With the entry into force of the new Construction Products Regulation (CPR) 2024/3110, the traditional Declaration of Performance (DoP) provided for by CPR 305/2011 is replaced by the Declaration of Performance and Conformity (DoPC).

The DoP, as defined by CPR 305/2011, certified exclusively the performance of the product with respect to the essential characteristics established for the construction work.

With the new regulation, the DoPC evolves and expands this role: it not only certifies the performance of the product with respect to the essential characteristics (as defined in Annex I), but also declares the product’s conformity with the applicable environmental, functional, and safety requirements, as defined in Annex III of the Regulation.

In practice, the manufacturer no longer simply declares performance values but must demonstrate compliance with a broader and more complex set of requirements.

 

It is advisable to be prepared while remaining aware that the old DoPs will probably remain valid for several more years, since the implementation of the new Regulation and all the innovations it contains (including the DoPC) depends on the publication of the new harmonised standards in the Official Journal of the European Union. 

Other new features of the DoPC

LCA environmental indicators

The new CPR 3110/2024 introduces the obligation to declare environmental sustainability performance over the product’s life cycle, including LCA indicators (such as climate impact, resource consumption, pollutant emissions). These indicators will be phased in gradually starting in 2026, also covering the environmental analysis of packaging.

Format and availability

The DoPC will be required to be in electronic (non-editable) format starting from 8 January 2026. It may be made available on a monitored website, ensuring continuous accessibility for customers and authorities.

CE marking and other marks

The new CPR clarifies that the CE marking remains the only authorised conformity symbol for construction products and prohibits the inclusion of other marks or performance symbols in the declaration to avoid market confusion.

Traceability and archiving

CPR 3110/2024 introduces the Digital Product Passport (Article 75): each product type will be assigned a unique identification code that will accompany it throughout its entire life cycle. The digital passport will include the DoPC and all technical information, safety data, and user instructions. The data will be stored online for at least 10 years after the last placing on the market, ensuring long-term traceability.

DoPC: checklist and sample template

By way of example (and not exhaustively), we have prepared a checklist and a sample of what the DoPC required by CPR 3110/2024 should contain.

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