Windows and Doors CPR Requirements: A Complete Compliance Guide for EU Manufacturers and Importers
Windows and doors sold in the EU market must comply with the Construction Products Regulation (CPR), Regulation (EU) No 305/2011. For manufacturers, importers, and distributors, this is not optional: placing a CE mark on a window or door without fulfilling the underlying CPR obligations exposes you to market withdrawal, fines, and reputational damage. Yet the requirements are genuinely complex — multiple harmonised standards apply, the declaration of performance must be correctly structured, and the applicable essential characteristics depend heavily on the intended use and end market.
This guide explains every major CPR obligation that applies to windows and doors, from the harmonised standards you need to work with, to factory production control, third-party assessment, the Declaration of Performance, and what changes when you import rather than manufacture. Whether you are preparing for a first CE marking exercise or auditing an existing compliance programme, you will find actionable information here.
What the CPR Actually Requires for Windows and Doors
The Construction Products Regulation establishes a common technical language for construction products across the EU. Its central mechanism is the Declaration of Performance (DoP): the manufacturer declares the performance of their product against a defined set of essential characteristics, using agreed test methods and assessment procedures set out in harmonised standards.
For windows and doors, the relevant essential characteristics include — depending on product type and application — resistance to wind load, watertightness, air permeability, resistance to fire, thermal transmittance (U-value), acoustic performance (sound reduction), dangerous substances, resistance to repeated opening and closing, and, for external doors, impact resistance and resistance to forced entry.
The CPR does not require a product to achieve any particular performance level for most of these characteristics. It requires the manufacturer to declare the performance they have tested for. Some characteristics can be declared as “no performance determined” (NPD) where the characteristic is not relevant to the intended use, though this must be handled carefully — certain end markets or building regulations may require a declared value. The distinction between “NPD” and a tested, declared value is fundamental to your compliance programme.
[INTERNAL LINK: Declaration of Performance guide for construction products]
Harmonised Standards Applicable to Windows and Doors
The harmonised standards are the backbone of CPR compliance for windows and doors. They define which characteristics must be assessed, which test methods apply, and which factory production control requirements the manufacturer must maintain. Using the harmonised standard — and only the published, CE-marking-active version — is what triggers the presumption of conformity and the right to affix the CE mark.
The primary harmonised standards covering windows and doors include:
EN 14351-1 covers windows and external pedestrian doorsets without fire resistance and/or smoke control characteristics. This is the workhorse standard for most residential and commercial aluminium, PVC, timber, and composite windows and external doors. It covers characteristics such as wind resistance, watertightness, air permeability, thermal transmittance, acoustic performance, resistance to repeated opening and closing, resistance to forced entry, and several others.
EN 14351-2 covers internal pedestrian doorsets. It covers different sets of essential characteristics relevant to internal applications, including, where applicable, acoustic performance and dangerous substances.
EN 16034 addresses pedestrian doorsets, industrial, commercial, garage doors, and openable windows with fire resistance and/or smoke control characteristics. This standard works in conjunction with EN 14351-1 or EN 14351-2 — a fire-rated external door must satisfy both.
EN 13241 covers industrial, commercial, garage doors and gates. If your product falls into this category, this is the primary standard.
It is essential to monitor the Official Journal of the European Union for publication of harmonised standards and for any amendments or transitions between standard editions. Working from a superseded version of a standard does not provide valid grounds for CE marking. Your compliance team should also be aware that some standards are published with corrections (corrigenda) that affect test requirements.
[INTERNAL LINK: Harmonised standards database for CPR products]
System of Assessment and Verification of Constancy of Performance
The CPR establishes five Systems of Assessment and Verification of Constancy of Performance (AVCP): Systems 1+, 1, 2+, 3, and 4. The system that applies to your product determines how much third-party involvement is required before you can issue a DoP and affix the CE mark.
For most windows and doors covered by EN 14351-1, the applicable system is System 3 for most characteristics, meaning an accredited Notified Body must conduct initial type testing (ITT). The manufacturer then takes responsibility for ongoing factory production control (FPC). Critically, under System 3, the Notified Body does not audit your factory — it tests your product. This means your FPC documentation is not reviewed by the Notified Body as a condition of the CE marking exercise, but it must still exist and be maintained.
Where fire-resistant characteristics are declared under EN 16034, System 1 applies. Under System 1, a Notified Product Certification Body must issue a certificate of constancy of performance, which involves both initial type testing and ongoing surveillance of your FPC.
Understanding which system applies to which characteristics on your product is important because a single doorset declaring both standard and fire-resistant characteristics will be subject to different AVCP systems for different parts of the declaration. The DoP must correctly reflect the involvement of each Notified Body and the certificate or test report number where applicable.
Factory Production Control: What Manufacturers Must Put in Place
Factory production control (FPC) is the internal quality management system that ensures the product you manufacture consistently matches the product that was tested. For windows and doors, FPC is not a bureaucratic exercise — it is the mechanism that justifies the ongoing validity of your CE mark after the initial type testing is complete.
Under the harmonised standards for windows and doors, FPC requirements typically include a written FPC manual or documented procedures, defined responsibilities for quality-related activities, specification and control of incoming materials and components (including profiles, glazing, hardware, sealants, and gaskets), process controls during manufacture, inspection and testing of finished products, control of non-conforming products, and records demonstrating that these controls are operating.
For manufacturers sourcing components from multiple suppliers — particularly hardware and glazing — the FPC must address how changes in components are evaluated against the tested configuration. This is a common compliance gap. If you switch a handle supplier, a hinge type, or a glass unit specification, you need a documented process for determining whether this change requires new type testing or whether existing test data still applies.
Records must be retained for a defined period — typically ten years for standard construction products, or as specified in the applicable standard. These records demonstrate traceability between the products you place on the market and the tested configurations that underpin your DoP.
[INTERNAL LINK: Factory production control template for window manufacturers]
Drafting a Compliant Declaration of Performance
The Declaration of Performance is the document that legally activates the CE mark. It is not a certificate — it is a declaration by the manufacturer, and the manufacturer takes legal responsibility for its accuracy. A DoP that references the wrong standard, omits a mandatory characteristic, or carries an incorrect Notified Body number is a non-compliant DoP even if the underlying testing was conducted correctly.
A compliant DoP for a window or door must contain, at minimum: a unique identification code for the product type, the intended use, the name and contact address of the manufacturer (and, where applicable, the authorised representative), the reference to the harmonised standard used, the AVCP system, the name and identification number of any Notified Body involved, the declared performance for each essential characteristic (or NPD where permitted), and a reference to the technical documentation used.
Each essential characteristic must be handled correctly. For example, thermal transmittance (U-value) must be declared in W/m²K using the test method or calculation method specified in the standard. Acoustic performance is declared as a weighted sound reduction index in dB. Wind resistance, watertightness, and air permeability are declared as classification values (e.g., Class 3 watertightness, Class 4 wind resistance) following the relevant EN classification standards such as EN 12207, EN 12208, and EN 12210.
The DoP must be made available to customers. It can be provided on paper, as a PDF, or — where agreed — via a website URL. Since 2020, a simplified labelling approach has also been permitted under the CPR for products used by consumers, but the underlying DoP obligations remain unchanged.
Do not confuse the DoP with a test report. A test report from a Notified Body is evidence underpinning the DoP; it is not itself the DoP. Manufacturers sometimes make the error of providing customers with a test report and assuming this fulfils the CPR requirement — it does not.
[INTERNAL LINK: Declaration of Performance template download]
CPR Obligations for Importers and Distributors
Importers and distributors have specific obligations under the CPR that are distinct from those of manufacturers. If you are placing a window or door on the EU market that was manufactured outside the EU, you — as the importer — take on manufacturer-like responsibilities. This is a point that many importers underestimate.
As an importer, you must verify that the manufacturer has carried out the appropriate conformity assessment procedure, that the required technical documentation has been drawn up, that the product bears the CE marking, and that the DoP has been prepared. You must not place the product on the market if you believe or have reason to believe it does not conform.
You must indicate on the product — or on its packaging, accompanying document, or data sheet — your name, registered trade name, or trademark and your contact address. This is a physical labelling requirement, not merely a documentation requirement.
If you make changes to the product that could affect compliance — for example, modifying hardware, replacing glazing units, or repainting — you take on full manufacturer responsibilities for the modified product, which means you must re-assess conformity and issue a new DoP.
Distributors who make a product available on the market without modification have lighter obligations, but must verify that the CE mark and DoP are present, and must not knowingly supply non-compliant products. Market surveillance authorities across the EU — including in Germany (DIBT), France (DGCCRF), and the Netherlands (ILT) — have increased enforcement activity on imported windows and doors in recent years, with a particular focus on thermal performance claims and fire rating declarations.
CE Marking Requirements: What Must Appear on the Product
The CE marking for a window or door does not appear only on a DoP or in accompanying documentation — it must also appear on the product itself or on its labelling. The CE mark must be followed by the identification number of the Notified Body involved in the AVCP process (where applicable), the year of affixing, the name and address of the manufacturer, the product type identifier, the reference to the harmonised standard, and the declared performance for key characteristics.
In practice, CE marking information for windows and doors is often applied via a label on the frame, on the glazing unit, or on packaging. Given the range of custom sizes and configurations typical in fenestration, manufacturers often use a base label format with a reference number that points to a specific DoP, rather than printing all performance data directly on the product.
One area where manufacturers frequently make errors is in ensuring the CE marking information is legible, indelible, and accessible at the point of use. If the CE label is placed on packaging that is discarded on site, or on a location of the frame that is covered during installation, this creates a compliance problem. Your FPC procedures should address exactly where and how the CE marking is applied, and this should be verifiable during production.
Common Compliance Failures and How to Avoid Them
Market surveillance reports from across the EU consistently highlight the same categories of failure for windows and doors. Understanding these patterns lets you direct compliance resources where they matter most.
The most common failure is an incomplete or incorrect DoP — typically one that uses NPD for characteristics where a declared value is required by the relevant market, or one where the Notified Body number is missing or incorrect. A related failure is the use of test data that does not actually support the declared performance: for example, declaring a U-value based on a calculated estimate that is not supported by the method specified in the standard, or claiming classification values from tests conducted on a configuration that differs materially from the production product.
FPC non-conformity is another consistent finding. Many small and medium manufacturers have FPC documentation in place but fail to maintain records of incoming material checks or to formally evaluate the impact of component changes. When a market surveillance authority requests FPC records, gaps in supplier change control or calibration records can undermine an otherwise reasonable compliance programme.
For importers, the most frequent failure is reliance on a DoP prepared by a non-EU manufacturer without verifying its accuracy and without ensuring the importer’s own information appears on the product labelling.
Finally, fire-rated products generate a disproportionate share of serious compliance failures. Declaring fire resistance characteristics requires System 1 assessment, which is rigorous and expensive, and some manufacturers attempt to work around this by using test data that is not supported by a valid certificate of constancy of performance. Market surveillance authorities treat this category of failure seriously because of the direct life-safety implications.
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The CPRBase.eu Windows & Doors CPR Compliance Pack is a professionally prepared PDF resource designed for manufacturers, importers, and compliance managers. It includes a ready-to-use Declaration of Performance template pre-structured for EN 14351-1 and EN 14351-2, an FPC checklist aligned to harmonised standard requirements, a CE marking label format guide, an importer obligations checklist, and a characteristic-by-characteristic reference table covering test methods and classification standards.
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Frequently Asked Questions
Do all windows and doors need CE marking in the EU?
Any window or external door placed on the EU market as a construction product must be CE marked if a harmonised standard exists for it and is active in the Official Journal. For most windows and external doors, EN 14351-1 is the relevant standard and CE marking is mandatory. Internal doors covered by EN 14351-2 are also subject to CE marking requirements. There is no size, volume, or product-type exemption for standard products.
Can I use NPD (No Performance Determined) for thermal transmittance on windows?
You can declare NPD for thermal transmittance under the CPR where the characteristic is genuinely not relevant to the intended use. However, in practice, most building regulations in EU member states — including the German Energieeinsparverordnung successor regulations, French RT2020/RE2020 requirements, and similar national instruments — require a declared U-value for compliance with energy performance rules. Declaring NPD for thermal transmittance on a product intended for typical building applications will generally prevent that product from being used in most EU markets. It is permissible under CPR but commercially limiting.
What happens if my supplier changes a component — do I need new type testing?
This depends on the significance of the change relative to the tested configuration. Your FPC procedure must include a documented change control process that evaluates whether a component change is within the scope of existing type test data. If the change affects a characteristic that has been declared — for example, changing the glazing unit specification affects both U-value and acoustic performance — new testing or a technical justification from the Notified Body is typically required. Making this assessment informally or not at all is one of the most common FPC failures identified by auditors.
I import windows manufactured in China. Do I need to issue my own DoP?
As the importer placing the product on the EU market, you must verify that the manufacturer’s DoP is accurate and complete, that the product has been assessed under the correct AVCP system by a legitimate Notified Body, and that your own name and contact details appear on the product labelling. If the manufacturer has issued a technically correct DoP and you are not modifying the product, you do not necessarily need to issue a separate DoP — but you bear legal responsibility for the accuracy of what is on the market. If you have any doubt about the quality of the manufacturer’s compliance documentation, commissioning an independent review before placing the product on the market is strongly advisable.
Is EN 14351-1 the same in all EU member states?
EN 14351-1 is a European harmonised standard and its technical content is identical across all EU member states. However, individual member states may have national annexes or national building regulations that specify minimum performance requirements for certain characteristics, or that require specific characteristics to be declared (rather than NPD) in their market. France, Germany, the Netherlands, and the Nordic countries all have national requirements that interact with the CPR declaration. Compliance with CPR and the harmonised standard ensures your product can be legally placed on the market; compliance with national building regulations determines whether and where it can actually be installed.
Conclusion
CPR compliance for windows and doors is not a one-time exercise. It requires initial investment in type testing and documentation, ongoing factory production control, and active management of component changes, standard updates, and market-specific requirements. For importers, it requires due diligence on the manufacturing chain that goes beyond simply receiving a CE mark certificate from a supplier.
The good news is that the framework is well established. The harmonised standards are detailed, the assessment systems are clear, and the DoP format is defined. Manufacturers and importers who invest in understanding the requirements — and who maintain rigorous FPC documentation — are well positioned to serve any EU market and to satisfy market surveillance scrutiny when it comes.
If your current compliance programme has gaps, the right time to address them is before a market surveillance authority or a customer’s compliance team identifies them for you. Start with your DoP: check every declared characteristic against actual test evidence, verify every Notified Body reference, and confirm that your FPC records would withstand a third-party review. That audit exercise will tell you quickly where to focus your efforts.
[INTERNAL LINK: CPR compliance audit checklist for manufacturers]
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Complete guide to windows and doors CPR requirements: harmonised standards, DoP, CE marking, AVCP systems, and importer obligations for EU compliance. (155 characters)
