Construction Products Regulation (EU) 2024/3110
Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2024 laying down harmonised rules for the marketing of construction products — the "new CPR" — repeals and replaces Regulation (EU) No 305/2011. The Regulation entered into force on 7 January 2025 and applies progressively from 8 January 2026. It maintains the broad architecture of the predecessor — CE marking conditional on a Declaration of Performance against harmonised technical specifications — but reforms the legal status of harmonised standards, adds a Declaration of Conformity component, introduces sustainability and circular economy requirements, and provides a 15-year phased transition for product families. Published as OJ L, 2024/3110, 18.12.2024.
Legal status and timeline
- Predecessor: Regulation (EU) No 305/2011 (CPR 305/2011).
- Adoption: 27 November 2024.
- Entry into force: 7 January 2025.
- Date of application (most provisions): 8 January 2026.
- Phased transition: 15-year transition for product families, with harmonised technical specifications under CPR 305/2011 continuing to apply for each family until they are replaced by harmonised technical specifications under Regulation 2024/3110.
- Repeal of CPR 305/2011: 8 January 2026, subject to the transitional provisions in Article 92 of Regulation 2024/3110.
- Status in May 2026: applies. Most construction products continue to be placed on the market under CPR 305/2011 harmonised standards because new harmonised technical specifications under Regulation 2024/3110 are being developed product family by product family.
Scope: products covered
Article 2(1) of Regulation 2024/3110 applies to "construction products". Article 3(1) defines a construction product as "any item produced and placed on the market, including by means of additive manufacturing, or fabricated and placed on the market, for incorporation in a permanent manner in construction works or parts thereof". The Regulation extends coverage to:
- Used products and remanufactured products placed on the market with declared performance under harmonised technical specifications — a substantive extension from CPR 305/2011 reflecting circular economy objectives;
- Pre-fabricated components made by additive manufacturing;
- Key parts that influence the safety or performance of a construction product, listed by delegated act under Article 4.
Exclusions
Article 2(2) excludes: products covered exclusively by other Union harmonisation legislation (with the construction-products dimension absorbed in the other act); on-site fabrication directly by the user; and products manufactured for the manufacturer's own use that are not placed on the market.
Distinctive feature: Declaration of Performance, not Declaration of Conformity
The CPR (both 305/2011 and 2024/3110) does not require a manufacturer to certify that the product is "safe" or meets minimum performance levels. Instead, the manufacturer issues a Declaration of Performance (DoP) stating the performance of the product against each essential characteristic covered by a harmonised technical specification, for the product's declared intended use. Member States retain the competence to set minimum performance requirements for the use of construction products in works, through national building regulations. The CPR harmonises only the assessment and declaration of performance, not the regulatory level of performance.
Regulation 2024/3110 adds a Declaration of Conformity component (Article 16 and Annex V Part B), declaring conformity with substantive provisions of the Regulation that go beyond declared performance — including sustainability requirements adopted by delegated act, safety provisions, and information obligations. The combined "Declaration of Performance and Conformity" replaces the predecessor's pure DoP.
Basic requirements for construction works (Annex I)
Annex I of Regulation 2024/3110 lists seven basic requirements for construction works (carried over from CPR 305/2011 with refinement):
- Mechanical resistance and stability;
- Safety in case of fire;
- Hygiene, health, and the environment;
- Safety and accessibility in use;
- Protection against noise;
- Energy economy and heat retention;
- Sustainable use of natural resources.
The "essential characteristics" of a construction product are those characteristics that relate to the seven basic requirements. Each harmonised technical specification lists the essential characteristics for the product family it covers; for each, the DoP states the level, class, or description of performance.
Harmonised technical specifications
The CPR works through "harmonised technical specifications" — comprising harmonised standards (hENs) adopted by CEN under a Commission standardisation request, and European Assessment Documents (EADs) for products not covered by hENs. Under Regulation 2024/3110, the Commission may also adopt acts setting common specifications where standardisation is delayed (Article 9). The 15-year phased transition operates by replacing existing CPR 305/2011 hENs progressively with new harmonised technical specifications aligned with Regulation 2024/3110.
Assessment and verification of constancy of performance (AVCP)
Annex IV of Regulation 2024/3110 establishes the AVCP systems — labelled 1+, 1, 2+, 3, and 4 — analogous to those of CPR 305/2011 but with adjustments:
- System 1+ / 1 — Notified Body certifies the product, with continuing surveillance. Used for products with high safety implications (fire-resistant products, structural elements).
- System 2+ — Notified Body certifies the factory production control (FPC), with continuing surveillance. Used for many structural and safety-relevant products.
- System 3 — Notified laboratory determines the product type; manufacturer maintains FPC. Used principally for fire and acoustic performance testing.
- System 4 — Manufacturer alone determines the product type and maintains FPC; no Notified Body involvement.
The AVCP system applicable to each product family is specified in the harmonised technical specification or by Commission delegated act under Article 11.
Technical documentation
Article 21 and Annex IV require the technical documentation specific to construction products. Content includes: a description of the product; the intended use(s); the harmonised technical specification applied; the essential characteristics and their levels, classes, or descriptions; the AVCP system; documentation from the Notified Body (where one is involved); manufacturing procedures and FPC documentation. Retention: 10 years from the last unit placed on the market (Article 22(7)). See technical documentation.
Declaration of Performance and Conformity
Article 16 and Annex V set the contents of the combined Declaration:
- Identification of the product type;
- Intended use(s);
- Manufacturer, importer, authorised representative details;
- AVCP system;
- Notified Body details and certificate references (where applicable);
- Declared performance for each essential characteristic, by reference to the harmonised technical specification;
- Declaration of conformity with the Regulation's substantive provisions;
- Sustainability information (gradually introduced via delegated acts under Article 21);
- Identification of the Digital Product Passport identifier (when adopted).
Marking, labelling, and Digital Product Passport
Article 17 requires the CE marking on construction products for which the manufacturer has issued a Declaration of Performance and Conformity. Article 19 requires the inscription of:
- Manufacturer's identity and contact details;
- Product type, batch, or serial number;
- Last two digits of the year in which the marking was first affixed;
- Identification of the harmonised technical specification;
- Intended use;
- Information on declared performance for each essential characteristic.
Construction products in scope of Regulation 2024/3110 will progressively be required to carry a Digital Product Passport identifier, with technical architecture to be set by Commission implementing acts under Article 76. See Digital Product Passport.
Recent and upcoming changes
- The Commission's standardisation request to CEN for harmonised technical specifications aligned with Regulation 2024/3110 was adopted in 2025; first families (cement, structural steel, fire-resistant glazing, insulation products) are expected to publish in 2026–2028.
- Delegated acts under Articles 4 (key parts), 7 (sustainability), and 11 (AVCP for new products) are in preparation.
- The Construction Products Information System (replacing parts of the NANDO database for construction) will be operational from 2026.
- The Commission has signalled enforcement priority for declared performance accuracy, particularly fire performance after the Grenfell findings and similar incidents.
Related legislation
- Ecodesign Regulation 2024/1781 (ESPR) — applies in parallel to construction products that are also energy-related products covered by ESPR delegated acts.
- Energy Performance of Buildings Directive (EU) 2024/1275 — applies to buildings, not the construction products themselves, but performance declarations under the CPR feed into building-level energy performance.
- GPSR 2023/988 — does not apply to construction products in scope of the CPR.
- REACH Regulation (EC) 1907/2006 — applies in parallel for chemical substances in construction products.
- Regulation (EU) 2024/1252 on critical raw materials — overlaps with CPR sustainability requirements for products containing critical raw materials.
Common errors
- Treating CE marking under CPR as a quality mark. CPR CE marking certifies declared performance only; minimum performance levels are set by national building regulations of each Member State of installation.
- Missing or incomplete Declaration of Performance. The DoP (now combined with the DoC under Regulation 2024/3110) must accompany the product or be available electronically.
- NPD ("No performance determined") for an essential characteristic. Permitted under specific conditions — but only where no regulatory requirement applies in the Member States of intended use; otherwise the manufacturer must declare a performance.
- Using a harmonised standard withdrawn or superseded. The OJEU references must be checked at the time of placing on the market.
- Confusion of CPR scope with broader construction supply. Some construction goods (e.g., temporary works, on-site mixes) fall outside CPR scope and are not CE-marked under the CPR.
Sources
- Regulation (EU) 2024/3110 on construction products — EUR-Lex.
- Regulation (EU) No 305/2011 (predecessor) — EUR-Lex.
- European Commission — Construction sector.
- European Commission — Construction Products Regulation page.
- Commission Notice — Blue Guide 2022 — EUR-Lex.