CE Marking for Construction Products and the New European CPR
The legislation governing the placing of construction products on the European market is undergoing a significant transformation. The CE marking and performance assessment system applied under the current Construction Products Regulation (305/2011/EU) has been restructured by the new Construction Products Regulation (EU) 2024/3110.
The new regulation addresses not only the technical performance of construction products but also environmental sustainability, the circular economy, resource efficiency, durability and digital product information.
What Changes with (EU) 2024/3110?
- Assessment of environmental sustainability performance
- Consideration of environmental impacts across the product lifecycle
- Resource efficiency and circularity
- Reuse, repair and recycling
- Durability and service life of products
- Provision of product information in digital form
- The Digital Product Passport approach
- Increased product traceability
- More comprehensive declaration of performance and conformity information
Declaration of Performance and Conformity
Under the new CPR, the Declaration of Performance and Conformity prepared by the manufacturer sets out the performance of the product with regard to the relevant essential characteristics and its conformity with the applicable product requirements. Where the relevant conditions apply, the declaration also contains information on the environmental sustainability performance of the product across its lifecycle — a broader assessment model than declaring technical performance alone.
Environmental Sustainability
One of the most important changes in the new CPR is the systematic treatment of the environmental performance of construction products. A system is being established to assess environmental impacts across the product lifecycle:
raw material → production → transport → use → end of life
The European Commission requires manufacturers to declare lifecycle-based performance data for certain environmental essential characteristics.
Digital Product Passport
(EU) 2024/3110 introduces a Digital Product Passport system for construction products, making performance and conformity information, safety information, instructions for use and other information required under the CPR digitally accessible. The system will also facilitate product traceability and the sharing of sustainability information in the construction sector.
AVCP – Assessment and Verification of Constancy of Performance
The conformity assessment system has been updated under the new CPR, with new approaches for verifying environmental essential characteristics in particular. One of these is System 3+, used specifically for verifying essential characteristics relating to environmental sustainability.
The assessment and verification system to be applied varies according to the product family, the relevant harmonized technical specification and the essential characteristics determined for the product.
The New Generation Approach
(EU) 2024/3110 makes sustainability and digitalization key elements of the CE conformity process. Products are increasingly assessed in terms of:
Technical Performance + Safety + Durability + Environmental Performance + Circularity + Digital Product Information
Topics such as carbon footprint, life cycle assessment, recyclability, reuse and resource efficiency will therefore become increasingly important for construction product manufacturers.
What This Means for Manufacturers
- Determining the legislative and technical specification scope of their products,
- Following the relevant harmonized standards,
- Determining and verifying product performance,
- Effectively implementing the Factory Production Control (FPC) system,
- Carrying out the necessary tests and assessments,
- Preparing performance and conformity information,
- Ensuring product traceability,
- Producing the required environmental performance data,
- Preparing for the new digital information and product passport requirements.
Transition from 305/2011 to 2024/3110
Not all construction products will move to the new system at the same time. According to the transition approach announced by the European Commission, 305/2011 and 2024/3110 will apply in parallel for a period. A product family will move to the new system once a harmonized performance standard is published under the new CPR and its reference appears in the Official Journal of the European Union. The replacement of harmonized standards will take place per product family within the defined transition periods; the full repeal of 305/2011 is foreseen for 2039.
Our Services
We provide technical support in determining the legislative scope of construction products, identifying relevant standards and technical specifications, determining the AVCP system, test and conformity assessment processes, Factory Production Control (FPC), the Declaration of Performance (DoP), CE marking and the transition to the new (EU) 2024/3110 CPR requirements.
Contact us to have your current CE process assessed against the new CPR requirements and to build a transition plan.