How to Write a Declaration of Performance: A Complete Guide for EU Manufacturers
If you place a construction product on the EU market covered by a harmonised European standard or a European Technical Assessment, you are legally required to issue a Declaration of Performance (DoP). This document is not a formality — it is a legally binding statement for which you, as the manufacturer, bear full responsibility. Get it wrong and you risk product recalls, market withdrawal, infringement proceedings, and damaged relationships with distributors and clients.
This guide walks through every element of a compliant DoP in plain, actionable terms. Whether you are drafting your first declaration or auditing an existing library of DoPs for accuracy, you will find here the structure, content requirements, legal references, and practical pitfalls that matter most.
What Is a Declaration of Performance and Why Does It Matter?
A Declaration of Performance is the document a manufacturer draws up to declare the performance of a construction product in relation to its essential characteristics, as required under Regulation (EU) No 305/2011 — commonly known as the Construction Products Regulation, or CPR. The CPR entered into application on 1 July 2013 and replaced the old CE marking system that operated under Directive 89/106/EEC.
The DoP serves a specific legal and commercial function. It translates technical test results into standardised declarations that enable buyers, specifiers, architects, and public authorities to compare products on a common basis and verify that a product meets the requirements of the works in which it will be incorporated.
Without a valid DoP, you cannot affix CE marking to your product. Without CE marking, you cannot legally sell that product in the EU market, in Northern Ireland under the Windsor Framework, or in a growing number of third countries that recognise or require CE-marked construction products.
The DoP also defines the scope of your liability. You are declaring — under your own responsibility — what your product does and does not achieve. If a performance level is declared incorrectly, you may be liable for consequential damage resulting from the product’s incorporation into a structure. This is not a theoretical risk; national market surveillance authorities across the EU actively inspect DoPs and have the power to require corrective action or remove products from the market.
[INTERNAL LINK: CPR Regulation overview and CE marking obligations]
Understanding the Legal Framework Before You Begin
Before drafting a single line, you need to identify precisely which legal instruments govern your product. The DoP structure and content are not left to manufacturer discretion — they are defined in law.
Regulation (EU) No 305/2011 (CPR) is the primary legal basis. Article 4 establishes the obligation to draw up a DoP. Article 6 specifies the mandatory content. Annex III provides the template format that all DoPs must follow. Manufacturers are not permitted to use a different layout or omit Annex III elements.
Commission Delegated Regulation (EU) No 574/2014 amended Annex III to simplify the template and, crucially, to allow DoPs to be made available on a website rather than supplied as a paper document with each product consignment, provided the product is not intended for individual consumers. Where a product is supplied to consumers, a paper or email copy must be provided on request at no cost.
Harmonised European Standards (hENs) define the essential characteristics relevant to each product family, the test methods to be used, the assessment and verification of constancy of performance (AVCP) system applicable, and the format in which performance shall be expressed. Your starting point is always identifying the correct hEN for your product — and confirming that it has been published in the Official Journal of the EU with its date of cessation of the coexistence period.
Where no hEN covers your product, or where you seek to declare performance for characteristics beyond the hEN’s scope, you may obtain a European Technical Assessment (ETA) from an approved Technical Assessment Body (TAB). The ETA then serves as the reference document for your DoP in place of — or in addition to — a harmonised standard.
[INTERNAL LINK: Finding the correct harmonised standard for your product]
The Nine Mandatory Elements of a DoP
Article 6 of the CPR and Annex III specify exactly what a DoP must contain. Every element is mandatory. A DoP missing any of these is non-compliant.
1. Unique identification code of the product-type. This is not a serial number or batch code. It is a code that identifies the product type for which the DoP has been drawn up. Each distinct product type requiring a separate set of performance declarations needs its own unique code and its own DoP.
2. Intended use or uses of the construction product. State the intended use as defined in the applicable harmonised standard or ETA. Do not write a commercial product description here — copy the intended use wording from the technical specification.
3. Name, registered trade name, or registered trade mark and contact address of the manufacturer. Use your full legal entity name and your registered office address, not a trading address or warehouse address.
4. Name and contact address of the authorised representative where applicable. If a non-EU manufacturer has appointed an authorised representative within the EU to fulfil CPR obligations, that representative’s details go here.
5. System or systems of assessment and verification of constancy of performance (AVCP). This is set by the harmonised standard. It ranges from System 1+ (most stringent — a notified body certifies the product and performs ongoing surveillance) down to System 4 (the manufacturer conducts its own factory production control and testing without third-party involvement). Stating the wrong AVCP system is a serious error.
6. Reference to the harmonised technical specification used. State the full standard number, including the edition year and any applicable amendments. If an ETA is used, state the ETA number and the TAB that issued it.
7. Notified body details and certificate reference where applicable. For AVCP Systems 1, 1+, 2, and 2+, a notified body is involved. State the notified body’s name, number as published in the NANDO database, and the certificate or report reference. For Systems 3 and 4, this section is not applicable but should still appear, marked accordingly.
8. Declared performance table. This is the substantive heart of the document. For every essential characteristic listed in the harmonised standard or ETA, you must either declare a performance level or class, or state “No Performance Determined” (NPD) if you choose not to declare performance for that characteristic.
9. Signature, name and function of the person empowered to sign on behalf of the manufacturer. The DoP must be signed by an authorised person. Include the place and date of signing.
[INTERNAL LINK: AVCP systems explained — which applies to your product?]
How to Complete the Performance Declaration Table
The performance table is where most errors occur. Here is how to approach it systematically.
Start by obtaining the current version of the harmonised standard that covers your product. Work through every essential characteristic listed in the relevant clauses. For each characteristic, you have three options: declare a specific value or class based on testing or calculation, use a threshold declaration (e.g., “≥ X”), or state NPD.
NPD is a legitimate choice, but use it carefully. You cannot affix CE marking for a characteristic you declare NPD, and if the characteristic is mandatorily required by the construction works regulation in the member state where the product will be used, you may effectively be barring your product from that market. NPD should be used where a characteristic genuinely does not apply to your product’s intended use, or where the market does not require its declaration.
Performance levels and classes must match the classification system in the standard. Reaction to fire, for instance, uses the Euroclasses system (A1, A2, B, C, D, E, F) along with smoke production (s1, s2, s3) and flaming droplets (d0, d1, d2) classifications. Do not express fire performance in national classification terms in the DoP — use the European classifications only.
Test reports must correspond to the product as currently manufactured. If you change a raw material, a production process parameter, or a product dimension beyond the tolerances in the standard, previous test results may no longer be valid. Establishing robust change management procedures that trigger a review of test validity is essential to keeping your DoPs accurate over time.
When a standard permits performance to be declared by calculation rather than testing — structural products assessed by Eurocodes, for example — the declaration must reference the calculation methodology used and any software or design tools applied.
Factory Production Control and Notified Body Requirements
The AVCP system applicable to your product determines what must happen before you can draw up a valid DoP, and what ongoing obligations follow.
Under System 1+, a notified product certification body certifies the product, performs initial inspection of the factory and factory production control (FPC), and conducts continuous surveillance. The certificate must remain valid for the DoP to be valid.
Under System 1, the notified certification body certifies the product but audit testing is conducted by the same body on samples from the market, rather than factory surveillance.
Under System 2+, a notified body audits and certifies your FPC system but does not certify the product itself.
Under System 3, a notified testing laboratory performs the initial type testing. You declare performance based on those results. No ongoing notified body involvement is required, but the tests must be repeatable and the FPC must demonstrate that production remains consistent with the tested product.
Under System 4, you perform all assessment yourself, including initial type testing and FPC. This system applies to a limited range of lower-risk products.
Your FPC documentation — production records, calibration logs, incoming material checks, non-conforming product records — is what gives substance to your DoP. Market surveillance authorities will request this documentation when they audit your CE marking compliance.
[INTERNAL LINK: Setting up factory production control for CPR compliance]
Common Mistakes That Invalidate a Declaration of Performance
Manufacturers across the EU repeatedly make the same errors. Knowing them in advance protects you.
Using an outdated standard reference. Harmonised standards are revised. If a new edition supersedes the edition you referenced, and the coexistence period has ended, your DoP must reference the current edition. Continuing to use an old edition reference renders the DoP non-compliant even if the product itself is unchanged.
Incorrect or missing notified body certificate reference. The certificate number must appear exactly as issued. A common error is listing the notified body number without the specific certificate reference, which means the DoP cannot be cross-checked against NANDO.
Product-type code reused across different products. Each product type must have its own unique code. Using the same code for product variants with materially different performance levels is not permitted.
Mismatch between DoP and CE marking label. The essential characteristics and performance levels on the CE marking label affixed to the product or its packaging must be consistent with the DoP. Contradictions between the two documents are a red flag for market surveillance authorities.
Failure to update after product modification. A change in raw material supplier, formulation, or production parameter that affects performance requires re-evaluation and potentially a new test, before the DoP is revised and re-issued.
Incorrect declared intended use. Using marketing language or a commercial description instead of the standard’s defined intended use prevents proper technical comparison and can create liability exposure.
Making Your DoP Available: Language, Format, and Accessibility Requirements
Article 7 of the CPR sets out how the DoP must be supplied. The language requirement is particularly important for exporters: the DoP must be available in the language or languages required by the member state where the product is made available on the market. If you sell across multiple member states, you need translations.
Since Commission Delegated Regulation (EU) No 574/2014, manufacturers supplying products to professional customers may make the DoP available on a dedicated website. If you use this route:
The URL must be stable and the DoP must remain accessible for the lifetime of the products to which it relates. If you restructure your website and the DoP links break, you are in breach even if the documents still exist somewhere on your server. Implement a document management system that maintains stable URLs and version-controlled DoP archives.
Where products are supplied to end consumers, a paper copy must be provided free of charge at the point of sale or, where that is not practical, made available online with clear in-store or packaging signage directing the consumer to it.
The DoP should be stored in a format that is clearly identifiable, that records the version history, and that links back to the notified body certificates and test reports on which the declarations are based. PDF format with version control metadata is the industry standard.
Staying Compliant After Issue: Maintenance and Version Control
Drawing up a DoP is not a one-time task. It is the beginning of an ongoing compliance obligation.
Establish a review schedule. At minimum, check each DoP annually against the following: Is the harmonised standard still current? Has your notified body certificate been renewed? Have any raw materials, process parameters, or product configurations changed? Has a new edition of the standard been published and has its coexistence period ended?
When you issue a revised DoP, retain the previous version. Market surveillance authorities may investigate products placed on the market in previous periods, and you need to be able to demonstrate what declaration was in place at the relevant time.
Consider assigning a DoP register to your quality management system. Link each DoP to the corresponding test reports, FPC records, notified body certificates, and product specifications. This makes audits faster, reduces the risk of errors propagating, and creates a clear audit trail that demonstrates diligence.
CPRBase.eu DoP Templates and Compliance Resources
Get Publication-Ready DoP Templates from CPRBase.eu
Drafting a Declaration of Performance from scratch against the Annex III template is time-consuming, and errors in structure or content can lead to market surveillance findings.
CPRBase.eu offers professionally prepared, regulation-aligned DoP template packages designed specifically for EU construction product manufacturers, importers, and compliance managers. Each template package includes:
- Annex III-compliant DoP template in editable format
- Guidance notes for completing each mandatory field
- Performance table structure matched to product category
- Version control and document management checklist
Download the CPRBase.eu DoP Template Pack and issue your first compliant Declaration of Performance with confidence.
Visit CPRBase.eu to access the full range of EU construction product compliance document packages.
Frequently Asked Questions
Do I need a separate Declaration of Performance for every product I manufacture?
You need a separate DoP for every distinct product type. A product type is defined by a consistent set of essential characteristics declared at specific performance levels. If two products share the same construction, materials, and performance across all declared characteristics, they may share a DoP. If any declared performance differs, each product requires its own DoP with its own unique product-type code. Practically, most manufacturers with a range of products will maintain a library of DoPs.
Can I use “No Performance Determined” for all essential characteristics and still affix CE marking?
This is a question that arises often and the answer requires care. Technically, there is no legal prohibition on issuing a DoP that declares NPD for every characteristic — the CPR does not require a minimum number of declared performances. However, a DoP with all NPDs provides no usable information to specifiers or buyers and may be challenged by market surveillance authorities as not fulfilling the purpose of the CPR. More practically, construction works regulations in member states typically require specific performance levels, so an all-NPD DoP would bar your product from regulated applications in most markets.
What happens if a notified body certificate is suspended or withdrawn?
If your notified body suspends or withdraws the certificate on which your DoP is based, the DoP is immediately invalid and you must cease placing that product on the market under CE marking until you obtain a new certificate. This situation can arise if a notified body loses its accreditation, if your FPC audit reveals non-conformances serious enough to justify suspension, or if the product is found not to conform. Maintain close communication with your notified body and respond promptly to any audit findings.
Is a DoP required for products exported outside the EU?
The DoP is an EU regulatory requirement under the CPR. It is not required by EU law for products exported outside the EU. However, many third countries — including several in the Middle East, North Africa, and the Western Balkans — either accept CE marking as evidence of conformity or require it directly. If your export market recognises CE marking, maintaining a valid DoP is necessary to support that claim. Always verify the specific import requirements of your target market.
How long must I keep records supporting a Declaration of Performance?
Article 11 of the CPR requires manufacturers to keep the technical documentation and the DoP for a period of ten years after the last product covered by the DoP has been placed on the market. This includes test reports, FPC records, notified body certificates, and all versions of the DoP itself. Ten years is a minimum; some liability frameworks under national law may impose longer retention periods.
Conclusion
A Declaration of Performance is one of the most consequential compliance documents you will produce as a manufacturer of construction products in the EU. It commits you, legally, to specific performance claims about your product and underpins every CE marking you affix. Treating it as an administrative formality is a serious mistake.
The practical approach is systematic: identify your harmonised standard or ETA, confirm your AVCP system and notified body obligations, complete the Annex III template with accurate and current performance data, establish a document management system that links the DoP to its supporting evidence, and build a review cycle that catches standard revisions, product changes, and certificate renewals before they create compliance gaps.
The manufacturers who manage DoPs well are those who embed them into their quality management system rather than treating them as standalone documents. When the declaration is a living part of your product compliance documentation — reviewed, updated, and stored with clear version control — market surveillance audits become straightforward and your route to market across the EU remains clear.
[INTERNAL LINK: EU construction product compliance checklist for manufacturers]
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Learn how to write a Declaration of Performance for EU construction products — mandatory content, Annex III structure, AVCP systems, and compliance tips. CPR-compliant guidance.
