Regulation 2024/3110 replaces Regulation 305/2011 and introduces harmonized rules for the marketing of construction products in the EU. Find out how Regulation 2024/3110 affects the obligations of importers and manufacturers, whether CE marking for construction products is required, and much more.
When does Regulation 2024/3110 apply?
- Regulation 2024/3110 generally applies from January 8, 2026, but some provisions (including definitions, some annexes, and selected procedural articles) apply from January 7, 2025.
- Regulation 2024/3110 repeals CPR 305/2011. It is important to note the extensive transitional provisions for harmonized standards, EADs/ETAs, and documents issued under Regulation 305/2011.
Scope: Which products are covered by 2024/3110?
The Regulation covers construction products (including 3D-printed items) intended to be permanently incorporated in buildings or civil engineering works, plus certain key parts (and, by manufacturer’s request, some materials) for such products. A few sectors (e.g., elevators already regulated elsewhere) fall outside this scope.
If a product is designed to become part of a building/structure and stay there, assume it is in scope unless clearly regulated by a separate sector law.
What is a construction product?
According to the regulation, “construction product’ means any formed or formless physical item, including 3D-printed products, or a kit that is placed on the market, including by means of supply to the construction site, for incorporation in a permanent manner into construction works or parts thereof with the exception of items that need first to be integrated into a kit or another construction product prior to being incorporated in a permanent manner into construction works.
‘Permanent’ means intended to remain in the construction work, or in parts thereof, after the completion of the construction or renovation process.
Harmonised EU rules vs. national requirements
A regulation is a legal act that directly applies to the legislation of an EU Member State. National regulations for construction products (e.g., technical requirements, fire regulations) also apply.
If your product is CPR-compliant and CE-marked under a harmonised specification, national authorities (and public buyers/utilities) cannot require different product-side “approval” in the harmonised field. Some of the obligations for the building remain national.
2024/3110 and 305/2011 differences
One declaration instead of two: DoP&C
Under 2024/3110 you prepare a Declaration of Performance & Conformity (DoP&C) — conceptually merging the old DoP with a conformity statement. It documents the product’s essential characteristics and compliance against the harmonised specification (harmonised standard or EAD/ETA), including environmental information phased in over time.
CE marking and CPR
CE continues to be the main marking that attests declared performance and conformity of construction products within the CPR scope.
Digital Product Passport (DPP) for construction products
The new CPR is part of the EU’s move to digital transparency. Construction products will carry a Digital Product Passport, providing structured access to performance, conformity, and sustainability data (interoperable formats, role-based access, durable availability).
Manufacturer obligations
As a manufacturer, you must:
- Identify the right harmonised specification (hEN or EAD/ETA)
- Prepare and maintain a technical file
- Produce the DoP&C and link every product type to it using a unique product-type identifier
- Apply CE marking correctly
- Prepare a digital product passport
Bear in mind that if you rebrand a product, modify it in a way that could affect performance or compliance, or change its intended use, you assume the role of a manufacturer, not importer.
Importer obligations
An importer must, before placing on the market:
- verify that the product bears CE,
- a DoP&C and DPP are accessible (where applicable),
- ensure that storage/transport won’t compromise compliance.
Transitional arrangements from CPR 2011
- Notified Bodies and TABs designated under 305/2011 are deemed designated under 2024/3110 but require reassessment under the new framework.
- Harmonized standards published under 305/2011 will be considered “harmonized standards for performance” for the purposes of the new CPR until they are replaced. ETAs/EADs remain in circulation with expiry/transfer rules (e.g., EADs not published by January 8, 2026, become ETA applications under 2024/3110).
Construction products in the EU: What does 2023/3110 change?
Here are the most important changes introduced by Regulation 2023/3110 compared to Regulation 305/2011:
- Merged declarations, declaration of performance and conformity instead of a single document
- Introduction of elements such as a digital product passport (DPP) and unique identifiers
- Emphasis on the CE marking
- Strengthened harmonized zone and transparency of national rules (registration in the Single Digital Gateway)
- Extensive transitional provisions for hENs/EADs/ETAs and notified bodies (deadlines until 2030).
Regulation 2024/3110 on Construction Products
The new CPR 2024/3110 introduces a refreshed model for the conformity of construction products: a combined DoP&C declaration, CE as the most important conformity mark, and a digital passport system. However, it’s important to remember that products must comply with the national regulations in force in the Member State where they will be approved.
If you’re planning to import or manufacture a construction product in the European Union but aren’t sure how to navigate the requirements, we are here to help you!