Technical Insight

GAR INSIGHT
Construction Products Regulation (EU) 2024/3110 — Product Performance, Declaration of Performance & CE Marking
GAR INSIGHT · CONSTRUCTION PRODUCTS · EU MARKET ACCESS

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.

ARTICLE GUIDE

Navigate This Article

Explore CPR scope, harmonised specifications, product performance, assessment systems, declarations, CE marking and the transition to the new EU construction products framework.

01
REGULATORY FOUNDATION

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.

Current Framework Regulation (EU) 2024/3110
Previous Framework Regulation (EU) No 305/2011
Product Area Construction Products
Market Marking CE
The CPR is fundamentally performance-based. CE marking under the construction products framework connects the product with declared performance established according to the applicable harmonised technical framework.
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02
REGULATORY TRANSITION

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.

PREVIOUS CPR

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.

NEW CPR

Regulation (EU) 2024/3110

Modernises the construction product framework and introduces expanded requirements concerning sustainability, digital information, economic operators and future product requirements.

The transition is product-family dependent. Manufacturers should not assume that publication of the new CPR automatically moves every existing construction product from the old system to the new one at the same time. The applicable regime must be established for the specific product and harmonised technical specification.
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03
PRODUCT SCOPE

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.

Commercial description is not regulatory classification. The manufacturer should identify the product’s intended use, relevant product family and applicable technical specification before determining the conformity route.
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04
TECHNICAL FRAMEWORK

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.

Using the wrong standard can invalidate the entire compliance route. Product scope, intended use and the applicable harmonised specification should be confirmed before testing begins.
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05
DECLARED CHARACTERISTICS

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.

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06
PERFORMANCE ASSURANCE

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
The conformity route is not chosen according to manufacturer preference. The applicable system is established by the regulatory and harmonised technical framework for the product concerned.
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07
INDEPENDENT ASSESSMENT

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.

Notification must match the required scope. The selected body should have the appropriate notification for the relevant construction product, specification and conformity assessment activity.
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08
PRODUCTION CONTROL

Factory Production Control

Factory Production Control — FPC — provides the operational link between the product originally assessed and the products subsequently manufactured.

01
Raw materials. Control incoming materials and critical components.
02
Manufacturing processes. Define and control processes affecting declared performance.
03
Inspection. Establish appropriate inspection and verification activities.
04
Testing. Perform production testing where required by the applicable specification.
05
Nonconforming product. Identify, control and resolve products that fail established criteria.
06
Traceability. Maintain records connecting production with conformity evidence.
07
Change control. Evaluate changes that could affect declared performance.
CE marking is not based only on the product originally tested. Factory Production Control is intended to ensure that manufactured products continue to provide the performance represented by the manufacturer’s conformity information.
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09
PERFORMANCE DECLARATION

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.

The declaration should be product-specific and evidence-based. Performance values or classes should correspond with the actual assessment evidence and the product placed on the market.
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10
EU MARKET MARKING

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.

COMMON MISUNDERSTANDING

“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.

CORRECT APPROACH

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.

CE marking is not a universal statement of construction suitability. The declared performance must still be evaluated against the requirements of the building or civil-engineering works in which the product will be used.
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11
COMPLIANCE EVIDENCE

Construction Product Technical Documentation

Technical documentation should provide a traceable basis for the manufacturer’s declared performance and CE marking.

01
Product definition. Identify product, model, variants and intended use.
02
CPR applicability. Document the applicable regulatory framework.
03
Technical specification. Identify the applicable harmonised technical specification.
04
Characteristics. Identify characteristics relevant to the declared product performance.
05
Assessment evidence. Maintain test, calculation, classification and assessment reports.
06
Third-party evidence. Maintain applicable notified-body certificates and reports.
07
Factory Production Control. Document production-control procedures and records.
08
Declaration. Maintain the applicable performance and conformity declaration.
09
CE marking. Maintain evidence supporting the information accompanying the CE mark.
10
Change control. Evaluate modifications affecting product performance or conformity.
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12
NEW CPR DIRECTION

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.

The new CPR is more than an update to CE-marking paperwork. It represents a broader transition toward digital, traceable and sustainability-focused construction-product information.
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13
COMPLIANCE RISKS

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.

The most costly CPR error often occurs at the beginning. If the product has been incorrectly classified or assessed against the wrong technical specification, testing, certification, declarations and CE-marking information may all need revision.
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14
COMPLIANCE ROADMAP

From Product Classification to CE Marking

A structured CPR conformity programme establishes the applicable regulatory and technical route before testing and certification expenditure begins.

01

Define Product

Establish product design, function and intended construction use.

02

Confirm CPR Scope

Determine whether the construction products framework applies.

03

Identify Regulatory Regime

Establish the applicable CPR framework during the transition.

04

Identify Specification

Determine the applicable harmonised technical specification.

05

Map Characteristics

Identify the performance characteristics applicable to the product.

06

Determine Assessment System

Establish manufacturer and third-party responsibilities.

07

Assess Performance

Complete required testing, calculation or classification.

08

Establish FPC

Implement factory production controls.

09

Complete Third-Party Assessment

Obtain notified-body involvement where required.

10

Build Documentation

Compile technical and conformity evidence.

11

Prepare Declaration

Declare applicable product performance and conformity information.

12

Apply CE Marking

Complete marking and place compliant product on the EU market.

The efficient sequence is classification → specification → assessment → production control → declaration → CE marking. Testing before the correct product specification and assessment system have been established can create unnecessary cost and repeated conformity work.
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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?

The defining CPR compliance question is: can the manufacturer establish a traceable technical chain from correct product classification and applicable specification through performance assessment, factory production control and third-party verification where required to the declaration and CE marking of the exact construction product placed on the EU market?
Technical note: The European construction products framework is currently undergoing a staged transition from Regulation (EU) No 305/2011 to Regulation (EU) 2024/3110. The applicable requirements can depend on the product family, intended use, harmonised technical specification, applicable assessment system and stage of regulatory transition. Manufacturers should therefore verify the current legal and technical framework for the specific construction product before testing, certification, declaration or CE marking. This article provides general technical information and does not replace product-specific regulatory or conformity assessment.
GLOBAL ALLIANCE REGISTER

How Global Alliance Register Can Support You

Global Alliance Register supports manufacturers, suppliers and responsible economic operators with independent technical-assurance services relevant to Construction Products Regulation (EU) 2024/3110 within the construction and infrastructure context. Based on the article's emphasis on regulatory review, performance and reliability verification and certification, GAR can coordinate competent specialists, laboratories, inspectors, auditors and accredited conformity-assessment resources as appropriate to the actual technical need. Within the context of this article, Global Alliance Register can support you in the following areas:

01

Determine the applicable conformity-assessment route for Construction Products Regulation (EU) 2024/3110, coordinate the required technical evidence and support independent third-party or Notified Body involvement where the governing framework requires it.

02

Review commissioning readiness and coordinate functional, performance and acceptance verification relevant to Construction Products Regulation (EU) 2024/3110, including defects, retesting and close-out evidence.

03

Verify performance, durability and reliability characteristics relevant to Construction Products Regulation (EU) 2024/3110, review the resulting data and identify deviations, weaknesses or corrective actions affecting dependable operation.

04

Review test records, inspection evidence, calculations, reports and other technical documentation relating to Construction Products Regulation (EU) 2024/3110 for completeness, consistency and traceability.

05

Define and coordinate appropriate laboratory, factory or field testing for Construction Products Regulation (EU) 2024/3110, including representative configurations, test methods, operating conditions and acceptance criteria.

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