‘Manufacturer’ means any natural or legal person who manufactures a construction product or who has such a product designed or manufactured, and markets that product under his name or trademark (CPR Article 2, Definitions, 19).

Obligations of manufacturers

Article 11 of the Construction Products Regulation describes your tasks and obligations as a manufacturer when you manufacture, market and sell construction products. Read the provisions of Article 11 here:

  1. Manufacturers shall draw up a declaration of performance in accordance with Articles 4 and 6, and affix the CE marking in accordance with Articles 8 and 9. Manufacturers shall, as the basis for the declaration of performance, draw up technical documentation describing all the relevant elements related to the required system of assessment and verification of constancy of performance.
  2. Manufacturers shall keep the technical documentation and the declaration of performance for a period of 10 years after the construction product has been placed on the market. Where appropriate, the Commission may, by means of delegated acts in accordance with Article 60, amend that period for families of construction products on the basis of the expected life or part played by the construction product in the construction works.
  3. Manufacturers shall ensure that procedures are in place to ensure that series production maintains the declared performance. Changes in the product-type and in the applicable harmonised technical specifications shall be adequately taken into account. Manufacturers shall, where deemed appropriate with regard to ensuring the accuracy, reliability and stability of the declared performance of a construction product, carry out sample testing of construction products placed or made available on the market, investigate, and, if necessary, keep a register of complaints, of non-conforming products and of product recalls, and keep distributors informed of any such monitoring.
  4. Manufacturers shall ensure that their construction products bear a type, batch or serial number or any other element allowing their identification, or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the construction product.
  5. Manufacturers shall indicate on the construction product or, where that is not possible, on its packaging or in a document accompanying it, their name, registered trade name or registered trade mark and their contact address. The address shall indicate a single point at which the manufacturer can be contacted.
  6. When making a construction product available on the market, manufacturers shall ensure that the product is accompanied by instructions and safety information in a language determined by the Member State concerned which can be easily understood by users.
  7. Manufacturers who consider or have reason to believe that a construction product which they have placed on the market is not in conformity with the declaration of performance or not in compliance with other applicable requirements in this Regulation, shall immediately take the necessary corrective measures to bring that construction product into conformity, or, if appropriate, to withdraw or recall it. Furthermore, where the product presents a risk, manufacturers shall immediately inform the competent national authorities of the Member States in which they made the construction product available to that effect, giving details, in particular, of the non-compliance and of any corrective measures taken.
  8. Manufacturers shall, further to a reasoned request from a competent national authority, provide it with all the information and documentation necessary to demonstrate the conformity of the construction product with the declaration of performance and compliance with other applicable requirements in this Regulation, in a language which can be easily understood by that authority. They shall cooperate with that authority, at its request, on any action taken to eliminate the risks posed by construction products which they have placed on the market.

Requirements which must be met by construction product manufacturers

The requirements to the manufacturer depend on the so-called AVCP system, which consists of five predetermined systems for the assessment and verification of a construction product's constancy of performance.

The requirements in the AVCP system precede the declaration of performance and the CE marking.The harmonised standards and the European Assessment Documents (EAD) determine the AVCP system and the overall requirements and technical details which must be met by the manufacturer. The AVCP system defines how the construction product's performance is assessed, and how you – as a manufacturer – must ensure its constant conformity with the declared performance.A construction product is placed in the AVCP system based on a risk as-sessment of its characteristics and significance to the buildings' conform-ity with the Building Regulations in general, including safety, health and environment. Based on the risk assessment, the manufacturers must meet certain requirements for testing and control of the construction products, and the AVCP system is meant to ensure the reliability and accuracy of the declaration of performance.Five different systems are used, designated: 1+, 1, 2+, 3 and 4.

Products with a higher risk assessment, e.g. smoke detectors which are placed in system 1, are subject to extensive requirements for continued testing according to the standard and independent third-party control of the production. The subsequent systems impose fewer and fewer requirements. 

Construction products with a low risk assessment, e.g. pavement flags which are placed in system 4, are subject to fewer requirements, and the manufacturer may perform its own factory production control without involving a third party. 

Annex ZA and the harmonised standards or EADs determine which system must be used for documenting the construction product's performance and affixing the CE marking. For some products, the AVCP system depends on their burning behaviour. 

Notified bodies must participate in systems 1+, 1, 2+ and 3. For a CE marking to be affixed to a construction product, the manufacturer's own factory production control (FCP) must be certified by a notified body in system 2+, while a certificate must be issued for the construction product's constancy of performance in systems 1 and 1+.

The entire system is set up for the purpose of ensuring that construction products with a CE marking can be marketed and sold freely within the EU.

The factory production control (FPC) typically covers:

  • Raw materials
  • Personnel
  • Production equipment
  • Ongoing controls
  • Handling of deviations


Overall tasks

Examples of construction products


Initial factory testing and the factory's own production control. No notified body required.

  • Concrete paving stones (EN 1338)

  • Mortar for masonry (998-1)


Initial testing by a notified body. One or more notified testing laboratories required.

  • EPS isolation (EN 13163), expanded polystyrene – often referred to as Styrofoam.


Certification of factory production control system. A notified product certification body or system certification body is required.

  • Load-bearing steel and aluminium structures (EN 1090-1)


Certification of the product itself. A notified product certification laboratory is required and possibly one or more testing laboratories.

  • Composite material for inside re-insulation (ETA-11/0414)

  • Smoke detectors (EN 14604)


Certification of the product itself. A notified product certification laboratory is required and possibly one or more testing laboratories.

  • Cement (EN 197-1)


AVCP systems for assessment and verification

In order to affix a CE marking on a construction product, the manufacturer must have its own factory production control (FCP) satisfying the requirements of the relevant harmonised standard (hEN) or ETA.

For some construction products, a testing or certification body (notified body) must participate in the process in addition to the manufacturer's own factory production control.

You can find a list of approved assessment bodies in the EU at the EU Commission's website.