# Declaration of Performance CPR Guide: Everything Manufacturers and Importers Need to Know
The Declaration of Performance (DoP) sits at the heart of EU construction product regulation. If you manufacture, import, or place construction products on the EU market, you cannot legally do so without one — yet the DoP remains one of the most misunderstood documents in the compliance landscape. Errors, omissions, and outdated formats cost companies time, money, and market access every year.
This guide walks you through every aspect of the Declaration of Performance under the Construction Products Regulation (EU) No 305/2011 (CPR): what it must contain, how it connects to CE marking, which harmonised standards and European Technical Assessments trigger the obligation, and how to avoid the compliance pitfalls that trip up even experienced manufacturers. Whether you are drafting your first DoP or auditing an existing document library for accuracy, you will find the practical detail you need here.
What Is a Declaration of Performance and Why Does It Exist?
The Declaration of Performance is a formal document in which a manufacturer takes legal responsibility for stating that a construction product meets declared performance levels for its essential characteristics, as assessed against a harmonised technical specification. The legal basis is Article 4 of Regulation (EU) No 305/2011 — the CPR — which replaced the Construction Products Directive (89/106/EEC) and has applied across all EU member states since 1 July 2013.
Before the CPR, the construction products market was fragmented. Manufacturers might carry out different tests in different countries and produce different documentation for each jurisdiction. The DoP, paired with CE marking, was designed to create a single, trusted technical language across the EU. When a contractor in Poland buys structural steel from a manufacturer in Portugal, the DoP is the document that tells them exactly what performance has been declared and how it was assessed — without needing to understand Portuguese regulatory practice.
Critically, a DoP does not claim that a product is fit for a specific application. It declares the performance of essential characteristics. Whether that performance level is adequate for a particular use in a particular building is governed by national building regulations in each member state. This distinction matters enormously for compliance managers who sometimes conflate CE marking with product approval.
The DoP also has implications beyond the EU. The UK’s Construction Products Regulation, which applied after the Brexit transition period, introduced the UKCA marking system and its own UK Declaration of Performance, but products placed on the EU market under the EU CPR still require an EU-format DoP in all 27 member states.
[INTERNAL LINK: CPR basics and CE marking overview]
When Is a Declaration of Performance Mandatory?
A DoP is mandatory whenever a construction product is covered by a harmonised standard (hEN) or a European Technical Assessment (ETA) and is placed on the EU market. The obligation falls on the manufacturer. This applies regardless of company size, country of establishment, or whether the product is sold directly to end users or through distributors.
Several scenarios require particular attention.
Harmonised standards are standards developed by CEN (the European Committee for Standardisation) under a mandate from the European Commission. Once the coexistence period ends and the standard is the sole applicable harmonised specification, manufacturers of products within its scope must issue a DoP. Examples include EN 13242 for aggregates, EN 197-1 for cement, EN 10080 for reinforcing steel, and EN 15804 for environmental product declarations in the construction sector (though EN 15804 operates within a different framework).
European Technical Assessments apply to innovative products not covered — or not fully covered — by a harmonised standard. An ETA is issued by a Technical Assessment Body (TAB) designated by a member state and listed in the EOTA (European Organisation for Technical Assessment) database. Once issued, the ETA gives the manufacturer the basis to draw up a DoP and affix the CE mark.
Importers face a particular obligation. If you import a construction product into the EU from a third country and the original manufacturer has not drawn up a DoP, the importer takes on the manufacturer’s obligations — including drawing up the DoP themselves. This is a compliance risk many importers underestimate. Article 13(3) of the CPR makes clear that when an importer places a product on the market under their own name or trademark, they assume full manufacturer responsibility.
Distributors do not normally draw up a DoP, but they may not alter a product in a way that changes its declared performance. If a distributor makes modifications, they may be considered a manufacturer for regulatory purposes.
[INTERNAL LINK: Harmonised standards list for construction products]
What Must a Declaration of Performance Contain?
The mandatory content of a DoP is set out in Article 6 of the CPR and further detailed in Commission Delegated Regulation (EU) No 574/2014, which established the template format that applies from 1 January 2019 (replacing the earlier Annex III format from the CPR itself). Getting the content right is non-negotiable: a DoP missing mandatory elements is invalid.
The following elements are required.
Unique identification code. Every DoP must carry a code that links it unambiguously to the specific product type to which it refers. This is not a serial number for individual units — it identifies the product type as described in the technical documentation.
Product type identification. The product type must be identified by at least the product reference number, batch number, type, or serial number, or any other element allowing identification. Manufacturers often link this to their own internal product codes.
Intended use. The DoP must specify the intended use or uses of the construction product, as foreseen by the manufacturer, in accordance with the applicable harmonised technical specification.
Name, registered trade name or registered trademark, and contact address of the manufacturer. Third-party manufacturers or importers acting as manufacturers must appear here.
System of Assessment and Verification of Constancy of Performance (AVCP). The AVCP system applicable to the product is determined by the relevant harmonised standard or European Commission decision. There are four systems — 1+, 1, 2+, and 4 — ranging from third-party certification with ongoing surveillance (System 1+) to manufacturer self-declaration (System 4). The DoP must state which system applies and must be consistent with the technical documentation.
Harmonised standard or ETA reference. The DoP must cite the specific harmonised standard or ETA it is based on, including the year of publication.
Notified body information. Where a notified body has been involved in conformity assessment (required for AVCP Systems 1+, 1, and 2+), the DoP must include the notified body’s name, identification number, and a description of the third-party task performed, along with the certificate or report reference.
Declared performance table. This is the substantive heart of the DoP. For each essential characteristic identified in the harmonised standard or ETA, the manufacturer must declare a performance level, class, or threshold — or state “No Performance Determined” (NPD) if the characteristic is not relevant to the intended use in any foreseeable market. Abuse of NPD declarations is a major compliance risk; regulators increasingly scrutinise blanket NPD usage.
Signatory information. The DoP must be signed on behalf of the manufacturer, with name, function, place, and date.
AVCP Systems Explained: What They Mean for Your DoP
The Assessment and Verification of Constancy of Performance system is one of the most practically significant concepts in CPR compliance, yet it is frequently misunderstood. The AVCP system does not determine whether your product needs a DoP — it determines how rigorous the conformity assessment process must be, and therefore who is responsible for what.
System 1+ is the most demanding. It applies to products where failures could have serious consequences — structural elements, fire-stopping products, and safety-critical construction products. A Notified Certification Body (NCCB) certifies the constancy of performance based on an initial type examination, ongoing factory production control surveillance, and audit testing of samples taken from the market or factory. The manufacturer cannot self-certify under System 1+.
System 1 is similar to 1+ but without the audit testing of market samples. It still requires a Notified Certification Body.
System 2+ involves a Notified Inspection Body performing initial inspection of the factory and factory production control, with ongoing surveillance. The manufacturer is responsible for initial type testing, but third-party certification of the factory production control system is required.
System 4 is full manufacturer self-declaration. The manufacturer performs its own initial type testing and factory production control with no mandatory involvement from a notified body. This applies to lower-risk products such as certain aggregates and some masonry products.
The practical implication for your DoP: if your product requires System 1+ and you have drawn up a DoP without involving a Notified Certification Body, your CE marking is invalid. Market surveillance authorities across the EU are increasingly checking this. Germany’s Deutsches Institut für Bautechnik (DIBt), France’s CSTB, and the UK’s OPSS (for UKCA products) have all conducted targeted enforcement campaigns in recent years.
[INTERNAL LINK: AVCP system selection guide for manufacturers]
Common Mistakes in Declarations of Performance
Based on regulatory guidance, notified body experience, and market surveillance findings, the following errors appear repeatedly in DoPs across the EU.
Citing the wrong standard version. Harmonised standards are updated regularly. If your DoP references EN 12390-3:2009 but the current applicable version is EN 12390-3:2019, your document may reference outdated test methods. Manufacturers must track standard revisions and update their DoPs accordingly. The OJEU (Official Journal of the European Union) lists applicable harmonised standards and their reference dates.
Inconsistent product type identification. If the product described in the DoP does not clearly correspond to the product on the market, the entire document is unreliable. This is particularly common when manufacturers update product formulations without revisiting their DoPs.
Blanket NPD declarations. Declaring NPD for a characteristic that is nationally regulated in a target market — even if not strictly required by the harmonised standard — can prevent contractors from using the product, because national technical rules may demand declared values. A well-constructed DoP anticipates the markets where the product will be sold.
Missing or incorrect notified body information. If your AVCP system requires notified body involvement and the certificate number is wrong, expired, or refers to a different product scope, your DoP is non-compliant. Notified bodies are listed in the NANDO (New Approach Notified and Designated Organisations) database, which is publicly accessible.
Failure to update DoPs when standards change. A transition period exists when a revised harmonised standard is published in the OJEU. Once the transition period ends, DoPs based on the superseded standard are no longer valid for CE marking purposes.
Translation errors. DoPs must be available in the official language(s) of the member states where the product is placed on the market. Machine translation without expert review has introduced compliance-critical errors into numerous DoPs across the EU.
Incorrect language on the CE marking. The CE marking affixed to the product or its packaging must reference the DoP, including its unique identification code. Disconnected CE marks — with no traceable DoP — are a major red flag for market surveillance authorities.
How to Draw Up a Declaration of Performance: Step-by-Step
Producing a compliant DoP follows a logical sequence. This framework applies to most construction products covered by a harmonised standard.
Step 1 — Determine applicability. Identify whether your product falls within the scope of a harmonised standard. Check the OJEU list of harmonised standards under the CPR. If no harmonised standard fully covers your product, assess whether an ETA via EOTA is the appropriate route.
Step 2 — Identify essential characteristics. Review the harmonised standard’s ZA annex (the annex that links the standard to the CPR and lists mandatory essential characteristics). Determine which characteristics are relevant to your intended use and target markets.
Step 3 — Determine the AVCP system. The AVCP system is stated in the ZA annex. Engage the appropriate notified body if required.
Step 4 — Conduct or commission initial type testing. For most products, this means testing by a notified testing laboratory according to the relevant test standards. Document the test results in a test report that forms part of your technical file.
Step 5 — Establish factory production control. FPC is a documented system of internal quality controls ensuring that production remains consistent with the tested product type. It is required under all AVCP systems. Many manufacturers integrate FPC into an ISO 9001 quality management system.
Step 6 — Draft the DoP using the mandatory template. Use the format from Commission Delegated Regulation (EU) No 574/2014. Complete every mandatory field. Build the performance table with declared values for each relevant essential characteristic.
Step 7 — Obtain the required certificate or report from the notified body. For Systems 1+, 1, and 2+, the notified body issues a certificate of constancy of performance or a factory production control certificate. Include the reference in your DoP.
Step 8 — Maintain the DoP and keep it available. The DoP must be made available to the market — electronically is acceptable under Article 7(3) of the CPR, provided it is freely accessible. You must retain the technical documentation for 10 years after the last product is placed on the market.
[INTERNAL LINK: Technical file requirements under CPR]
Making DoPs Accessible: Obligations Under Article 7
Article 7 of the CPR specifies how the Declaration of Performance must be provided to users. This is an area where practice has evolved significantly since 2013, and where digital compliance tools have become increasingly important.
The DoP must accompany the product — but not necessarily as a physical paper document. Article 7(2) allows the DoP to be provided on a website, provided that the product is supplied with instructions on how to access the document. The website must be kept up to date, and the DoP must remain accessible for as long as the product is on the market and for 10 years afterward.
When products are supplied to consumers (as opposed to professional users), the DoP must be provided in paper form on request, at no charge.
Where multiple identical products are supplied in a single consignment, a single DoP may accompany the batch — but each product must be traceable back to that document.
For manufacturers supplying products across multiple EU member states, the DoP must be available in the official language(s) required by those states. Article 7(4) allows member states to require translations, and many do. Compliance managers maintaining DoP libraries should ensure language versions are kept in sync with the master document — an updated performance value in the German version that is not reflected in the French or Spanish version creates legal exposure.
Digital DoP management systems — including structured document repositories linked to product codes — are increasingly used by larger manufacturers. These systems also support audit trails, which are valuable during market surveillance investigations.
FAQ: Declaration of Performance Under the CPR
Q: Can I use a single DoP for multiple product variants?
Yes, provided the variants form part of the same product type as described in the technical documentation, and the declared performance values in the DoP table accurately reflect all variants. If different variants have meaningfully different performance levels for the same characteristic, they should have separate DoPs, or the document must clearly differentiate variants and their respective declared values. Using a single overly broad DoP to cover products with varying performance is a common compliance risk.
Q: How long must I keep a Declaration of Performance on file?
Article 11(2) of the CPR requires manufacturers to keep the DoP and technical documentation for 10 years after the last product covered by the DoP has been placed on the market. For products with long production runs, this obligation may extend significantly beyond the date you stop making a particular model.
Q: Do I need a new DoP when a harmonised standard is revised?
Yes, once the coexistence period for the revised standard ends and the new standard becomes the sole applicable harmonised specification, your DoP must be updated to reference the new standard. Test reports conducted under the old standard may or may not remain valid — this depends on whether the test methods have changed materially. Your notified body can advise. Failure to update constitutes a non-compliance that market surveillance authorities can act on.
Q: What happens if my product is found to have a non-compliant DoP during a market surveillance check?
National market surveillance authorities have the power to require corrective action, including withdrawal of the product from the market, correction and reissue of the DoP, and — in serious or repeated cases — referral to the European Commission under the safeguard clause procedure. Penalties vary by member state; Germany, France, and the Netherlands have all issued significant fines and withdrawal orders for CPR non-compliance. A non-compliant DoP can also expose distributors and importers to liability.
Q: Is a Declaration of Performance the same as a Declaration of Conformity?
No. These are different documents with different legal bases. A Declaration of Conformity (DoC) is used under the New Legislative Framework (NLF) directives and regulations — the Machinery Directive, the Low Voltage Directive, the EMC Directive, and so on. A Declaration of Performance is specific to the CPR
