CPR Explained: What the EU's Construction Products Regulation Actually Requires

CPR is the regulation that decides whether a construction product can legally carry a CE mark, and the version most of the industry is now working under, Regulation (EU) 2024/3110, changed more than a document title. It rewrote what has to be proven, who can self-certify, and how a product's data is supposed to travel with it. If you read our companion piece on ESPR, this is the other half of the picture: ESPR sets the general sustainability rules, CPR is the construction specific regulation that puts them into practice for building products.

What is the CPR, and how is it different from ESPR?

The Construction Products Regulation sets the rules for placing a construction product on the EU market: what has to be tested, who has to test it, and what a manufacturer is allowed to claim about it. The revised version, Regulation (EU) 2024/3110, replaces the previous Regulation (EU) No 305/2011 and modernises the framework for the green and digital transition, without changing its basic job. CPR is construction specific. It does not set general environmental sustainability policy for every product category across the EU, that is what ESPR does. CPR is where those general rules get translated into construction specific obligations: testing, CE marking, and the Declaration of Performance and Conformity.

Practically, this also creates a genuine single market benefit. Where a harmonised standard is cited, one EU test is meant to be enough, so a manufacturer does not need to repeat testing separately in every member state where the product is sold.

From DoP to DoPC: what actually changed

Under the old regulation, manufacturers issued a Declaration of Performance, a document stating a product's performance levels against relevant characteristics. The revised CPR replaces this with a Declaration of Performance and Conformity, DoPC. The difference is not cosmetic: a DoPC adds an explicit statement that the product complies with all applicable EU requirements, not only its declared performance levels, and it must be issued in a machine readable format so it can feed directly into the Digital Product Passport system rather than sitting in a PDF nobody indexes.

The five AVCP systems, from strict to self-declared

AVCP stands for Assessment and Verification of Constancy of Performance, the framework that decides how strictly a product's claimed performance has to be checked, and by whom. CPR keeps five systems, unchanged in their basic logic from the previous regulation:

• System 1+: the strictest tier. A notified body carries out initial type testing, inspects the factory, and performs ongoing surveillance and audit testing.
• System 1: the same as 1+, minus the audit testing.
• System 2+: a notified body certifies the factory's production controls, while the manufacturer handles initial type testing itself.
• System 3: a notified body is involved only for initial type testing. Everything else is the manufacturer's responsibility.
• System 4: full manufacturer self-declaration. No notified body is involved at any stage.

Which system applies depends on the product and the characteristic being assessed, not on the manufacturer's preference. A product can sit under different AVCP systems for different characteristics at once.

CE marking and the Digital Product Passport

The CE mark itself has never listed a product's actual performance values, it signals that a DoPC exists and that the right assessment procedure was followed. Under the revised CPR, CE marking gains a new companion: a data carrier, typically a QR code, linking the physical product to its digital passport. That is the practical link between CPR and the Digital Product Passport concept introduced at the general level by ESPR: CPR is the regulation that actually requires construction products to carry one, including mandatory Global Warming Potential declarations for selected products from 8 January 2026, a separate, product level requirement from the building level whole life carbon disclosure that comes from the EPBD. We cover the manufacturer side of this in our Digital Product Passport guide.

Sustainability as a basic requirement

One of the more structural changes in the revised CPR is that sustainability and environmental performance now sit among the basic requirements a construction product has to satisfy, alongside long standing ones like mechanical resistance and fire safety, rather than being treated as a separate, optional consideration. In practice, that means environmental data is being phased in as something to prove, not just something to disclose voluntarily.

The CPR timeline: old and new side by side

The old and new regulations do not switch over on a single date. They run in parallel for years, which is exactly why so many people mix up which rules apply when.

Frequently asked questions