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 from 8 January 2026, with certain provisions applying from 7 January 2025 and Article 92 (penalties) from 8 January 2027 (Article 96). 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; Articles 1 to 4, parts of Articles 5, 7 and 12, Articles 9, 10, 63, 89 and 90 and several annexes from 7 January 2025; Article 92 (penalties) from 8 January 2027 (Article 96).
- 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, except for the provisions needed for products covered by legacy harmonised standards and European assessment documents, which are repealed with effect from 8 January 2040 (Article 94); transitional provisions in Article 95.
- Status in October 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, 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. 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;
- 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: 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 (Articles 13 and 15 and Annex V), 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 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
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 implementing acts setting common specifications where standardisation is delayed or deficient (Article 8). 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)
Article 10 and Annex IX of Regulation 2024/3110 establish the assessment and verification systems (AVS) — labelled 1+, 1, 2+, 3, 3+ and 4 — analogous to the AVCP systems of CPR 305/2011 but with adjustments, including the new System 3+ for notified-body control of the environmental sustainability assessment:
- 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 system applicable to each product family or category is determined by Commission delegated act under Article 10(2).
Technical documentation
Article 22(3) requires 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: economic operators must keep documents and information at the disposal of national authorities for 10 years after they supplied or were supplied with the product (Article 20(4)). See technical documentation.
Declaration of Performance and Conformity
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 for the predetermined environmental essential characteristics in Annex II that are declared (Article 15(2));
- 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 drawn up a Declaration of Performance and Conformity. Under Article 18(2), the CE marking 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.
Construction products in scope of Regulation 2024/3110 will progressively be required to carry a Digital Product Passport identifier, under Articles 75 to 80, once the construction digital product passport system has been established by Commission delegated act under Article 75(1). 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 Article 7 (product requirements) and Article 10(2) (assessment and verification systems for product families) are in preparation.
- 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.