Construction Products Regulation (EU) 2024/3110: what applies to you now and what waits

The Construction Products Regulation, Regulation (EU) 2024/3110Regulation (EU) 2024/3110, Construction Products RegulationThe whole regulationClick opens the law on the EU Publications Office., entered into force on 7 January 2025 and replaces Regulation (EU) No 305/2011Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)The whole regulationClick opens the law on the EU Publications Office. in stages (Art. 96Regulation (EU) 2024/3110, Construction Products RegulationArticle 96Click opens the article on EUR-Lex., Art. 94Regulation (EU) 2024/3110, Construction Products RegulationArticle 94Click opens the article on EUR-Lex.). For a seller the stage that counts is the switch of a product family, or of a category within it. The new duties start one year after the Commission adopts the implementing act that makes that family’s new standard mandatory, or on a later date the act names (Art. 95(9)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 9Click opens the article on EUR-Lex., Art. 5(8)Regulation (EU) 2024/3110, Construction Products RegulationArticle 5, paragraph 8Click opens the article on EUR-Lex.). The Commission says the first such acts, for cement, are probably due in 2027 (European Commission, harmonised technical specifications). Its working plan puts the adoption for cement in the fourth quarter of 2027, so on that plan the cement duties would start around the fourth quarter of 2028 (Commission working plan, Table 3). Until the switch, a product that a standard cited under the old Regulation covers keeps the old rules: the manufacturer draws up a declaration of performance and affixes the CE marking.

What you do:

1. Settle whether the Regulation reaches your product. It does only if the product is a construction product, meaning an item placed on the market to be built permanently into a building or civil engineering work, and a harmonised standard cited under the old Regulation covers it or a European technical assessment has been issued for it (Art. 3, points (1) and (3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 3Click opens the article on EUR-Lex., Art. 20(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 20, paragraph 1Click opens the article on EUR-Lex., Art. 4(1)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 4, paragraph 1Click opens the article on EUR-Lex.; European Commission, CPR overview). Annex VII lists 36 product families, from cement and doors and windows to insulation, fixings, adhesives, sealants and cables. A product no such standard or assessment covers needs no declaration and takes no CE marking under this Regulation.
2. If you make the product, you draw up the technical documentation and the declaration of performance, affix the CE marking, and keep both for 10 years (Art. 4(1)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 4, paragraph 1Click opens the article on EUR-Lex., Art. 6Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 6Click opens the article on EUR-Lex., Art. 8(2)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 8, paragraph 2Click opens the article on EUR-Lex., Art. 9Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 9Click opens the article on EUR-Lex., Art. 11(1)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 11, paragraph 1Click opens the article on EUR-Lex., Art. 11(2)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 11, paragraph 2Click opens the article on EUR-Lex.).
3. If you import or distribute it, check before you sell that the product carries the CE marking, comes with the declaration of performance and has instructions and safety information in a language the country of sale determines and users can easily understand. An importer adds its own name and contact address (Art. 13(2)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 13, paragraph 2Click opens the article on EUR-Lex., Art. 13(3)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 13, paragraph 3Click opens the article on EUR-Lex., Art. 13(4)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 13, paragraph 4Click opens the article on EUR-Lex., Art. 14(2)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 14, paragraph 2Click opens the article on EUR-Lex.).
4. If the manufacturer is outside the EU, name an operator established in the EU: an EU manufacturer, an importer, an authorised representative or, where none of these exists, a fulfilment service provider (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). Who can play that part is in EU responsible person.
5. Selling another maker’s product under your own name or trademark makes you the manufacturer, with every manufacturer duty (Art. 15Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 15Click opens the article on EUR-Lex.; Art. 26(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 26, paragraph 1Click opens the article on EUR-Lex.).
6. Selling online counts as selling in the EU when the offer is aimed at EU customers (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex.). The online-sale duties of the new Regulation for sellers wait for the switch, as set out below.
7. Find the date of your product family. The implementing act for it sets the clock: the new rules apply one year after the Commission adopts it, or on a later date the act names, and you may apply them earlier if you choose (Art. 95(9)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 9Click opens the article on EUR-Lex.).

Two Regulations apply side by side, and each product family moves from the old to the new on its own date

The Commission calls this the coexistence principle: “Product families will migrate to the new framework individually. If a product is covered by a standard cited under the CPR-2011, in principle the provisions of the CPR-2011 apply. Once a new performance harmonised standard is cited under CPR-2024, the product family must follow the new regulation” (European Commission, CPR 2024 revision). The law says the same in its transitional article. Harmonised standards cited under the old Regulation stay valid under it until the Commission withdraws them. The old articles on the declaration of performance, CE marking and operators then apply only to products covered by those standards or by the old European assessment documents (Art. 95(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 3Click opens the article on EUR-Lex., Art. 95(8)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 8Click opens the article on EUR-Lex.).

What you owe today and what you will owe after the switch, by role

Every operator under the new Regulation must also, on request of an authority, name its suppliers and customers for a product, keep its documents for 10 years and present them within 10 days of a request, and give users a channel such as a telephone number or an email address to report an accident or a safety issue (Art. 20(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 20, paragraph 3Click opens the article on EUR-Lex., Art. 20(4)Regulation (EU) 2024/3110, Construction Products RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex., Art. 20(5)Regulation (EU) 2024/3110, Construction Products RegulationArticle 20, paragraph 5Click opens the article on EUR-Lex.).

The declaration of performance and the declaration of conformity become one document, the DoPC

Under the old Regulation the manufacturer draws up a declaration of performance, the DoP. It states how the product performs on its essential characteristics, as the harmonised standard sets them (Art. 4(1)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 4, paragraph 1Click opens the article on EUR-Lex., Art. 6(1)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 6, paragraph 1Click opens the article on EUR-Lex.). The old Regulation has no declaration of conformity of its own. That term belongs to the Directive 89/106/EEC it replaced.

The new Regulation merges the two into the declaration of performance and conformity, the DoPC. It expresses the product’s performance on its essential characteristics and, where product requirements apply, states that the product meets them (Art. 15(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 15, paragraph 1Click opens the article on EUR-Lex.). By drawing it up the manufacturer takes responsibility for the product’s conformity with its declared performance and the requirements, and becomes liable under national law (Art. 13(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 13, paragraph 2Click opens the article on EUR-Lex.).

The environmental part is phased. The declaration must cover at least the climate-change characteristics of Annex II from 8 January 2026, the points (e) to (m), among them ozone depletion, acidification and water use, from 9 January 2030, and the points (n) to (s), among them particulate matter and land-use impacts, from 9 January 2032 (Art. 15(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex.). Read it with Art. 95(9)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 9Click opens the article on EUR-Lex.: the duties of Chapter II reach a product family only after its switch.

The DoPC is the declaration of this Regulation. Other EU product laws, such as the low-voltage and machinery rules, have an EU declaration of conformity of their own; how those declarations work is on the declaration of conformity.

CE marking goes on only with a declaration behind it, and the new mark carries more after it

The CE marking is affixed only to products for which the manufacturer has drawn up the declaration (Art. 8(2)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 8, paragraph 2Click opens the article on EUR-Lex., Art. 17(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 17, paragraph 2Click opens the article on EUR-Lex.). A product that no cited standard and no assessment covers does not take it. The marking goes on visibly, legibly and indelibly, on the product, or on a label, the packaging or the accompanying documents where that is not possible, before the product is placed on the market (Art. 9Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 9Click opens the article on EUR-Lex., Art. 18Regulation (EU) 2024/3110, Construction Products RegulationArticle 18Click opens the article on EUR-Lex.). It is the only marking that attests the performance of the product on the characteristics assessed (Art. 8(3)Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)Article 8, paragraph 3Click opens the article on EUR-Lex., Art. 17(4)Regulation (EU) 2024/3110, Construction Products RegulationArticle 17, paragraph 4Click opens the article on EUR-Lex.). How the marking works across all EU product laws is in CE marking.

What follows the marking differs:

Harmonised technical specifications now mean the mandatory ones only

Under the old Regulation the term covers harmonised standards and European assessment documents. Under the new one it covers only the performance harmonised standards the Commission has made mandatory, the fall-back implementing acts used if standardisation is blocked, and three kinds of delegated act: those that set product requirements, those that set rules on product information and those that fix the assessment and verification system of a product family (Art. 3, point (42)Regulation (EU) 2024/3110, Construction Products RegulationArticle 3Click opens the article on EUR-Lex., Art. 6(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 6, paragraph 1Click opens the article on EUR-Lex., Art. 7(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 7, paragraph 1Click opens the article on EUR-Lex., Art. 9(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 9, paragraph 3Click opens the article on EUR-Lex., Art. 10(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 10, paragraph 2Click opens the article on EUR-Lex.; European Commission, harmonised technical specifications). European assessment documents are no longer part of it. They stay a route to voluntary CE marking. Delegated Regulation (EU) 2026/1310, which sets the assessment systems, is itself a delegated act of the last kind.

The path of a standard under the new Regulation has three steps. The Commission asks the European standardisation organisations to draft it; it assesses the result and, if the standard is in conformity, adopts an implementing act that makes it mandatory; the standard binds one year after that act, unless the act names a later date. It may be applied voluntarily from the day the act is adopted (Art. 5(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 5, paragraph 2Click opens the article on EUR-Lex., Art. 5(8)Regulation (EU) 2024/3110, Construction Products RegulationArticle 5, paragraph 8Click opens the article on EUR-Lex.). A standard cited under the old Regulation is replaced this way, and its citation is withdrawn after a transitional period of at least one year (European Commission, CPR 2024 revision).

A notified body takes part in some assessment systems and in none of others

The old Regulation’s systems carry over, with changes. The new Regulation has six assessment and verification systems: 1+, 1, 2+, 3+, 3 and 4. System 4 is the manufacturer’s self-verification and self-certification, with no task for a notified body. In the others a notified body issues a certificate or a validation report. Which system applies to a product family and category is set by Delegated Regulation (EU) 2026/1310 (Annex IX; Art. 10(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 10, paragraph 2Click opens the article on EUR-Lex.; Delegated Regulation (EU) 2026/1310, Art. 3). The delegated Regulation was published on 28 August 2026 and entered into force on the twentieth day after that, 17 September 2026 (Art. 4). It matters to you when a family switches. How a notified body works and how to find one is on notified body.

Selling online: what the new Regulation adds for marketplaces, shops and distance sales

Today, what the law adds for an online offer comes from Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.. An offer aimed at EU end users counts as made available on the EU market, and a product under the old Regulation needs an operator established in the EU (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex., Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). The old Regulation itself has no article on online sales.

The new Regulation adds a set of rules for operators. They apply to a product family, or a category within it, after its switch (Art. 95(9)Regulation (EU) 2024/3110, Construction Products RegulationArticle 95, paragraph 9Click opens the article on EUR-Lex.). The marketplace duties and the rule on intermediaries are set out under “What the law leaves open”, because the text does not say whether they wait for the switch.

• What the listing shows. Where required, the offer must show clearly and visibly the CE marking, the details that follow it, the label of Art. 22(9)Regulation (EU) 2024/3110, Construction Products RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex. and the data carrier of the digital product passport (Art. 29(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 29, paragraph 2Click opens the article on EUR-Lex.). A manufacturer, importer or distributor must display the information the Regulation requires to customers before they are bound by a sales contract, distance selling included. The manufacturer must also show a label “Only for professional use” there. A product without that label is deemed also meant for consumers (Art. 22(5)Regulation (EU) 2024/3110, Construction Products RegulationArticle 22, paragraph 5Click opens the article on EUR-Lex., Art. 24(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 24, paragraph 3Click opens the article on EUR-Lex., Art. 25(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 25, paragraph 3Click opens the article on EUR-Lex.).
• What the manufacturer gives you. Once a passport exists for the product, the manufacturer must give an online seller a digital copy of the data carrier and the product identifier, free of charge and within five working days of the request, so that customers who cannot see the product can reach the information (Art. 77(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex.).

The Commission’s summary of the same rules is on its page for economic operators.

A manufacturer outside the EU needs an EU operator today, and an authorised representative after the switch

Today, Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. lists Regulation (EU) No 305/2011Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)The whole regulationClick opens the law on the EU Publications Office. among the laws for which a product “may be placed on the market only if there is an economic operator established in the Union” who holds the declaration of performance and the technical documentation and answers the authorities (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). The operator’s name and contact details go on the product, its packaging, the parcel or a document with it (Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). A reference to the old Regulation reads as a reference to the new one (Art. 94Regulation (EU) 2024/3110, Construction Products RegulationArticle 94Click opens the article on EUR-Lex.).

After the switch the new Regulation adds its own rule: a manufacturer not established in the EU must appoint a single authorised representative by written mandate (Art. 23(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 23, paragraph 1Click opens the article on EUR-Lex.). Drawing up the technical documentation cannot be part of that mandate. The mandate must let the representative at least keep the declaration and documentation for the authorities, hand them the information they ask for, end the contract if the manufacturer breaks the rules and tell the authorities of a risk, and cooperate on corrective action (Art. 23(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 23, paragraph 2Click opens the article on EUR-Lex.). The Commission says the duty includes manufacturers in the EEA, Switzerland and Turkey (European Commission, economic operators).

An importer or distributor that sells under its own name or trademark, changes the product, gives it a use other than the manufacturer assessed, claims characteristics the manufacturer did not declare, or chooses to take the role is treated as the manufacturer (Art. 26(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 26, paragraph 1Click opens the article on EUR-Lex.). Adding translations, and repackaging that does not touch the product’s condition or the required information, do not make you the manufacturer (Art. 26(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 26, paragraph 3Click opens the article on EUR-Lex.). Who may be the EU operator, and the difference between a representative and a responsible person, is in EU responsible person and authorised representative vs responsible person.

If you sell without the declaration or the marking, the authorities can have the product withdrawn

Under the new Regulation, where a market surveillance authority finds that a product covered by a harmonised technical specification, or its manufacturer, does not comply, it requires the operator to take corrective action, to withdraw the product or to recall it within a reasonable period. If the operator does not, the authority makes sure the product is withdrawn or recalled, or that making it available is prohibited or restricted. The operator must extend the corrective action to every unit it supplied across the EU (Art. 65(1)Regulation (EU) 2024/3110, Construction Products RegulationArticle 65, paragraph 1Click opens the article on EUR-Lex., Art. 65(3)Regulation (EU) 2024/3110, Construction Products RegulationArticle 65, paragraph 3Click opens the article on EUR-Lex., Art. 65(4)Regulation (EU) 2024/3110, Construction Products RegulationArticle 65, paragraph 4Click opens the article on EUR-Lex.). A product for which a declaration is required, and none exists, may not be made available on the market (Art. 13(2)Regulation (EU) 2024/3110, Construction Products RegulationArticle 13, paragraph 2Click opens the article on EUR-Lex.). Each EU country sets the penalties, which must be effective, proportionate and dissuasive. Its duty to lay down the rules applies from 8 January 2027, and it notifies them to the Commission by 8 December 2026 (Art. 92Regulation (EU) 2024/3110, Construction Products RegulationArticle 92Click opens the article on EUR-Lex., Art. 96Regulation (EU) 2024/3110, Construction Products RegulationArticle 96Click opens the article on EUR-Lex.). The old articles on market surveillance and on formal non-compliance were repealed on 8 January 2026 (Art. 94Regulation (EU) 2024/3110, Construction Products RegulationArticle 94Click opens the article on EUR-Lex.).