EU regulation
Construction Products Regulation 305/2011: performance and transition
Overview
Short answer
Parts of Regulation (EU) No 305/2011 continue to apply to products within the transition to the new Construction Products Regulation. Check the harmonised standard or assessment document before choosing the declaration and requirements. The earlier framework has not disappeared for all products at once. Articles 94–95.
Legal status
Partially repealed, transition ongoing
Partially repealed with retained transitional provisions. Checked on 11 October 2026 against the 29 May 2026 consolidation and Articles 94–95 of Regulation 2024/3110.
Part 1
Which products remain under the earlier CPR?
Transitional rules retain specified provisions of 305/2011 for products covered by older harmonised standards or European assessment documents under Article 95. Monitor the validity and withdrawal of standards. The product’s technical route determines the framework, rather than a company’s preference to continue using a familiar template. Article 95(3)–(8).
Part 2
When is a declaration of performance needed?
Where a construction product is covered by a harmonised standard or conforms to a European Technical Assessment issued for it, the manufacturer normally draws up a declaration of performance when placing it on the market. Article 5 contains limited derogations. The declaration needs to address the intended use and correct essential characteristics. Articles 4–6.
Part 3
What CE marking demonstrates
CE marking connects to declared performance and the prescribed assessment procedure. It does not by itself establish suitability for particular construction works. Project design needs to compare the declared characteristics with the requirements of the use. Keep the product’s documentation distinct from the project’s choice of a suitable product. Article 8.
Part 4
Who keeps the evidence together?
The manufacturer is responsible for the declaration and conformity with declared performance. Importers and distributors have their own verification duties. Selling under your own name or modifying a product in a way that affects performance can bring manufacturer responsibilities. Also determine the applicable system for assessment and verification of constancy of performance. Articles 11–15 and 28.
Part 5
Create a traceable product file
Link product identification, intended use, standard or assessment, declaration of performance and marking to the same product version. Add testing evidence and factory production control supporting the declared values. As a practical method, make each performance statement in sales material traceable to evidence. Record why a changed component or manufacturing process does or does not affect performance.
Part 6
Plan the transition product by product
Article 94 repeals most of 305/2011 from 8 January 2026 while retaining specified provisions until 8 January 2040. This does not mean every product can use the earlier framework until 2040. Article 95 governs earlier product-specific transitions. See our separate article on Construction Products Regulation 2024/3110. Articles 94–95.
Checklist
Key takeaways
- Start with intended use and the technical specification.
- The declaration of performance addresses relevant essential characteristics.
- CE marking is not a general approval for every construction project.
- Check the product family’s transition, not only the regulation’s year.
Questions and answers
Frequently asked questions
Is 305/2011 fully repealed?
No. Specified provisions remain for products covered by the transition.
Must all construction products carry CE marking under the earlier CPR?
No. Check the harmonised standard or issued European Technical Assessment and any derogations.
Is the declaration of performance the same as the new declaration?
No. The new CPR uses a declaration of performance and conformity within its framework.
Can we always wait until 2040?
No. The product family’s transition and withdrawal of older specifications may occur earlier.
Further reading
Official sources
How Verca helps
How Verca can support the process
Verca brings together product information, documents and version history, providing structure for declarations and evidence. Responsible people still need to check performance and the applicable assessment procedure. Platform.