Construction Products Reform: What the GSR Means for Cost Managers

28 June 2026 · 4 min read · Regulation & Compliance

The Construction Products Reform White Paper closed for consultation on 20 May 2026. Its centrepiece — a new risk-based General Safety Requirement (GSR) — will pull every construction product used in the UK within the regulatory regime, whether or not a designated standard exists. For quantity surveyors and cost managers, this is more than a compliance story. It changes how we specify, how we price risk, and how we manage product substitution on live schemes.

What Is Actually Changing

Today, a construction product is regulated only if it sits under a designated standard or has a UK Technical Assessment. Anything outside that perimeter — and there is a lot of it — sits in a regulatory grey zone. The GSR closes that gap. Under the new framework:

• All construction products placed on the UK market will have to satisfy a risk-based General Safety Requirement.
• Manufacturers will carry clearer obligations around declaration of performance, traceability, and post-market surveillance.
• A new national construction products library will become the authoritative reference for product information — replacing the patchwork of test data, certificates and declarations we currently rely on.
• Regulator powers are being strengthened, with the Office for Product Safety and Standards taking a more active enforcement role alongside the Building Safety Regulator.

The government has committed to publishing its consultation response before the end of 2026, with primary legislation expected to follow in 2027. The Construction Products (Amendment) Regulations 2025 are already in force from 8 January 2026 — the first statutory step on this path.

The QS Angle: Specification Lock-In Is About to Get More Expensive

For developers and contractors, the practical question is not will the GSR affect my scheme — it will. The question is whether the cost plans and procurement strategies on those schemes already reflect the new risk profile. In our experience, most do not. Three implications stand out:

• Product substitution risk is rising. Once GSR is live, products that have historically been specified by brand or by long-standing trade practice will increasingly be reviewed against the new requirement. Where no designated standard exists, the burden of demonstrating safety shifts firmly onto the supply chain. Contractors will substitute more aggressively — and design teams will resist more often. Both movements have a cost.
• Specifying "or equivalent" is no longer enough. The traditional QS hedge — naming a product and adding "or equivalent approved" — has always been commercially efficient but legally thin. Under GSR, the test of equivalence shifts from "the architect says it's fine" to "the product demonstrably meets the General Safety Requirement." That is a different and more expensive conversation to have mid-contract.
• Cost plans need a compliance line. Embodied carbon, sustainability data, and now product compliance are all converging on the same problem: the cost of demonstrating fitness-for-purpose is now material. For schemes over £2m we are starting to see this in the form of extended pre-construction periods, additional technical submittals, and more granular BOQ itemisation. None of this is large in isolation, but it accumulates.

Government's stated aim is that the GSR will create a level playing field for reputable manufacturers and end the era of opaque product data. For cost managers, the more immediate effect is that the specification risk we have historically under-priced is about to become visible on every variation account.

Practical Steps for Cost Managers

1. Audit current specifications for designated-standard coverage. On every live scheme, identify the product groups that currently sit outside designated standards — façades, fixings, specialist MEP components, and finishes are common offenders. These are where GSR will bite first.
2. Tighten "or equivalent" clauses. Replace loose equivalence language with named performance criteria and an evidence requirement. This reduces variation disputes and shifts the compliance burden to the party best placed to discharge it — usually the contractor at procurement stage.
3. Build a compliance allowance into feasibility cost plans. Allow 0.3-0.7% of construction value for product compliance evidence, technical submittals, and potential substitutions during the construction phase. Calibrate against scheme size and complexity.
4. Push data requirements into tender enquiry letters. Require named products, declaration of performance references, and test certificates at tender stage — not post-award. This is the cheapest point in the project to surface compliance gaps.
5. Track the government response. The consultation response is expected before the end of 2026. Anything published in Q4 will have a direct line into live cost plans being prepared for 2027 starts.

What This Means for Our Clients

For developers we work with, the message is straightforward: the cost of getting product specification wrong is rising, and the window to update specifications, procurement strategies and cost plan contingencies at low cost is now — before the GSR becomes law. Schemes that already have robust specification discipline and clear product data flows will see minimal disruption. Schemes that rely on contractor-led design or loose equivalence clauses are likely to see the impact first, in the form of substitution disputes, programme delay and variation account inflation.

We are already embedding GSR awareness into our pre-construction cost planning and development monitoring workflows, and we are flagging product compliance status on live schemes where it is material. If you would like a quick review of how exposed your current pipeline is, we are happy to talk it through.

Sources: MHCLG, Construction Products Reform White Paper (25 February 2026); MHCLG, General Safety Requirement for Construction Products — Consultation (closed 20 May 2026); Kennedys, Construction Products Reform White Paper: a new era for safety (May 2026); Gowling WLG, Construction Products Reform White Paper: key headlines (March 2026); Crown Office Chambers, Untangling the Web of Blame (April 2026); Womble Bond Dickinson, The future of construction products: a new regulatory era (April 2026); Charles Russell Speechlys, Building Safety in the UK: A Period of Significant Reform (May 2026). This article is for general guidance only and does not constitute legal or professional advice.