In Regulation (EU) 2024/3110, in addition to the established concept of product performance, two new levels are now formalized: product requirements and product information.
Understanding and distinguishing these three levels is essential to grasp the specific obligations for manufacturers and the scope of intervention left to Member States.

 

Product performance: declaring essential characteristics

In the context of CPR 2024/3110, performance represents the level, class or value with which a product exhibits its essential characteristics. These characteristics are directly related to the basic requirements of construction works, including environmental characteristics, which are now explicitly considered in the new regulation.
Product performance:

• can be expressed in values, classes or levels;
• is defined through harmonized technical specifications or ETA (European Technical Assessment);
• is included in the Declaration of Performance and Conformity (DoPC);
• is linked to the basic requirements of the works, including essential environmental characteristics.

⚠️ CPR does not impose minimum performance thresholds at European level. The performance must be declared, not necessarily “approved.” The Regulation defines how to measure and declare, not what level is sufficient.
 

Product requirements: mandatory conditions for market placement

CPR 2024/3110 officially introduces the concept of product requirements, meaning characteristics that a product must have in order to be placed on the market, regardless of its performance levels.

Product requirements:

• are not gradable;
• do not express performance in values or classes;
• follow a binary logic: the product is either compliant or not.

❗ If an applicable requirement is not met, the product cannot be considered compliant, even if its performances are high.
Compliance with these requirements must also be documented in the DoPC.
 

Product information: transparency, traceability and responsible use

The third level defined by the new CPR concerns product information, which does not measure performance and does not attest to compliance.
Product information must be complete, clear, accessible and available also in digital format.
Required product information includes:

• unique identification;
• intended uses and admissible conditions of use;
• durability or estimated useful life;
• main materials;
• instructions for installation, use, maintenance and disassembly;
• safety aspects and end‑of‑life management.

Product information is no longer a secondary element: it becomes an integral part of product compliance and therefore mandatory.

 
The role of member States: regulating use without hindering the market

Thanks to the new regulatory framework, member States cannot intervene on the placing of the product on the market, but may regulate its suitability for use in specific local contexts, using the Product performance and the product information provided by the manufacturer.

Possible actions by Member States include:

• setting minimum performance thresholds for works (not for products);
• establishing conditions of use tied to environmental or functional contexts;
• regulating product use in terms of safety, health, environment or durability;
• imposing installation, maintenance, disassembly and end‑of‑life rules;
• assessing product suitability for specific applications.

ℹ️ Product information does not become an EU requirement in itself, but it is used to regulate national use of products within works.
 

Practical example: an external window

A manufacturer markets a CE‑marked window according to the applicable harmonized standard. In the DoPC it declares:

• Thermal transmittance Uw = 1.3 W/m²K
• Water tightness: class E750
• Air permeability: class 4
• Wind load resistance: class C3
• Acoustic insulation Rw = 38 dB

These values represent the product’s performance.

At the same time, the product must comply with applicable product requirements, for example related to:

• safety,
• health,
• environment,
• mandatory conditions.

Finally, it must provide product information, such as:

• intended use (e.g., residential and tertiary buildings);
• conditions of use (e.g., exposure to driving rain, wind class);
• estimated useful life;
• installation instructions (e.g., subframe, joints, fasteners);
• maintenance procedures;
• foreseeable limits of use.

Now imagine that a member State introduces a national regulation for buildings in a coastal zone subject to high wind and rain. The State cannot require different performance thresholds than those set in the harmonized standard, but it can restrict the use of products that are not suitable for that context, based on the declared performance and provided information.

Outcome: the product remains compliant with the CPR and can be freely marketed, but it may not be suitable for use in that specific context.