EU Construction Products Regulation 2024/3110: What the Text Says About Importers, Declarations of Performance and CE Marking

Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2024 lays down harmonised rules for the marketing of construction products and repeals Regulation (EU) No 305/2011. It was published in the Official Journal on 18 December 2024. Its Article 96 sets two main application dates, 7 January 2025 for a list of provisions and 8 January 2026 for the rest, and Article 95 ties the obligations on a given product family to later implementing acts. For an importer bringing windows, doors, panels, insulation or structural products from China into the EU, the Regulation sets out what an importer has to check before placing a product on the market, but the product-by-product detail is not in the Regulation itself.

This article reads the Regulation as published (Official Journal text), read on 13 October 2026. It covers the articles that matter most to a buyer: subject matter and scope, the declaration of performance and conformity, CE marking, the duties of importers, the cases in which an importer is treated as a manufacturer, and the application and transitional dates. It is a reading of the legal text for procurement planning, not legal advice, and it does not decide whether any particular product is covered. We did not read the annexes, any harmonised standard, any implementing or delegated act, or the penalty provisions. For related rules, see our guides to the General Product Safety Regulation, the Ecodesign for Sustainable Products Regulation and the United Kingdom’s construction products reform.

Subject matter and scope

Article 1(1) says the Regulation lays down harmonised rules for the placing and making available on the market of construction products, by establishing harmonised rules on how to express the environmental and safety performance of construction products in relation to their essential characteristics, including on life cycle assessment, and environmental, functional and safety product requirements. Article 1(2) adds rights and obligations for economic operators dealing with construction products or their components.

Article 2(1) applies the Regulation to construction products, including used products, and to key parts of products and to parts or materials intended to be used for products covered by the Regulation if the manufacturer of those parts or materials so requests. Article 2(2) excludes lifts subject to Directive 2014/33/EU, escalators and their components, and requirements or performance assessment subject to Directive (EU) 2020/2184 and covered by the delegated acts referred to in that Directive.

Article 3 defines a “construction product” as any formed or formless physical item, including 3D-printed products, or a kit, that is placed on the market, including by means of supply to the construction site, for incorporation in a permanent manner into construction works or parts thereof, with the exception of items that first need to be integrated into a kit or another construction product before being incorporated. “Placing on the market” means the first making available of a product on the Union market, or the first making available on the Union market of a used product after a deinstallation.

Application dates and transitional rules

Article 96 says the Regulation enters into force on the twentieth day following its publication and shall apply from 8 January 2026, with the following exceptions.

• From 7 January 2025: Articles 1 to 4, Article 5(1) to (7), Article 7(1), Article 9, Article 10, the first subparagraph of Article 12(1), Article 16(3), Article 37(4), Article 63, Article 89 and Article 90, and Annexes I, II, III, IV, VII, IX and X.
• From 8 January 2027: Article 92.

Article 95 sets transitional rules. Harmonised standards referenced under Regulation (EU) No 305/2011 and in force on 8 January 2026 remain valid under that Regulation until withdrawn by the Commission or otherwise repealed (Article 95(3)). Article 95(9) says the requirements and obligations of economic operators in Chapters I, II and III apply to a product family, or a product category within it, only from one year after the date of adoption of an implementing act under Article 5(8) making a harmonised standard mandatory or an implementing act under Article 6(1), unless the act sets a later date; economic operators may choose to apply those harmonised technical specifications earlier. Article 95(7) allows certificates, test reports and European technical assessments issued under Regulation (EU) No 305/2011 to be used as the technical basis for compliance where the product type corresponds and the requirements and assessment methods remain valid.

The practical effect is that the date from which a particular product family carries the new obligations depends on acts we did not read. A buyer should ask the factory and the importer which regime applies to the exact product on the order date, and put the answer in the file.

The declaration of performance and conformity

Article 13(1) says that where a product is covered by a harmonised technical specification adopted under Article 5 or 6, the manufacturer shall undergo the applicable assessment and verification system in Annex IX and draw up a declaration of performance and conformity before the product is placed on the market. Where the product is covered by a harmonised technical specification adopted under Article 7, the manufacturer shall also verify compliance with the applicable product requirements specified by delegated acts. A manufacturer of a product not covered by any harmonised technical specification may issue a declaration in accordance with the relevant European assessment document and European technical assessment.

Article 13(2) says that by drawing up the declaration the manufacturer assumes responsibility for the conformity of the product with its declared performance and any applicable product requirements, and becomes liable under Union and national law. In the event of non-compliance, or where a required declaration is absent, the product may not be made available on the market.

Article 14 lets a manufacturer decide not to undergo assessment and not to draw up a declaration in two cases. The first is a product that is individually manufactured or custom-made, and that meets all four conditions: it is manufactured using a non-series process; it is produced in response to a specific order; it is installed in a single identified construction work by a manufacturer who is also responsible for the safe incorporation of the product into the work; and it complies with the applicable national rules and is under the supervision of those responsible for the safe execution of the works. The second is a product manufactured in a manner exclusively appropriate to heritage conservation and in a non-series process for renovating officially protected works.

CE marking

Article 17(2) says the CE marking shall be affixed only to products for which the manufacturer has drawn up a declaration of performance and conformity under Articles 13 and 15, and shall be affixed to key parts. Article 17(3) says that by affixing the CE marking the economic operator indicates that it has assumed responsibility for the conformity of the product with the declared performance and applicable product requirements, and becomes liable for them under national contract and tort law. Article 17(4) says the CE marking shall be the only marking attesting to the performance of the product with regard to assessed essential characteristics and to the conformity of the product with the Regulation.

What an importer must do

Article 24 sets out the obligations of importers. The points below are quoted or closely paraphrased from the text.

• Article 24(1)–(2): place on the market only compliant products; before doing so, ensure that the manufacturer has demonstrated compliance and performance, has drawn up the technical documentation, that the product bears the CE marking and labelling, that it is accompanied by the declaration of performance and conformity or that the declaration is available, and that the manufacturer has complied with Article 22(5), (6) and (7).
• Article 24(3): verify that the use of the product has been declared by the manufacturer; ensure the product is accompanied by general product information, instructions for use and safety information as set out in Annex IV in a language determined by the Member State concerned or, absent that, a language easily understood by users; and display to customers, before they are bound by a sales contract, the information that must be provided under the Regulation.
• Article 24(4): ensure that storage or transport conditions under its responsibility do not jeopardise conformity with the declaration of performance and conformity.
• Article 24(5): where it considers or has reason to believe that a product is not in conformity, not place it on the market until it conforms or the declaration is corrected, and where the product presents a risk, inform the manufacturer and the competent national authority.
• Article 24(6): indicate its name, registered trade name or trade mark, place of business and contact address on the product or, where not possible, on its packaging or an accompanying document.
• Article 24(7)–(8): investigate complaints and, if necessary, keep a register of complaints, non-conforming products, withdrawals and recalls; take corrective measures, or withdraw or recall, where a placed product is not in conformity, and inform authorities where it poses a risk.
• Article 24(9): importers selling to end users shall also fulfil the obligations incumbent on distributors.

When an importer is treated as a manufacturer

Article 26(1) says an importer or distributor shall be considered a manufacturer, with the obligations of a manufacturer under Article 22, where it:

• places a product on the market under its own name or trademark;
• modifies a product intentionally, or the product is unintentionally modified so that compliance with the declaration or the requirements may be affected;
• makes a product available with a declared use different from the declared use attributed by the manufacturer in the assessment and verification process;
• claims for the product characteristics deviating from those declared by the manufacturer; or
• opts to assume the role of the manufacturer.

Article 26(3) says paragraph 1 does not apply where the economic operator only adds translations of information supplied by the manufacturer, or replaces the outer packaging of a product already placed on the market, including when changing the packaging size, if the repackaging is carried out so that the original condition of the product cannot be affected and the information required by the Regulation is still correctly provided. For a buyer who sells Chinese products under its own brand in the EU, the first bullet is the one to take to its adviser.

The Regulation at a glance

What to put in a China purchase brief

None of the following is a requirement placed on a factory by the Regulation. They are questions an EU importer can write into the brief so that the documents are settled before an order is placed. Put each answer in writing and keep it with the purchase order.

• Regime: which regime the exact product falls under on the order date, with the harmonised standard or European assessment document the factory relies on.
• Declaration: a copy of the declaration of performance and conformity for the exact product type, in the form the importer will hold.
• CE marking and labelling: where the marking and labelling sit on the product and on the packaging, shown on a sample before bulk production.
• Technical documentation: confirmation that the factory holds it and will make it available through the importer.
• Product information: the general product information, instructions for use and safety information in the language of the Member State of sale.
• Own-brand sales: whether the importer will sell under its own name or trade mark, and what follows from Article 26(1)(a).
• Custom-made lines: whether any line relies on the custom-made exemption in Article 14, and who holds the evidence of the four conditions.
• Change control: a commitment that a change of design, material or supplier is notified before production, by item code.

For the supply side of related products see our guide to window and door packages.

What this reading does not cover

This article does not read Annexes I to X, the harmonised standards, any implementing or delegated act, the provisions on European assessment documents and technical assessment bodies, or the penalty provisions. It does not say which product families are covered by which date, and it does not say that any named product needs a declaration. Check the Official Journal and the Commission’s lists of harmonised standards for the current position before you rely on this reading, because the version we read is the text as published on 18 December 2024, and keep a dated copy with the project file so that the position at the date of the order can be shown later.

Questions buyers ask about Regulation (EU) 2024/3110

What is Regulation (EU) 2024/3110?

It is the Construction Products Regulation of 27 November 2024, which lays down harmonised rules for the marketing of construction products and repeals Regulation (EU) No 305/2011.

When does it apply?

Article 96 says it applies from 8 January 2026, with a list of provisions applying from 7 January 2025 and Article 92 from 8 January 2027. Article 95(9) ties the obligations on a product family to later implementing acts.

What must an importer check before placing a product on the market?

Article 24(2) says the importer must ensure that compliance and performance have been demonstrated, that the technical documentation exists, that the product bears the CE marking and labelling, and that it is accompanied by the declaration of performance and conformity or that the declaration is available.

When is an importer treated as the manufacturer?

Article 26(1) lists cases including placing a product on the market under its own name or trademark, modifying it, changing its declared use, claiming different characteristics or opting to assume the manufacturer’s role.

How does FBM Sourcing support this kind of project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers.