White papers welcomed but more can be done, says the GAI

The publication of the Construction Products Reform White Paper, alongside the Consultation on the General Safety Requirement (GSR), marks a significant step in the UK Government’s ongoing programme of reform following the Grenfell Tower tragedy. Together, these documents seek to address long-standing systemic weaknesses within the construction products sector, including fragmented regulation, inconsistent product information, limited enforcement, and gaps in competence and accountability.

GAI’s formal responses to both consultations are grounded not only in direct member feedback but also in wider engagement across industry. They also build upon the issues and themes raised in our response to last year’s Green Paper.

At the heart of both consultations is a shift in regulatory philosophy, from a system largely based on compliance with standards towards one that prioritises safety in use and lifecycle performance. 

The GAI strongly supports this direction of travel. In particular, the introduction of the General Safety Requirement (GSR) represents a move towards shared responsibility across the supply chain, recognising that safety outcomes depend not only on compliant products, but on how those products are specified, installed, and maintained in practice. 

However, a key concern raised relates to the proposed application of the GSR. There is a risk that it will, in practice, apply primarily to non-harmonised or non-designated products. Given that much of the architectural ironmongery sector including essential hardware components such as hinges, locks, door closers, and escape hardware falls within harmonised/designated standards, this could create inconsistency within the regulatory framework. GAI has therefore called for the GSR to apply universally across all construction products, ensuring a clear and consistent baseline for safety. 

A related concern is the ongoing reliance on standards and conformity markings as indicators of safety. While standards remain an essential part of the system, they were not always developed with safety as their primary objective. As a result, conformity marks such as CE and UKCA are often misunderstood as indicators of fitness for purpose in specific applications, when in reality safe performance depends on correct use within a system. This is particularly evident in fire doors, where the interaction between components, including ironmongery is critical to overall performance.

A further important consideration is the need to maintain alignment with European systems. The construction products sector operates across a highly integrated, pan-European market, and divergence in standards, testing, and certification risks introducing unnecessary duplication, increased cost, and barriers to trade. GAI has therefore emphasised the importance of maintaining consistency wherever possible, including through mutual recognition of assessment outcomes and alignment with established European methodologies. That said, the coexistence of CE and UKCA marking further complicates this landscape. While the continued recognition of CE marking offers practical benefits, it also introduces duplication and uncertainty. Given that UKCA is effectively based on the same underlying standards, questions remain about its long-term necessity. GAI has therefore highlighted the need for clearer direction, including the potential rationalisation towards a single, widely recognised conformity marking framework focussing on CE marking only.

Competence is another central theme running throughout the reforms. The development of BS 8670-2 competence standard for construction products (which is available for Draft Public Comment until July 12th) represents a positive step towards establishing more consistent expectations across the sector. 

However, GAI has been clear that standards alone will not close the existing competence gap. There must be explicit regulatory recognition that individuals working with construction products are required to demonstrate appropriate, verifiable competence. In practice, this is likely to require a more formal mechanism such as a recognised professional register to ensure ongoing accountability, supported by Continuing Professional Development (CPD). 

Beyond product performance, the consultations place significant emphasis on improving product information and traceability. GAI strongly supports this focus, recognising that poor-quality information was a key factor identified by the Grenfell Inquiry. The move towards digital product information linked to physical identifiers is particularly welcome, offering the potential to improve transparency, traceability, and decision-making throughout the product lifecycle. GAI has led the way in this area through provision of Product Data Templates for doors and hardware in addition to its ongoing work on the creation of a new standard for data dictionaries for building hardware.

Equally important is the need to address accountability across the supply chain. The GAI’s response highlights that responsibility is often fragmented, particularly at the interfaces between design, specification, procurement, and installation. This can lead to ambiguity in decision-making and a lack of clear ownership of safety-critical outcomes. Of particular concern is the limited formal recognition of designers and specifiers, despite their direct influence on product selection and, ultimately, safety. GAI has called for these roles to be explicitly recognised as dutyholders, aligned with the Construction (Design and Management) Regulations. 

The question of enforcement is perhaps the most critical factor underpinning reform. Across both consultations, GAI members consistently highlighted a lack of confidence in the current system, with insufficient action taken against those who fail to meet regulatory requirements.

Without robust enforcement, there is a risk of a continued ‘race to the bottom’, driven by price competition rather than quality and compliance. Strengthened enforcement, clearer regulatory oversight, and a co-ordinated role for national and local authorities will therefore be essential. The industry is also seeking clarity on who will be responsible for overseeing and ‘policing’ competence frameworks such as those written under BS 8670-2 standard to ensure they are applied consistently in practice. 

The success of these reforms will depend on practical implementation. This includes ensuring sufficient testing capacity, providing clear and accessible guidance, and allowing realistic transition periods for industry to adapt. Without these supporting measures, there is a risk that additional regulatory burden will not translate into improved safety outcomes.

Overall, the GAI supports the direction of reform and the ambition to create a more robust, transparent, and safety-focused construction products regime. However, achieving this will require a coherent, system-wide approach that aligns regulation, standards, competence, and enforcement. Only through this alignment can the industry deliver the meaningful and lasting improvements in building safety that these reforms are intended to achieve. 

Find the GAI response to the White Paper here

An online quiz based on this feature is available on the GAI Learning Hub. Completion of this quiz is worth one CPD point towards Registered Professional status. Take the quiz here