Construction product conformity in the European Union is built around a fundamental principle: manufacturers must provide reliable, comparable information about the performance of their products before those products are placed on the EU market.
The European Construction Products Regulation — CPR — establishes harmonised rules for expressing the performance of construction products and for placing them on the European market.
The regulatory framework is now undergoing an important transition. Regulation (EU) 2024/3110 establishes the new CPR framework, modernising and progressively replacing Regulation (EU) No 305/2011.
For manufacturers, the practical question is therefore no longer simply whether a construction product requires CE marking. The manufacturer must establish which CPR regime and harmonised technical specification applies to the particular product, determine the relevant characteristics and assessment system, evaluate product performance, prepare the required declaration and maintain production conformity.
This GAR Insight explains how construction products are classified, how harmonised technical specifications are used, how product performance is assessed, when notified bodies become involved, how declarations are prepared and how CE marking supports access to the European construction market.
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Explore CPR scope, harmonised specifications, product performance, assessment systems, declarations, CE marking and the transition to the new EU construction products framework.
Understanding the Construction Products Regulation
The Construction Products Regulation establishes harmonised rules for placing construction products on the European market and provides a common technical language for communicating product performance.
Unlike many product directives that primarily establish safety requirements for the finished product, the CPR is strongly focused on reliable and comparable information concerning the performance of construction products in relation to relevant characteristics.
From CPR 305/2011 to Regulation (EU) 2024/3110
The European Union has modernised its construction products framework through Regulation (EU) 2024/3110.
The new Regulation entered into force in January 2025 and most of its provisions apply from 8 January 2026. However, the transition from the previous CPR is deliberately progressive rather than an immediate replacement of the entire existing system.
Regulation (EU) No 305/2011
Established the familiar European framework based on harmonised standards, declarations of performance, assessment and verification of constancy of performance and CE marking.
Regulation (EU) 2024/3110
Modernises the construction product framework and introduces expanded requirements concerning sustainability, digital information, economic operators and future product requirements.
Which Construction Products Are Covered?
CPR applicability begins with the regulatory classification of the product and its intended use. A manufacturer should determine whether the product falls within the construction products framework and whether an applicable harmonised technical specification exists.
Structural Products
Structural components and systems may fall within harmonised construction-product specifications.
Building Envelope
Windows, doors, façades, insulation and related building envelope products can fall within CPR requirements.
Construction Materials
Cement, aggregates, masonry products and numerous other construction materials may be covered.
Fire-Related Products
Products whose performance influences fire resistance, reaction to fire or fire protection can require CPR assessment.
Building Services Products
Certain products incorporated permanently into construction works may fall within harmonised CPR product families.
Specialised Systems
Innovative or specialised construction products may require assessment through an appropriate European technical route.
Harmonised Technical Specifications
Harmonised technical specifications provide the common European methodology used to assess and communicate construction-product performance.
Correct identification of the applicable specification is therefore one of the most important steps in CPR compliance.
Product Scope
Confirm that the construction product falls within the scope of the applicable specification.
Intended Use
Verify that the manufacturer’s intended use corresponds with the use addressed by the specification.
Characteristics
Identify the characteristics for which product performance must be assessed or declared.
Assessment Methods
Establish the prescribed testing, calculation, classification or other assessment methods.
Understanding Product Performance
CPR compliance is based on establishing and communicating the performance of the construction product in relation to applicable characteristics.
Mechanical Performance
Strength, resistance, load-bearing capacity or other structural characteristics may be relevant.
Fire Performance
Reaction to fire, resistance to fire and related characteristics may require testing or classification.
Thermal Performance
Thermal resistance, conductivity or related energy-performance characteristics may apply.
Acoustic Performance
Sound insulation or absorption characteristics can be relevant for particular construction products.
Durability
Performance over the intended service conditions may need to be considered.
Environmental Performance
Sustainability and environmental characteristics have an increasingly important role under the new CPR framework.
Assessment & Verification of Product Performance
The applicable assessment and verification system determines how product performance is established and how continuing conformity is controlled.
| Activity | Purpose | Typical Evidence |
|---|---|---|
| Product Assessment | Establish product performance | Testing, calculation, classification or documented assessment |
| Factory Production Control | Maintain production consistency | Procedures, inspections, records and production controls |
| Third-Party Assessment | Provide independent verification where required | Certificates, reports and surveillance records |
| Ongoing Verification | Confirm continuing product performance | Production tests, audits and monitoring evidence |
When Is a Notified Body Required?
Depending on the applicable assessment system, independent third-party involvement may be required.
The manufacturer’s first task is therefore to establish the assessment system applicable to the construction product and the characteristics concerned.
Product Certification
Certain systems require a notified product certification body to perform specified conformity assessment activities.
Factory Production Control Certification
Some products require independent certification and surveillance of factory production control.
Testing
Independent laboratory involvement may be required depending on the applicable assessment system.
Surveillance
Continuing surveillance may form part of the applicable conformity system.
Factory Production Control
Factory Production Control — FPC — provides the operational link between the product originally assessed and the products subsequently manufactured.
Declaration of Performance & Conformity
The declaration is a central element of the CPR conformity system. It formally connects the construction product with its assessed characteristics and the manufacturer’s responsibility for the information provided.
During the transition to the new CPR, manufacturers should identify the declaration requirements applicable under the regulatory regime governing the specific product.
Product Identification
Clearly connect the declaration to the product type and relevant identification.
Intended Use
Identify the intended use or uses addressed by the applicable technical specification.
Declared Performance
State the applicable performance information in the form required by the relevant CPR framework.
Assessment Information
Include the relevant conformity assessment and third-party information where required.
CE Marking of Construction Products
CE marking under the CPR communicates that the manufacturer has followed the applicable European construction-product conformity framework and assumes responsibility for the product information accompanying that marking.
“CE means the product is approved for every building.”
CE marking does not by itself determine whether a construction product is suitable for every project, structure or national building application.
CE Communicates Regulatory Performance Information
Designers, specifiers and other stakeholders use declared performance together with applicable building requirements to determine suitability for the intended project.
Construction Product Technical Documentation
Technical documentation should provide a traceable basis for the manufacturer’s declared performance and CE marking.
Sustainability, Digitalisation & the Future CPR
Regulation (EU) 2024/3110 significantly expands the future role of environmental information, sustainability and digital product information within the construction products framework.
Environmental Performance
The new framework strengthens the role of environmental and sustainability characteristics in construction-product information.
Digital Product Information
Digitalisation is intended to make regulatory and performance information more accessible throughout the product value chain.
Digital Product Passport
The new CPR establishes a framework for digital product passports containing relevant construction-product information.
Circularity
The modernised framework gives greater regulatory importance to resource efficiency, sustainability and circular construction.
Common CPR Compliance Problems
Wrong Product Standard
The product is assessed against a specification that does not correctly cover its intended use.
Testing Before Classification
Laboratory testing begins before the correct technical specification and assessment route have been established.
Incorrect Assessment System
The manufacturer assumes that third-party involvement is unnecessary without verifying the applicable system.
Unsupported Performance Claims
Declared values or classes are not adequately supported by testing, calculation or other recognised assessment evidence.
Weak Factory Production Control
Production controls do not adequately demonstrate that manufactured products remain consistent with assessed performance.
Uncontrolled Product Changes
Materials, suppliers, dimensions or manufacturing processes change without evaluating the impact on declared performance.
Incorrect Declaration
Product identification, intended use, assessment information or performance values are inconsistent with supporting evidence.
Assuming CE Means Project Approval
CE marking is incorrectly interpreted as automatic suitability for every national building requirement or construction project.
From Product Classification to CE Marking
A structured CPR conformity programme establishes the applicable regulatory and technical route before testing and certification expenditure begins.
Define Product
Establish product design, function and intended construction use.
Confirm CPR Scope
Determine whether the construction products framework applies.
Identify Regulatory Regime
Establish the applicable CPR framework during the transition.
Identify Specification
Determine the applicable harmonised technical specification.
Map Characteristics
Identify the performance characteristics applicable to the product.
Determine Assessment System
Establish manufacturer and third-party responsibilities.
Assess Performance
Complete required testing, calculation or classification.
Establish FPC
Implement factory production controls.
Complete Third-Party Assessment
Obtain notified-body involvement where required.
Build Documentation
Compile technical and conformity evidence.
Prepare Declaration
Declare applicable product performance and conformity information.
Apply CE Marking
Complete marking and place compliant product on the EU market.
From Construction Product Testing to Demonstrable Performance
CPR conformity begins with correct product classification. The manufacturer must understand what the product is, how it will be used in construction works and which European technical framework applies.
That classification establishes the relevant characteristics, assessment methods and conformity responsibilities. Product testing is therefore only one component of a wider system involving technical assessment, factory production control, third-party involvement where required, documentation and formal declaration of performance and conformity information.
The transition to Regulation (EU) 2024/3110 adds another important dimension. Manufacturers should determine which regulatory regime currently applies to their particular product family rather than assuming that all construction products move to the new system simultaneously.
Ultimately, the declared performance, supporting technical evidence, production controls and CE-marking information should all describe the same product placed on the European market.
The Performance Question
Can the manufacturer demonstrate the declared characteristics through the assessment methods required by the applicable harmonised technical framework?
The Production Question
Can the manufacturer demonstrate that products leaving production continue to provide the performance represented by the conformity documentation and CE marking?