Construction Products Regulation CPR (EU) 305/2011: CE Marking for Construction.
The CPR Regulation (EU) 305/2011 sets the rules for CE marking construction products placed on the EU market. IgeraIndustria answers every CPR compliance question: harmonised standard applicability, Declaration of Performance content, AVCP system requirements, Notified Body obligations, and DoP mandatory fields. Your technical and regulatory team finds the answer in seconds.
CPR 305/2011: CE marking and DoP compliance for construction products
CE marking under the CPR is mandatory for all construction products covered by a harmonised standard. Yet many manufacturers confuse the AVCP system that applies to their product, omit mandatory fields from the Declaration of Performance, or do not know when a European Technical Assessment is needed in the absence of a harmonised standard.
35+
construction product families covered by published harmonised standards (hEN) in the Official Journal. CE marking is mandatory once the coexistence period ends.
DoP
Declaration of Performance is mandatory with every CE-marked construction product. It must declare performance against essential characteristics and reference the applicable hEN or ETA.
AVCP 1+
the most rigorous AVCP system, applied to structural products and products with significant safety implications (e.g. structural steel, fire-resistance products). Requires Notified Product Certification Body.
The regulatory team spends hours identifying which AVCP system applies to their product, what must appear in each field of the Declaration of Performance, and whether their factory production control system meets the harmonised standard requirements. IgeraIndustria answers those questions in seconds, citing the exact CPR article or annex, so the technical team can focus on getting to market.
Instant CPR compliance query by product type
IgeraIndustria locates the exact CPR requirement that applies to each product and responds with the applicable harmonised standard, AVCP system, DoP mandatory content, and Notified Body obligations.
Harmonised standard applicability
Not all construction products are covered by a published hEN. IgeraIndustria identifies whether a harmonised standard exists for your product, whether the coexistence period has ended (making CE marking mandatory), and which essential characteristics must be declared under that standard.
AVCP system determination
The AVCP system (1+, 1, 2+, 3 or 4) is specified in the harmonised standard or in the Commission decision for each product. IgeraIndustria identifies which system applies to your product and explains the obligations: who tests, who certifies, and what the Notified Body must do.
Declaration of Performance content
CPR Article 6 and Annex III specify the mandatory fields of the DoP: product type identification, reference to hEN or ETA, intended use, list of essential characteristics, declared performance or “No Performance Determined” (NPD), and reference to the Notified Body. IgeraIndustria identifies missing or incorrect DoP fields.
European Technical Assessment (ETA)
When no harmonised standard exists for a product, the manufacturer may apply to a Technical Assessment Body (TAB) for an ETA based on a European Assessment Document (EAD). IgeraIndustria explains the ETA procedure, the EAD content requirements, and how to use the ETA as the basis for CE marking and a DoP.
Factory Production Control (FPC) requirements
All AVCP systems require the manufacturer to maintain a documented Factory Production Control system in accordance with the applicable harmonised standard. IgeraIndustria explains the FPC documentation requirements: procedures, inspection frequencies, non-conforming product management, and record retention.
CPR and product liability
The CPR does not harmonise national building requirements or establish performance levels — it only requires that manufacturers declare performance. IgeraIndustria clarifies the distinction between CE marking obligations and national technical specifications, and the liability implications of the declared performance.
Complete CPR (EU) 305/2011 compliance support
From harmonised standard identification to DoP preparation and Notified Body management, IgeraIndustria supports the technical and regulatory team at every stage of CPR conformity assessment.
Initial type testing (ITT) planning
Initial type testing must be performed in accordance with the harmonised standard to establish the declared performance of the product type. IgeraIndustria identifies the test methods specified in the hEN, the sampling requirements, and which characteristics require third-party testing under AVCP 1+ or 3 vs manufacturer self-testing under AVCP 4.
DoP preparation and review
The Declaration of Performance is a legal document. Errors or omissions expose the manufacturer to market surveillance enforcement. IgeraIndustria reviews draft DoPs for completeness, checks that all mandatory essential characteristics are listed, that NPD is correctly used where performance is not declared, and that the Notified Body reference number is correctly stated.
CE marking label content
CPR Annex ZA of each harmonised standard specifies the information that must appear on the CE marking label or accompanying documentation. IgeraIndustria identifies the mandatory label content for your product: identification code, last two digits of year, DoP number, product description, intended use, and performance level by characteristic.
Micro-enterprise simplified DoP
CPR Article 37 allows micro-enterprises (fewer than 10 persons, annual turnover or balance sheet total <€2 million) to use a simplified assessment procedure for products covered by AVCP systems 3 and 4. IgeraIndustria explains the conditions for using the simplified procedure and the documentation still required.
Technical file and record retention
Manufacturers must keep the technical documentation and the DoP for 10 years after the last product covered by the DoP was placed on the market. IgeraIndustria explains the technical file content requirements: ITT reports, FPC procedures, hEN or ETA reference, Notified Body certificate (where applicable), and traceability records.
Importers and distributors under CPR
CPR Article 13 imposes obligations on importers: they must ensure the manufacturer has prepared a DoP and affixed CE marking correctly, that the product is accompanied by instructions and safety information in the language of the Member State where sold, and that the manufacturer is identifiable. IgeraIndustria clarifies the importer due-diligence obligations.
The 4 pillars of CPR (EU) 305/2011 compliance
These pillars define what manufacturers must demonstrate before affixing CE marking and placing construction products on the EU market.
Pillar 1 — Harmonised standard or ETA
CE marking under CPR requires either a published harmonised standard (hEN) whose reference appears in the Official Journal, or a European Technical Assessment (ETA) for the specific product. Where a hEN exists and the coexistence period has ended, CE marking is mandatory. Where no hEN exists, the manufacturer may apply for an ETA from a Technical Assessment Body. Products not covered by a hEN or ETA cannot bear CE marking under CPR.
Pillar 2 — AVCP and Notified Body
The AVCP system specified in the hEN determines the role of the Notified Body. Under systems 1+, 1 and 2+, a Notified Product Certification Body must be involved. Under system 3, a Notified Testing Laboratory performs initial type testing. Under system 4, the manufacturer performs all conformity assessment activities without a Notified Body. The Notified Body’s certificate number must appear in the DoP where applicable.
Pillar 3 — Declaration of Performance (DoP)
The DoP is the manufacturer’s legally binding declaration of the product’s performance against the essential characteristics defined in the hEN or ETA. It must be drawn up before CE marking is affixed. The DoP must be made available to the customer: on paper (unless the customer consents to electronic delivery) or on the manufacturer’s website. A unique identification code must link the DoP to the product type.
Pillar 4 — CE marking label and instructions
CE marking is affixed by the manufacturer to the product, its packaging, or its accompanying documentation. It must be followed by the last two digits of the year it was first affixed. The name and registered address of the manufacturer, the product type identification code, the DoP number, and the performance levels must accompany the CE marking as specified in the hEN. Instructions and safety information must be in the official language(s) of the Member State of destination.
How IgeraIndustria works for CPR (EU) 305/2011
Five steps from loading your product documentation to receiving an answer with the exact CPR article, applicable AVCP system, and DoP mandatory content.
Index your CPR product documentation
Upload your Declarations of Performance, initial type test reports, factory production control procedures, Notified Body certificates, and ETAs. IgeraIndustria processes them together with the full CPR (EU) 305/2011 text and the Official Journal list of harmonised standards in under 24 hours.
Connect the assistant to your regulatory team
Embed it in your compliance portal, Teams, Slack or as a standalone tool for the product management and regulatory affairs team. One line of code. Compatible with any document management system.
Ask in plain language
«Which AVCP system applies to our structural timber product under EN 14081-1?», «What fields are mandatory in the DoP for our cement product?», «Can we use NPD for fire resistance in our window DoP?»
IgeraIndustria searches across 2 knowledge layers
First in your internal product documentation (DoPs, ITT reports, Notified Body certificates, FPC procedures), then in the indexed CPR (EU) 305/2011 regulation and Official Journal harmonised standards list.
Answer with regulation reference and AVCP obligation
The response cites the applicable CPR article or annex, states which AVCP system applies, which Notified Body involvement is required, and flags the most common DoP errors that market surveillance authorities detect.
IgeraIndustria in action — CPR AVCP system and DoP query
AVCP system determination and DoP mandatory content query for a structural timber product resolved in under 3 seconds with the applicable standard and Notified Body requirement.
Regulatory Affairs Manager
We manufacture structural timber products covered by EN 14081-1. Which AVCP system applies and do we need a Notified Body? What must our DoP contain?
IgeraIndustria
CPR 305/2011 — Structural Timber EN 14081-1
AVCP system for EN 14081-1:
- • System 1 applies to strength class-graded structural timber — a Notified Product Certification Body (NPCB) must certify the constancy of performance
- • The NPCB performs initial inspection of the factory and the FPC, and carries out surveillance, assessment and evaluation at least once per year
Mandatory DoP content for your product:
- • Unique identification code of the product type
- • Reference to EN 14081-1 and the strength class(es) declared
- • Intended use: structural applications in accordance with Eurocode 5
- • NPCB name and certificate number
- • Performance declared for each essential characteristic (or NPD where applicable)
⚠️ Bending strength (fₚ,k), modulus of elasticity (E₀,mean), and density (ρk) must be declared — NPD is not acceptable for structural safety characteristics
✓ CPR (EU) 305/2011 Art. 6 + EN 14081-1:2016+A1:2019 Annex ZA · Confidence: 98.1%
12
product lines under CPR
-55%
DoP preparation time
0
market surveillance NCs
We manufacture twelve product lines all subject to different harmonised standards and AVCP systems under CPR 305/2011. Preparing correct Declarations of Performance — with the right characteristics declared and the right Notified Body reference — used to take our regulatory team weeks per product update. IgeraIndustria resolves the AVCP system and DoP content questions in seconds. Our market surveillance audits are clean.
*Representative testimonial based on results from real customers
Frequently asked questions — CPR (EU) 305/2011
Which construction products require CE marking under CPR 305/2011?
CE marking is mandatory for all construction products covered by a harmonised standard (hEN) whose reference has been published in the Official Journal of the EU. The main product families covered include: cements (EN 197-1), aggregates for concrete (EN 12620), reinforcing steel (EN 10080), windows and external pedestrian doorsets (EN 14351-1), external thermal insulation composite systems (EN 13499/13500), waterproofing products (EN 13707, EN 13956), chimney systems (EN 1443), structural timber (EN 14081-1), and prefabricated concrete elements (EN 13369). If no hEN exists, manufacturers may voluntarily obtain a European Technical Assessment (ETA) from a Technical Assessment Body (TAB).
What are the Assessment and Verification of Constancy of Performance (AVCP) systems?
AVCP systems determine how the manufacturer verifies and declares the performance of a construction product. System 1+ (most rigorous): Notified Product Certification Body (NPCB) issues a certificate of constancy of performance based on its own testing, inspection of factory production control, and audit-testing of samples; also carries out surveillance, assessment and evaluation. System 1: same as 1+ but without audit-testing of samples. System 2+: manufacturer tests initial types and maintains FPC; NPCB certifies FPC only. System 3: NPCB performs initial type testing; manufacturer maintains FPC without NB involvement. System 4: manufacturer does everything (testing, FPC, DoP) without NB involvement.
What is the New CPR (proposed revision) and when will it apply?
The European Commission proposed a revised CPR (New CPR) in 2022 to address limitations of the 2011 Regulation. Key changes in the proposal: mandatory digital labelling and Digital Product Passport for construction products; simplified rules for micro-enterprises; introduction of environmental and safety requirements alongside performance; clearer rules on third-country products; and a single European Assessment Document (EAD) repository. The New CPR was still under trilogue negotiation as of mid-2024. If adopted, there will be a transition period of several years before it fully replaces CPR 305/2011. Manufacturers should monitor the legislative progress and assess impact on their product documentation.
IgeraIndustria CPR (EU) 305/2011 Plans
No lock-in. Cancel whenever you want.
Starter
For construction product manufacturers that need to identify the correct AVCP system, harmonised standard, and DoP content without weeks of regulatory research.
- CPR 305/2011 pre-indexed
- AVCP system identification tool
- DoP content checklist
- 1,000 queries/month
- Widget for the regulatory team
- Email support
Professional
For manufacturers with multiple product lines under CPR that need ongoing compliance support for the technical and regulatory affairs team.
- CPR + internal DoPs and ITT reports indexed
- Multi-product DoP management
- FPC gap analysis
- 5,000 queries/month
- hEN update alerts
- Priority support
Enterprise
For construction product groups managing CPR alongside other CE marking regulations (LVD, Machinery, EMC) requiring integrated compliance management.
- Multi-regulation (CPR + LVD + Machinery)
- Multi-brand and multi-site management
- Market surveillance response kit
- Unlimited queries
- 99.9% uptime SLA
- Dedicated customer success
Comply with CPR 305/2011. No more DoP errors or market surveillance issues.
- Free 14-day trial — no credit card required
- Full CPR (EU) 305/2011 text and harmonised standards list pre-indexed from day 1
- Upload your DoPs, ITT reports, Notified Body certificates, and FPC procedures
- AVCP system identification tool and DoP content gap checker