Construction Products (CPR)

CPR compliance is not “just CE”

Construction products are one of the most complex CE-marking areas in the EU. Unlike many product groups, CPR compliance often depends on whether a suitable harmonised technical specification exists and which conformity route is available.

In practice, manufacturers frequently face:

• incomplete / changing harmonisation (not every product has a usable harmonised standard)
• different certification routes depending on product type and intended use
• different AVCP systems with different roles for the manufacturer vs. Notified Bodies
• national building rules that still influence market acceptance in each Member State

Our job is to turn this complexity into a clear, evidence-based route to compliant EU market access.

Construction Products Regulation (CPR) — what it actually covers

The Construction Products Regulation (EU) No 305/2011 sets rules for how manufacturers assess and declare performance of construction products and how CE marking is used when a harmonised technical specification applies.

Important nuance: CPR CE marking is primarily about declared performance (DoP) against relevant characteristics — it is not a universal “approval for use everywhere” in construction works.

Products typically covered

• Cement, concrete, and aggregates
• Structural metalwork
• Windows, doors, and curtain walling
• Thermal insulation products
• Roofing and waterproofing materials
• Fire protection products
• Sanitary appliances
• Road construction products

Two main routes to CE marking under CPR

1) Harmonised standard route (hEN)

If your product is covered by a harmonised European standard (hEN), CE marking is typically based on that standard’s declared characteristics, test methods, and requirements for factory production control (FPC) — together with the applicable AVCP system.

2) ETA route (EAD/ETA) when harmonisation is not available

If there is no suitable harmonised standard, CE marking may still be possible via an European Assessment Document (EAD) and a European Technical Assessment (ETA) issued by a Technical Assessment Body (TAB). This route is often used for innovative products, kits, or system products.

AVCP systems — why they define cost and timeline

The Assessment and Verification of Constancy of Performance (AVCP) system determines who does what (manufacturer vs. third party):

• System 1+ / 1 / 2+: significant involvement of a Notified Body (certification and ongoing surveillance; scope depends on the system)
• System 3: typically third-party testing by a notified laboratory, with manufacturer responsibility for FPC
• System 4: manufacturer-only route (no Notified Body), still requiring robust testing and control

We help you identify the correct AVCP route early — because it drives evidence, budget, and the required partners.

Not harmonised does not mean “no requirements”

Even where CE marking is possible, national building rules and application conditions can still affect acceptance. For many manufacturers, the biggest risk is not the CE mark itself — it is choosing the wrong route or declaring the wrong performance characteristics for the intended markets.

Our services for CPR / construction products

• Route selection: hEN vs. ETA (EAD/ETA) strategy
• Identification of applicable standards/specifications and performance characteristics
• AVCP determination and coordination with Notified Bodies / TABs
• Testing plan, lab coordination, and evidence review
• DoP (Declaration of Performance) preparation and CE marking file package
• Factory Production Control (FPC) implementation support
• Pre-audit / readiness check to reduce rework and delays

Request CPR Certification Support