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" or CPR-2024) replaces Regulation (EU) No 305/2011 (CPR-2011) in stages, not on a single date. It keeps the broad architecture of its predecessor, with CE marking resting on a declaration of performance against harmonised technical specifications, but it changes the legal status of harmonised standards, adds product requirements and a conformity element to the declaration, and introduces environmental sustainability and digital product passport rules. Published in OJ L, 2024/3110, 18.12.2024.
Legal status and timeline
- Adoption: 27 November 2024.
- Entry into force: 7 January 2025 (twentieth day after publication; Article 96).
- Applying from 7 January 2025: Articles 1 to 4, Article 5(1) to (7), Article 7(1), Articles 9 and 10, Article 12 first paragraph, Article 16(3), Article 37(4), Articles 63, 89 and 90, and Annexes I to IV, VII, IX and X (Article 96). These provisions allow the preparatory work and delegated acts to begin.
- General date of application: 8 January 2026 (Article 96). CPR-2011 is repealed from the same date, except for the provisions listed below.
- Penalties (Article 92): from 8 January 2027.
- Notified bodies and technical assessment bodies: those already notified or designated under CPR-2011 are treated as such under the new Regulation, but must be reassessed by 8 January 2030 at the latest (Article 95(2)).
- Repeal of the retained CPR-2011 provisions: 8 January 2040 (Article 94).
- Status in October 2026: applies, with most product obligations still pending family by family.
What applied from 8 January 2026, and what did not
The date in Article 96 is a general date of application, and Article 95 narrows it. Read together, the rules work as follows.
| Your product | Rules that apply now | What happens next |
|---|---|---|
| Covered by a harmonised standard cited in the OJEU under CPR-2011 | CPR-2011 Articles 2, 4 to 9, 11 to 18, 27, 28, 36 to 40, 47 to 49, 52, 53, 55, 60 to 64 and Annexes III and V remain in force for these products only (Articles 94 and 95(8)). The standard stays valid until withdrawn or otherwise repealed (Article 95(3)). You keep issuing a Declaration of Performance. | Chapters I to III of the new Regulation apply one year after the implementing act making the replacement specification mandatory, or later if that act says so. You may move earlier, from the specification's entry into force (Article 95(9)). The Commission withdraws the old reference within a further year (Article 95(10)). |
| Covered by a European Assessment Document listed under CPR-2011 by 8 January 2026 | The EAD remains valid until 9 January 2031, unless it expires sooner (Article 95(4)). | Products may not be placed on the market on the basis of European Technical Assessments issued under such an EAD after 9 January 2036. The EAD stops being usable earlier if a new specification covers the same product and intended use (Article 95(5)). |
| Not covered by any cited standard or EAD | No CE marking route exists unless you obtain a European Technical Assessment under an EAD adopted through the new Regulation. A manufacturer may then issue a declaration of performance and conformity (Article 13(1)). National rules apply otherwise. | Product families in Annex VII gain coverage as the working plan progresses. |
| Covered by a specification made mandatory under Article 5(8) or Article 6(1) | The earliest such act foreseen in the working plan is Q4 2027 (cement). | Declaration of performance and conformity, new CE marking content, and full Chapter III obligations, one year after adoption unless the act sets a later date. |
Article 95(7) lets certificates, test reports and European Technical Assessments issued under CPR-2011 serve as the technical basis under the new Regulation, where the product type corresponds and the requirements and assessment methods remain valid. Harmonised standards cited under CPR-2011 and not withdrawn count as harmonised performance standards for the purposes of Article 5(7), Article 6(1) and Article 31(2) (Article 95(8)).
The Commission's own summary states that the two regulations "will coexist for a significant period". Its timeline page gives 2039 for the repeal of CPR-2011, while Article 94 of the Regulation states 8 January 2040; this page follows the legal text.
Scope: products covered
Article 2(1) of Regulation 2024/3110 applies to construction products, including used products, and to key parts of products. Article 3(1) defines a construction product as "any formed or formless physical item, including 3D-printed products, or a kit that is placed on the market, including by means of supply to the construction site, for incorporation in a permanent manner into construction works or parts thereof", excluding items that must first be integrated into a kit or another construction product. Parts or materials intended for use in regulated products also fall within scope if their manufacturer so requests (Article 2(1)(b)). Compared with CPR-2011, the following stand out:
- Used products, defined in Article 3(20) as products that are not waste or have ceased to be waste and that have been installed at least once in a construction work. Placing on the market includes the first making available in the Union of a used product after deinstallation (Article 3(5));
- 3D-printed products, expressly included in the definition of construction product (Article 3(1));
- Key parts — parts used as components or spare parts that a harmonised technical specification identifies as essential for the characterisation, safety or performance of a product (Article 3(16)).
Exclusions
Article 2(2) excludes lifts subject to Directive 2014/33/EU, escalators and their components, and requirements or performance assessment covered by delegated acts under Article 11(8) of the Drinking Water Directive (EU) 2020/2184. Article 2(3) allows Member States to exempt products placed on the market in the EU's outermost regions. Separately, Article 14 lets manufacturers of individually manufactured or custom-made non-series products, and of products for heritage conservation, opt out of drawing up a declaration of performance and conformity under strict conditions.
Distinctive feature: declared performance, not a safety claim
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 conformity element (Articles 13 and 15 and Annex V): where product requirements have been set by delegated act under Article 7, the combined declaration of performance and conformity also states that they are met. It replaces the DoP only once the new rules reach the product family under Article 95(9). Until then, a CPR-2011 Declaration of Performance remains the correct document.
Basic requirements for construction works (Annex I)
Annex I of Regulation 2024/3110 lists eight basic requirements for construction works (the seven of CPR 305/2011, reworded, plus emissions into the outdoor environment):
- Structural integrity of construction works;
- Fire safety of construction works;
- Protection against adverse hygiene and health impacts related to construction works;
- Safety and accessibility of construction works;
- Resistance to the passage of sound and acoustic properties of construction works;
- Energy efficiency and thermal performance of construction works;
- Emissions into the outdoor environment of construction works;
- Sustainable use of natural resources of construction works.
The "essential characteristics" of a construction product are those characteristics that relate to the basic requirements in Annex I, together with the predetermined environmental essential characteristics listed in Annex II (Article 3(7)). 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
Under CPR-2024, a harmonised standard stops being merely cited and becomes mandatory by implementing act. The Commission assesses a standard delivered by the European standardisation organisations and, if it meets the requirements, adopts an implementing act making it mandatory; it applies one year later unless the act sets a later date, which is reserved for exceptional and justified cases (Article 5(7) and (8)). Where standardisation fails, the Commission may adopt implementing acts setting out essential characteristics and assessment methods itself (Article 6(1)). Article 8 is a separate fall-back: common specifications as an alternative way to meet product requirements set under Article 7. European Assessment Documents, adopted by the organisation of technical assessment bodies, remain the route for products outside the harmonised specifications (Articles 31 to 37).
Assessment and verification of constancy of performance (AVCP)
Article 10 and Annex IX of Regulation 2024/3110 establish the assessment and verification systems: 1+, 1, 2+, 3+, 3 and 4. They resemble the AVCP systems of CPR-2011 and add System 3+, under which a notified body validates the environmental sustainability assessment. Products still under CPR-2011 use the AVCP systems of that Regulation (Annex V):
- System 1+ / 1 — Notified Body certifies the product, with continuing surveillance.
- System 2+ — Notified Body certifies the factory production control (FPC), with continuing surveillance.
- System 3+ — Manufacturer assesses environmental performance and maintains FPC; the notified body validates the input data, assumptions, method and software use, and inspects the plant initially.
- System 3 — Performance is assessed through tests by a notified testing laboratory, or through calculations, tabulated values or descriptive documentation; the notified body confirms the product type and decides on the certificate; the manufacturer maintains FPC.
- System 4 — Manufacturer alone determines the product type and maintains FPC; no Notified Body involvement.
The system applicable to each product family or category is set by Commission delegated act under Article 10(2), before the specification applies. It may differ within a family, by essential characteristic or product requirement.
Technical documentation
Under the new rules, Article 22(3) requires technical documentation as the basis for the declaration. It covers the declared use; all elements needed to demonstrate performance and conformity; the established procedures under Article 22(4); the applicable assessment and verification systems; any simplified procedures used under Articles 59 to 61; and the environmental sustainability calculation for the characteristics in Article 15(2). Economic operators keep documents and information for 10 years after supplying the product or service concerned, unless they are provided through the digital product passport (Article 20(4)). See technical documentation.
Declaration of Performance and Conformity
Where the new rules apply to a product family, Article 15 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;
- Environmental sustainability performance over the life cycle for the characteristics declared (Article 15(2)). As a minimum, Article 15(3) requires Annex II points (a) to (d) on climate change from 8 January 2026, points (e) to (m) from 9 January 2030 and points (n) to (s) from 9 January 2032, once a declaration of performance and conformity is required for the product;
- Digital product passport details, once the system is available.
Marking, labelling, and Digital Product Passport
Under the new rules, the CE marking is affixed only to products for which the manufacturer has drawn up a declaration of performance and conformity (Article 17(2)). It goes on the product or, where that is not possible, on an attached label or the packaging, or failing that the accompanying documents (Article 18(1)). Under Article 18(2), it must be followed by:
- The last two digits of the year in which the marking was first affixed (for used products, also the year of deinstallation);
- The name and registered address, or identifying mark, of the manufacturer and, where applicable, of the authorised representative;
- The unique identification code of the product type;
- The declaration code of the Declaration of Performance and Conformity;
- The identification number of the notified body or bodies, where applicable;
- A data carrier connected to the Digital Product Passport, once available.
The product-type code and declaration code may be replaced by a data carrier or permalink to the declaration, and may be omitted if the digital product passport data carrier is provided (Article 18(2)). Products still under CPR-2011 follow Articles 8 and 9 of that Regulation.
The construction digital product passport system is to be set up by Commission delegated act under Article 75(1). The system must be fully operational six months after that act enters into force, and the manufacturer obligation in Article 22(7) applies eighteen months after it (Article 80(1)). See Digital Product Passport.
Which product families move first
The first CPR Working Plan (COM(2025) 772 of 16 December 2025) covers 2026 to 2029 and all dates in it are indicative. It records three standardisation requests adopted so far: precast concrete products (family 1) and structural metallic products (family 20), both still under CPR-2011, and cement, building limes and other hydraulic binders (family 15). Examples of its planned dates for making standards mandatory:
| Annex VII family | Standards delivery | Made mandatory (implementing act) |
|---|---|---|
| 15: cement, building limes and hydraulic binders | Q3 2027 | Q4 2027 |
| 2: doors, windows, shutters, gates and hardware | 2028 | 2029 |
| 30: flat glass, profiled glass and glass block | 2028 | 2029 |
| 16: reinforcing and prestressing steel | 2029 | 2029 |
| 4: thermal insulation products | 2029 | 2029 |
Article 95(9) then adds at least one year before the obligations bite. Precast concrete and structural metallic products are listed for citation under CPR-2011, so those products stay on the old rules for now. The plan also foresees delegated acts on reaction and resistance to fire. The next working plan is due by the end of 2028, and the Commission reports progress annually, starting at the end of 2026.
Related legislation
- Ecodesign Regulation 2024/1781 (ESPR) — in the event of conflict, the relevant provisions of Regulation 2024/3110 prevail (Article 12(2)). Recital 32 gives ESPR priority for sustainability requirements on energy-related products in the ecodesign working plans that are also construction products, such as boilers and heat pumps, and on intermediate products other than cement.
- 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 — applies only to the extent that Union harmonisation legislation does not cover the same risks (Article 2(1) GPSR), so it can still matter for consumer-facing products outside a harmonised specification.
- REACH Regulation (EC) 1907/2006 — applies in parallel for chemical substances in construction products.
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.
- Assuming 8 January 2026 changed your paperwork. For a product under a harmonised standard cited under CPR-2011, the Declaration of Performance continues. A declaration of performance and conformity is needed only once Article 95(9) applies to the family, or if you opt in early.
- Missing or incomplete declaration. Without a required declaration, the product may not be made available on the market (Article 13(2)).
- Relying on "No performance determined" (NPD) under CPR-2011. National building rules may still require a declared value for the intended use, so check the Member States of destination. Under CPR-2024, delegated acts under Article 5(5) can make certain characteristics mandatory to declare (Article 15(3)).
- Using a harmonised standard that has been withdrawn or superseded. Check the OJEU references at the time of placing on the market.
- Assuming everything used on a site is a construction product. The definition covers items placed on the market for permanent incorporation into works (Article 3(1)); temporary works equipment is not incorporated permanently.
Frequently asked questions
Does Regulation 2024/3110 apply to my product now?
Probably not yet for its product obligations. If your product falls under a harmonised standard cited under Regulation 305/2011, you continue under the retained parts of that Regulation. Chapters I to III of Regulation 2024/3110 apply to your family one year after an implementing act makes a replacement specification mandatory, unless the act sets a later date (Article 95(9)).
Do I still issue a Declaration of Performance under Regulation 305/2011?
Yes, for products under harmonised standards cited under that Regulation and for products under qualifying European Assessment Documents. Article 95(8) keeps the relevant articles in force for those products only, until 8 January 2040 at the latest.
When is Regulation 305/2011 fully repealed?
On 8 January 2040 (Article 94). Most of it was repealed on 8 January 2026, but the articles and annexes needed for products under legacy standards and European Assessment Documents continue until 2040. In practice, a family moves earlier, when its new specification takes effect.
Do I have to declare global warming potential since 8 January 2026?
Only in a declaration of performance and conformity. Article 15(3) sets 8 January 2026 as the starting point for the climate change characteristics in Annex II, but a product needs that declaration only once the new rules reach its family under Article 95(9), or if the manufacturer opts in.
Is my existing notified body certificate still valid?
Notified bodies under Regulation 305/2011 are treated as notified under the new Regulation, subject to reassessment by 8 January 2030 (Article 95(2)). Existing certificates and test reports can serve as a technical basis under the new rules where the product type corresponds and the methods remain valid (Article 95(7)).
Can I switch to the new Regulation early?
Yes, once a harmonised technical specification for the family has entered into force. Article 95(9) lets economic operators apply it from then by following the procedure leading to a declaration of performance and conformity.
Sources
- Regulation (EU) 2024/3110 on construction products — EUR-Lex.
- European Commission — Construction Products Regulation 2024 revision.
- European Commission — (First) CPR Working Plan for 2026-2029, COM(2025) 772.
- 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.