external cladding, insulation, fire doors, fire-stopping, cavity barriers, smoke control systems): fire test evidence specific to the installed configuration, field-of-application assessment where the installed detail differs from the tested detail, and confirmation of compatibility with adjacent products in the system.
Golden thread status (HRBs)	For Higher-Risk Buildings: confirmation that all product information has been uploaded to the golden thread digital record. Data format and system reference. Confirmation that the information meets the requirements of the Building Safety Act 2022 and the Building Regulations (as amended).

3. Common Mistakes

Only recording cladding products and ignoring fire-stopping, cavity barriers, and structural fixings

The Grenfell Inquiry highlighted failures across multiple product categories, not just cladding. Fire-stopping products, cavity barriers, fire doors, structural fixings, and insulation materials are all safety-critical and must be recorded in the compliance register with the same rigour as external wall products. A register that only covers cladding misses the point of the exercise and leaves the building owner without traceability for products that are critical to fire compartmentation and structural integrity.

Not retaining Declarations of Performance

The Construction Products Regulations 2013 require manufacturers to issue a Declaration of Performance (DoP) for every construction product covered by a harmonised standard. The DoP is the manufacturer's formal declaration of the product's performance characteristics and is the primary evidence of compliance. Many contractors note the product name and CE/UKCA mark but do not retain a copy of the DoP itself. Without the DoP, the declared performance cannot be verified, and the register is incomplete.

Accepting product substitutions without updating the register

Product substitutions happen frequently on construction sites — the specified product is unavailable, and a ‘similar’ product is used instead. Every substitution must be formally assessed by the designer, approved in writing, and reflected in the compliance register. Installing a substitute product without updating the register creates a disconnect between what the drawings and specification say was installed and what was actually installed — which is precisely the problem the golden thread is designed to prevent.

Not recording installation location at a granular level

Recording that ‘Product X was installed on Level 3’ is not sufficient. The register must identify the precise location: floor, zone, room, element reference, and drawing reference. For fire-stopping, the specific compartment line and penetration must be identified. This level of detail is essential for future maintenance, fire risk assessment, and any product recall — without it, the building owner cannot identify which specific locations are affected.

4. Frequently Asked Questions

When will the Construction Products Reform White Paper become law?▾

The Construction Products Reform White Paper was published in February 2026 and sets out the government's proposed approach to strengthening construction product safety regulation. It proposes a new Construction Products Regulator with enhanced enforcement powers, mandatory product registration for safety-critical products, and extended traceability requirements beyond HRBs to all construction projects. The legislative timetable has not been confirmed, but the government has indicated that it intends to bring forward primary legislation within the current parliamentary session. In practical terms, contractors who implement robust product compliance registers now will be well positioned when the requirements become mandatory — those who wait will face a significant compliance burden at short notice.

Does the register apply to all products or just safety-critical ones?▾

For HRBs under the Building Safety Act 2022, the golden thread requires information about all products that are relevant to the building's safety — which in practice covers structural products, fire safety products (cladding, insulation, fire-stopping, fire doors, cavity barriers, smoke control), and products that affect means of escape. For non-HRB projects, there is currently no statutory requirement for a comprehensive product register, but best practice — and the direction of travel signalled by the White Paper — is to record all safety-critical products. At a minimum, fire-critical products and structural products should be recorded on every project.

What is the difference between UKCA marking and CE marking?▾

UKCA (UK Conformity Assessed) marking replaced CE marking for products placed on the Great Britain market following Brexit. CE marking remains valid for products placed on the Northern Ireland market under the Windsor Framework. The UK government has extended transitional arrangements several times, and as of 2026, CE-marked products that comply with the relevant EU harmonised standards are still accepted on the GB market alongside UKCA-marked products. The compliance register should record whichever marking the product bears, along with the relevant notified body reference and the Declaration of Performance.

Who is responsible for maintaining the register after handover?▾

For HRBs, the Accountable Person (typically the building owner or management company) is responsible for maintaining the golden thread — including product information — throughout the building's life. The contractor must hand over a complete and accurate register at practical completion, and the Accountable Person must then keep it updated whenever products are replaced, repaired, or modified during the building's operational life. For non-HRBs, the register forms part of the O&M Manual and H&S File and is the building owner's responsibility to maintain.

Generate your Construction Products Compliance Register on Construction Suite

Construction Suite walks you through every required section with a guided Q&A — built to BSA 2022 / Construction Products Regulations 2013 — and generates a professionally formatted document in minutes.

Get started free