CIH response to Construction Products Reform Green Paper

The case for reform and the need for cultural change (Qs 1, 3, 10–12, 19–20, 37)

1.1 CIH agrees with the government’s assessment that gaps remain in the construction products regulatory framework. Grenfell exposed a regulatory system that allowed unsafe materials to enter and remain in use, with little recourse when things went wrong.

1.2 We welcome the proposals to introduce a general safety requirement, broaden the scope of regulation, and strengthen enforcement. However, our work indicates that reform must extend beyond improving technical standards. Drawing on our work from the Rethinking Repairs and Maintenance (RERAM) project, the Better Social Housing Review (BSHR) we suggest that the government’s approach to construction products reform and the wider building safety regime should consider:

• How to ensure products are safe in use, not just in testing.
• How to reflect the lived realities of how homes are maintained and repaired in policy development.
• How to ensure that in addition to compliance, professional practice and cultural change is incorporated.

1.3 As our recent submission to the 2025 Spending Review highlighted, social landlords often operate within complicated systems, shaped by long-term procurement arrangements, ageing housing stock, and their compliance with the Regulator of Social Housing. In this context, decisions about construction products are complex. Therefore, reform that focuses solely on individual products, without recognising the broader environment in which they are specified, installed and maintained, could risk missing key factors that affect safety and delivery.

2. Resident safety and use in context (Qs 10–12, 19–20, 43)

2.1 The Grenfell Inquiry highlighted that often the most concerning failures in product performance stem from how products are used, not only how they are made. Issues around damp and mould, inadequate fire door installation, or substitution of approved materials can be connected to wider issues in terms of decision-making, skills, or gaps in oversight. For example  these issues often occur when there is unclear responsibility across supply chains, inconsistent standards on installation, or when operational pressures affect procurement decisions

2.2 We support the proposals to:

• Clarify responsibilities for those specifying, installing, and maintaining safety-critical products and systems.
• Introduce minimum competence standards across roles.
• Ensure that oversight mechanisms accurately reflect how products are used and maintained in real-world housing settings.

2.3 We feel that these proposals align with wider social housing sector reform. The Social Housing Regulation Act, Awaab’s Law, and the introduction of the Competence and Conduct Standard all signal a shift towards accountability, professionalism and clearer standards of conduct that we are clear should be based in a more accountable culture. We would therefore recommend that any construction product reform should complement wider housing sector policy and practice approaches. 

3. Transparency, traceability, and resident trust (Qs 17, 21-27, 41) 

3.1 The social housing sector requires clear and consistent information and guidance on the materials used in residents' homes.

3.2 We support proposals to create a central product information database and ensure safety claims are independently verified. We believe this could be further developed to enable social housing providers to quickly and confidently check what products have been installed, their composition, and whether they meet the relevant standards.

3.3 This is especially important in older stock, where there is a greater risk of incomplete or inconsistent data. When information is missing or unclear, it becomes harder to manage risks and keep people safe. Our feedback from members indicates that this can also create barriers to the effective delivery of repairs, upgrades, and essential safety work.

3.4 We also support the proposal of a ‘digital product passport’ and agree that required EU-CPR information via a QR code would be appropriate. We would also suggest that this be designed with real-world use in mind, ensuring it works for contractors, housing teams, and residents alike. This should also link into the building’s wider data systems, including regulations relating to the Golden Thread, so nothing gets lost over time.

3.5 Residents should be able to ask about the products used in their home and receive a clear, timely, and accurate response. This is a key part of rebuilding trust between landlords and residents that has been highlighted in the Better Social Housing Review and the Grenfell Inquiry findings.

4. Oversight, enforcement and redress (Qs 38–44, 49–52)

4.1 We support the proposal for enhanced powers for both the National Regulator for Construction Products (NRCP) and the Building Safety Regulator (BSR) to act on product safety issues and for more coordination between national and local enforcement bodies. This should be straightforward and consistent, with clear contact points in the event of an issue, ensuring a prompt and effective response.

4.2 Our recommendations in this area are for government to:

• Establish clear and accessible routes for residents and landlords to report concerns.
• Ensure that different regulators collaborate and focus on the most significant risks.
• Ensure enforcement applies to both organisations and individuals where necessary, especially in cases where serious or deliberate failings pose a risk to people.

4.3 As the Grenfell Inquiry and the Public Accounts Committee inquiries into remediation have both shown, the previous system failed to act on warnings. We must not allow this to happen again. Regulators need the tools, and the duty, to step in early and prevent harm.

5. Deliverability and social housing sector capacity (Qs 3, 56-57, 58)

5.1 Social landlords are currently facing a wide range of resource and legislative pressure. For example, alongside this consultation, the sector is working to implement, Awaab’s Law, respond to new consumer standards, improve stock conditions under the Decent Homes review, and decarbonise homes to meet net-zero targets. This is in addition to developing new homes to meet desperate housing need and contribute to the government’s 1.5 million homes target. We would therefore strongly recommend that any new duties on product safety must recognise this context.

5.2 We would suggest:

• A clear implementation timetable and guidance that works alongside existing and planned policy and practice.
• Support for workforce training and development, including those who install, maintain, and inspect products.
• A commitment to work with the social housing sector to test and pilot any changes before finalisation. 

6. Conclusion (Q58)

6.1 We agree with the Green Paper that reform of the construction product regime is vital to delivering on the commitments made in response to the Grenfell Tower tragedy. In line with our wider approach on culture and professionalism, we suggest that this needs to go beyond correcting technical and regulatory failings, as it needs to establish a system that actively supports safety, transparency, and professional accountability across the whole product lifecycle.

6.2 This means:

• A clear safety requirement for all products.
• Stronger oversight and enforcement.
• Embedding cultural change and professionalism across the system.
• Alignment with housing regulation and the lived experience of residents.

6.3 CIH is committed to working with the government, regulatory bodies and the housing sector to ensure this regime delivers on its ambitions and creates meaningful, lasting change.

Visit the government's website for more information on the consultation.

For more information on our response please contact Eve Blezard, policy lead, eve.blezard@cih.org.