CE Marking FAQ

We answer the 15 most frequently asked questions about CE Marking

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CE Marking is the attestation by which the manufacturer declares that a construction product, when it falls within the scope of a harmonised technical specification or a European Technical Assessment (ETA), complies with the applicable European regulatory framework and with the declared performances of the product itself.

In the construction products sector, CE Marking allows the placing on the market within the European Economic Area and is based on the technical documentation required by the CPR, on the manufacturer’s declaration, and on compliance with the applicable assessment and verification system.

With the new CPR (EU) 2024/3110, this framework is maintained but strengthened in terms of traceability, digitalisation and, progressively, environmental information.

CE Marking allows a construction product to be placed on the market of the European Economic Area according to common harmonised rules.

It is not a quality mark nor a voluntary mark of excellence: it indicates that the product is accompanied by the documentation required by the CPR system and that its performances have been assessed and declared according to the applicable technical specification.

Under the new CPR 2024/3110, the framework is expanded, as product information is progressively intended to include, depending on the applicable technical specifications, aspects of sustainability, digitalisation and traceability.
The basic requirements for construction works are now eight, including also the sustainable use of natural resources.

The party responsible for CE Marking is the manufacturer, i.e. the entity that places the product on the market under its own name or trademark and assumes responsibility for the conformity of the product with the declared performances and the applicable CPR obligations.

If an importer or distributor markets the product under their own name or trademark, or modifies it in such a way that its conformity may be affected, they assume the obligations of the manufacturer.

The Declaration of Performance (DoP) is the document by which the manufacturer declares the performances of the construction product in relation to the essential characteristics defined by the applicable technical specification.

Within the framework of CPR 305/2011, the DoP has been the central document accompanying CE Marking. However, the new CPR (EU) 2024/3110 introduces the concept of the Declaration of Performance and Conformity (DoPC), intended to integrate in a single document both the declaration of performance and compliance with the applicable product requirements.

The practical transition from DoP to DoPC will not occur uniformly and simultaneously for all products but will follow the progressive implementation of the new Regulation.

Do you have doubts about how to adapt your documentation to the new CPR 2024/3110? Our CPR team can support you in drafting the DoPC. Contact us: cpr@certimac.it or fill in the form at the bottom of the page.

A harmonised standard is a European technical standard developed by European standardisation bodies under a mandate from the European Commission, and whose references are published in the Official Journal of the European Union.
In the construction products sector, publication in the OJEU allows such a standard to be used as a basis for performance assessment and for CE Marking of the product, where applicable.

Under the new CPR 2024/3110, the role of harmonised technical specifications remains central, but the system progressively evolves and coexists, during the transitional phase, with the previous CPR 305/2011 framework and with the ETA/EAD route for products not covered by a harmonised standard.

CE Marking must be affixed visibly, legibly and indelibly on the construction product.

If this is not possible or not justified due to the nature of the product, it may be affixed to a label, the packaging or accompanying documents, in accordance with the applicable provisions.

The new CPR also strengthens the link between the physical product, documentation and the digital information associated with the product.

A construction product is subject to CE Marking when it falls within the scope of an applicable harmonised technical specification, or when the manufacturer chooses to follow the European Technical Assessment (ETA) route for a product not covered by a harmonised standard.

To verify the obligation, it is therefore necessary to check whether a relevant harmonised standard has been published in the OJEU or, alternatively, whether the product can be assessed via EAD/ETA.

Under the new CPR 2024/3110, this logic remains valid, but the transition to the new regime occurs progressively depending on the new harmonised technical specifications.

Not sure whether your product is subject to CE Marking or which regulatory regime applies? Contact the CPR Technical Director at cpr@certimac.it or fill in the form at the bottom of the page.

Yes, there are specific cases where a construction product may not be subject to CE Marking, for example when it does not fall within the scope of a harmonised technical specification and is not placed on the market via the ETA route.

Within the CPR framework, there are also certain derogations and simplifications for specific situations, such as products manufactured on request, for a specific work, or in non-serial contexts.

However, these exceptions must be carefully assessed on a case-by-case basis, as they do not apply automatically or generally.

If a construction product is not covered by a harmonised standard, the manufacturer may consider the European Technical Assessment (ETA) route, based on a European Assessment Document (EAD), provided that this route is relevant for the product.

The ETA provides a technical basis to declare product performances and, where applicable, proceed with CE Marking. Under the new CPR 2024/3110, the ETA/EAD route remains relevant, also within the transitional framework between the old and new regimes.

Certimac can support you in assessing whether the ETA/EAD route applies to your product and how to proceed. Contact our CPR Team at cpr@certimac.it or fill in the form at the bottom of the page.

The declaration must be made available when the product subject to the CPR framework is placed on the market, according to the modalities provided by the applicable legislation.

Under the traditional CPR system, the DoP accompanies the product or is made available in paper or electronic form.

Under the new CPR 2024/3110, the documentation framework evolves towards the DoPC and greater integration with digital tools, but the transition will be gradual and dependent on the implementation of new technical specifications and European implementing acts.

The declaration may be provided in paper form or, where permitted, in electronic format or through digital availability, provided that it remains clearly linked to the relevant product and accessible to the intended recipients.

Under the new CPR 2024/3110, the importance of digital documentation and machine readability increases, in line with the evolution towards tools such as the DoPC and, in perspective, the Digital Product Passport.

Annex ZA is the part of the harmonised standard that links the technical content of the standard to the obligations under the European CE Marking system.

It normally identifies the essential characteristics to be declared, the relevant assessment methods, and the applicable system of assessment and verification of constancy of performance.

For manufacturers, Annex ZA remains a key technical-operational reference to correctly apply the harmonised standard to their product.

Harmonised standards issued under Regulation (EU) 305/2011 use the designation AVCP (Assessment and Verification of Constancy of Performance). The new CPR 2024/3110 updates this terminology to AVS (Assessment and Verification Systems), which will progressively come into use with the publication of new harmonised standards under the new regime.

Beyond terminology, the principle remains unchanged: the system defines how the declared performances of a construction product must be assessed and verified, distinguishing between the tasks of the manufacturer and, where applicable, those of the Notified Body, with the objective of ensuring reliability, consistency and constancy over time.

The CPR 2024/3110 also introduces a new assessment system specifically for environmental sustainability: system 3+, which complements the existing AVCP systems (4, 3, 2+, 1, 1+) and, under the new regime, will be referred to as AVS 3+.

Do you want to understand which AVCP system applies to your product and what it entails? Our CPR team can support you. Contact us at cpr@certimac.it or fill in the form at the bottom of the page.

The initial Type Testing (ITT) and, more generally, Product Type Determination (PTD) are the technical activities through which the manufacturer defines and documents the performances of the construction product with respect to the applicable technical specification.


Depending on the case, this determination may be based on tests, calculations, tabulated values or other technical documentation provided for under the CPR framework.
Where required by the applicable AVCP system - or AVS, for products covered by harmonised standards issued under the new CPR 2024/3110 - a Notified Body is also involved in these activities.

This represents the initial step to reliably establish product performances and properly prepare the documentation for CE Marking.

Factory Production Control (FPC) consists of the set of internal procedures, verifications and periodic controls under the responsibility of the manufacturer, supported by a Notified Body where required by the applicable AVCP system - or AVS, for products covered by harmonised standards under CPR 2024/3110 - to ensure that the product placed on the market maintains its declared performances over time.

Its content and intensity depend on the applicable technical specification and the AVCP/AVS system foreseen for the product.
FPC is therefore an essential tool to ensure continuity, traceability and reliability of production for CE Marking purposes.

Ask our expert
Eng. Mattia Morganti
CE Marking - CPR Expert

Notified Body

Certimac supports manufacturers in fulfilling the requirements for the conformity of construction products for the purpose of obtaining CE Marking.

find out more

Iter Marcatura CE

Percorso Marcatura CE

L’iter della Marcatura CE per i materiali e i prodotti da costruzione

Do you have further questions on CE Marking or CPR 2024/3110?

Each product has its own specific regulatory pathway. For cases requiring a detailed assessment, our CPR Team is available to provide precise and up-to-date technical guidance.

Contact our experts by filling in the form at the bottom of the page, or:
email: cpr@certimac.it 
phone: +39 0546 678518

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