UK Construction Products Reform: What the Proposed General Safety Requirement Means for Importers of Building Products from China

On 25 February 2026 the UK government published the Construction Products Reform White Paper and, alongside it, a consultation on a General Safety Requirement (GSR) for construction products that are not covered by a designated standard or a technical assessment. The White Paper confirms that a GSR will be introduced and that importers, distributors and fulfilment service providers will carry obligations. The consultation, which ran until 20 May 2026, set out the detail as proposals, and GOV.UK states that responses are being analysed, so the final rules are not yet published.

This article reads those documents as published on GOV.UK (the White Paper page and the GSR consultation page), read on 10 October 2026, together with the OPSS guidance page last updated on 22 July 2026. It is a reading of government documents for procurement planning, not legal advice, and it covers proposals that may change. Check GOV.UK for the outcome before you rely on any detail. For the marking rules that apply today, see our guides to UKCA and CE marking for China-made products and sourcing building materials from China for UK developers.

What has been confirmed and what is still a proposal

The White Paper (CP 1515) separates what the government says it will do from what it is still consulting on. The points below are taken from its chapter on the general safety requirement.

• Confirmed in the White Paper: the government states that it will bring all construction products within the regulatory regime, in a risk-based and proportionate way, by introducing a GSR for products not covered by designated standards or subject to a technical assessment (paragraph 6.4.5).
• A legal duty on several parties: the requirement places a legal duty on economic operators, including but not limited to manufacturers, importers and distributors (including merchants), to place only safe products on the market (paragraph 6.4.6).
• Importers, distributors and fulfilment providers: obligations will be introduced for them (paragraph 6.4.7).
• Still being settled: the White Paper says the details of the GSR are the subject of the parallel consultation (CP 1516), that the GSR will be introduced through secondary legislation, that a transition period will follow, and that the government is “aiming for implementation by late 2027” (paragraph 6.4.8).
• Regulator: guidance for economic operators will be published by the national regulator for construction products, which sits within the Office for Product Safety and Standards (OPSS).

Why the gap exists: products outside designated standards

Under the current regime, a product is regulated under the construction products regulations only if it is covered by a designated standard or by a UK technical assessment. The White Paper (paragraphs 2.4.1 and 2.4.2) says that, as a result, there are no minimum requirements that cover all construction products, and a significant proportion of products remain outside the regime. It cites research for government by the Adroit Consortium suggesting that between 29% and 61% of products have a designated standard, with a central estimate that around 37% of the UK market is regulated under the Construction Products Regulations.

The same chapter gives the trade context. In 2024 the biggest share of construction products imports from a single country came from China, from which the UK imported around £4.2bn in goods. The White Paper does not say that Chinese products are unsafe, and this article does not either. The point for a buyer is narrower: a product imported from China that has no designated standard has so far had no general safety rule to meet, and the GSR is designed to close that gap for all sources.

What the GSR would ask of an importer

The consultation document (CP 1516) defines an importer as a person who first places a construction product from outside the country on the UK market (paragraph 7.21). That is a role in the contract and the customs entry, not a description of the factory, so it matters who holds it. Paragraph 7.22 proposes that importers be responsible for checking, before they accept a product for import and allow it to be placed on the market, that:

• the manufacturer has completed an assessment of risks for the product;
• the product information has been produced and made publicly available;
• the manufacturer’s details are affixed to the product; and
• a copy of the product information, in a digital format, is provided when supplying the product and on request of another economic operator in the supply chain.

Two further proposals concern records and labelling. Paragraph 7.23 proposes that an importer also shows its registered trade name or registered trademark and its registered postal address on the product where possible, or otherwise on the packaging or in the accompanying documentation. Paragraph 7.24 proposes that importers keep a record of all product documentation supplied by the manufacturer, a record of those to whom they supplied products, and any records of safety incidents, and that they retain, or arrange for the retention of, those records for 10 years from the date the product was last placed on the market.

The consultation document adds that it intends to require distributors, including merchants, to check that the manufacturer or importer has met the requirement before supplying a product for use (paragraph 7.26), so a developer buying through a merchant can expect the same documents to be asked for further down the chain.

For the European Union rules on importers of construction products, see our reading of Regulation (EU) 2024/3110.

Where a technical assessment fits

The White Paper explains the interaction in paragraphs 6.5.1 and 6.5.2. If a manufacturer chooses to undertake a technical assessment against a UK Assessment Document (UKAD) or a European Assessment Document (EAD), the product is regulated under the construction products regulations and the GSR does not apply. Where the manufacturer has not pursued a technical assessment and the product is not covered by a designated standard, the product is not regulated under those regulations and would be subject to the GSR. For a buyer this means each product line sits on one of three routes, and the brief should say which one the maker is claiming.

• Designated standard: the product falls under the existing regime and its marking rules.
• Technical assessment: the product is assessed against a UKAD or an EAD and is regulated under the existing regime.
• Neither: the product would fall under the GSR once it is introduced.

What the government says industry should do now

Paragraph 6.4.9 of the White Paper says the government expects industry to take steps now to prepare for the GSR. It points to PAS 2000:2026, “Construction Products – Bringing Safe Products to Market – Code of Practice”, developed by the British Standards Institution with government funding and with officials from the Ministry of Housing, Communities and Local Government and OPSS engaged in the process. The White Paper describes PAS 2000 as a framework for manufacturers to demonstrate that they have taken reasonable steps to ensure their products are safe, covering pre-market risk assessment, factory production control, production information and collection, and the use of market feedback. The OPSS guidance page records that a link to the published code of practice was added on 2 March 2026.

The White Paper is not a requirement placed on makers by law today, and PAS 2000 is a code of practice, not a regulation. It is, however, a reference a buyer can name in a brief to ask a maker what it already has.

What to put in a China purchase brief now

None of the following is a legal requirement today. They are questions an importer can write into the brief and the purchase order so that the records the consultation proposes can be assembled later. Put each answer in writing and keep it with the purchase file.

• Route statement: for each product line, whether the maker claims a designated standard, a technical assessment, or neither, and the document it relies on.
• Risk assessment record: whether the maker has carried out a documented assessment of safety risks for the intended use, and whether it can share it or a summary.
• Product information: the information that accompanies the product, in a form that can be supplied digitally to the next party in the chain.
• Labelling space: whether the product or its packaging can carry the importer’s name and address as well as the maker’s details, and who applies them.
• Document control: how amendments to product documents are notified, so the file shows what applied to each batch.
• Retention: who keeps what, for how long, with the aim of being able to produce the records for 10 years if the proposal is adopted as drafted.
• Importer of record: which party will be the importer for the UK market under the sales terms. The proposal attaches duties to that party.

Northern Ireland sits in a different position. The consultation document notes that, under the Windsor Framework, Regulation (EU) 2024/3110 (the EU Construction Products Regulation) remains applicable in Northern Ireland for products regulated under that framework. If a project is in Northern Ireland, ask the specifier which regime governs each product line.

Questions buyers ask about the UK General Safety Requirement

Is the General Safety Requirement already law?

No. The White Paper and the consultation were published on 25 February 2026, the consultation closed on 20 May 2026, and GOV.UK states that responses are being analysed. The White Paper says the GSR will be introduced through secondary legislation with a transition period and that the government is aiming for implementation by late 2027.

Which products would the General Safety Requirement cover?

Construction products that are not covered by a designated standard and are not subject to a technical assessment. Products that follow a technical assessment against a UKAD or EAD remain under the construction products regulations.

Who counts as the importer?

The consultation document defines an importer as a person who first places a construction product from outside the country on the UK market. Which party that is depends on the contract and the entry, so settle it before the order.

Does the proposal single out products from China?

No. The White Paper mentions China only in its trade context, noting that in 2024 the biggest share of construction products imports from a single country came from China. The proposed duties apply to all economic operators placing products on the UK market.

How does FBM Sourcing support a UK project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

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