When does the new Construction Products Regulation apply?

Regulation (EU) 2024/3110 applies from **8 January 2026**. Individual articles and annexes already applied from **7 January 2025**, and one further article applies only from **8 January 2027** (Art. 96). For shop operations, 8 January 2026 is the date from which the distributor duties in Article 25 are applicable. The transitional rule matters: harmonised standards from the old list remain valid until the Commission withdraws them, and European Assessment Documents from the old list run until **9 January 2031** (Art. 95(3) and (4)).

Is a link to a file on the product page enough?

A link is enough if the declaration is made available on a website in accordance with Article 16(2). That requires **six** conditions to be met at the same time; the first demands that the content is made available in an unalterable electronic format. A file that is swapped out under the same address does not meet it. In practice that means a fixed version number, a separate address per version, a validity period and an archive that keeps earlier versions reachable.

At which moment does the customer have to see the information?

Before being bound by the sales contract. Article 25(3) requires the distributor to display the prescribed information in a visible manner before customers are bound by a sales contract, and it names distance selling explicitly. In the shop that means on the product detail page and in the basket at the latest, not in the order confirmation or on the delivery note. Quotes and order lists need the same block, because a binding can arise there too.

How long do we have to keep the documentation?

**Ten** years after the date on which the product was supplied or received, kept available for the competent national authorities. On request the documentation has to be presented within **ten** days (Art. 20(4)). Under the old regulation the retention period was **ten** years from the moment the product was placed on the market (Art. 11(2) of Regulation (EU) No 305/2011). What matters is less the duration than the mapping: which version applied at the time of delivery?

Does this also apply to items we only resell?

Yes. The distributor is an economic operator and carries the duties in Article 25: they satisfy themselves on the **four** points in paragraph 2 before making the product available, and they display the information before the contract binds. The duties in that chapter apply where a product is covered by a harmonised technical specification or has been CE marked on the basis of a European Technical Assessment (Art. 20(1)). Items outside that scope need no declaration – but the item master has to be able to tell the difference.

Showing Declarations of Performance Before Checkout

Q: What has to appear in the online offer?

Where an economic operator makes a product available online or through other forms of distance selling, the offer has to state clearly and visibly, where required, the CE marking, the information listed in Article 18(2), the marking under Article 22(9) and a data carrier linked to a digital product passport (Art. 29(2)). **Seven** further items follow the CE marking, beginning with the last two digits of the year in which it was first affixed (Art. 18(2)).

A builders' merchant with an online shop does not sell goods that simply drop into a basket. Cement, insulation boards, windows and reinforcing steel come with a document that records the performance of the product in relation to its essential characteristics. Since 8 January 2026 that document is governed by Regulation (EU) 2024/3110, and one requirement lands directly in the shop: the distributor displays the prescribed information in a visible manner before the customer is bound by a sales contract – explicitly including distance selling (Art. 25(3)). That moves the declaration of performance and conformity from the shipping folder onto the product detail page. Before a product is made available there are four checks the distributor has to work through (Art. 25(2)), and behind the sale sits a retention period of ten years with a ten-day deadline for presenting documents to the authority (Art. 20(4)). This article translates those requirements into shop work: into fields in the item master, into release logic before publication and into a document model that survives a change of version.

Key takeaways

The display duty lands on the product detail page, not on the delivery note: the prescribed information is visible before the customer is bound by a sales contract, and that applies explicitly to distance selling (Art. 25(3) of Regulation (EU) 2024/3110).
Before each making available there are four checks on the item: CE marking, a declaration of performance and conformity that is either enclosed or available, product information including safety information, and the language both are supplied in (Art. 25(2)).
The declaration may sit on a website instead of travelling with the product – but only if six conditions are met at the same time, one of them an unalterable electronic format (Art. 16(2)).
Seven further items follow the CE marking, and the online offer has to state them clearly and visibly where required (Art. 18(2) and Art. 29(2)).
Keep documentation for ten years, present it within ten days on request (Art. 20(4)): that is not an archiving question but the question of whether anyone can still find the version that applied at the time of delivery.

What changed on 8 January 2026

Regulation (EU) 2024/3110 became applicable on 8 January 2026 and replaces Regulation (EU) No 305/2011; individual articles and annexes already applied from 7 January 2025, and one further article applies only from 8 January 2027 (Art. 96). For the shop the important change is not the numbering but the cut of the distributor's duties. Anyone making a construction product available on the market is an economic operator within the meaning of the regulation, and the online catalogue is one form of making available. The duties in that chapter apply where a product is covered by a harmonised technical specification or has been CE marked on the basis of a European Technical Assessment (Art. 20(1)). That is the first question the item master has to answer: does this item fall inside the scope at all?

Two documents have become one. The old regulation knew the declaration of performance; the new one requires a declaration of performance and conformity that carries both. It covers the performance of a product over its life cycle in relation to essential characteristics, and it does so in stages: the characteristics under Annex II points (a) to (d) from 8 January 2026, points (e) to (m) from 9 January 2030 and points (n) to (s) from 9 January 2032 (Art. 15(3)). A shop that links the declaration only as a file today will follow that staging in three waves. That is an argument for treating the document as a data record from the outset rather than as an attachment – the same direction the digital product passport is heading in.

One declaration, two names

In established catalogues the document still runs under the label declaration of performance, or under the short form DoP. Regulation (EU) 2024/3110 calls it a declaration of performance and conformity because it bundles the performance statement and the conformity statement into a single document. For data maintenance that means one document type, one field set and two labels in the interface. Anyone who instead creates two separate types ends up, after the first change of supplier, with items carrying both – and nobody can say which one applies.

The four checks in Article 25 as a release checklist

Article 25(2) states the distributor's duty as a sequence: before a distributor makes a product available on the market, they satisfy themselves on four points. First, the product carries the CE marking and, where applicable, the marking under Article 22(9). Second, where required, a declaration of performance and conformity accompanies the product, or the declaration is available in accordance with Article 16(2). Third, the general product information, instructions for use and safety information are supplied. Fourth, the language is right: it is the one laid down by the member state or, where no such language has been laid down, one that can easily be understood by users (Art. 22(6)).

Check	What the distributor looks for	Field in the item master	Failure pattern in the shop
CE marking	marking on the product, plus the marking under Art. 22(9)	flag plus the year it was first affixed	item is live while the marking is missing at goods-in
Declaration	enclosed or available on a website under Art. 16(2)	document link with version and validity	the link points to an earlier version
Product information	general details, instructions for use, safety information	document set per item rather than per supplier	shared folder with no item reference
Language	language under Art. 22(6), laid down or easily understood	language flag per document	delivery into a country whose language version is missing
Display	visible before the customer is bound by a contract (Art. 25(3))	mandatory block on the detail page and in the basket	information only appears on the delivery note
Retention	ten years available, ten days to present (Art. 20(4))	archive copy with a timestamp per order	the supplier replaced the file and the old version is gone

In the shop these four points are not prose but a release condition. They belong at the point where an item moves from created to visible – in Shopware that is the sales channel visibility, fed by the fields that arrive from PIM and ERP. An item without a valid declaration is not flagged in red; it is not published. That is inconvenient in range maintenance and cheap compared with correcting a whole category afterwards.

The declaration as a versioned document on the item

The regulation expressly allows the declaration to sit on a website instead of accompanying the product. The price for that is six conditions that have to be met at the same time (Art. 16(2)). The first of them decides the technical architecture: the content of the declaration has to be made available on the website in an unalterable electronic format. A file the supplier swaps out under the same address does not meet that. A document with a fixed version number, its own address and a validity period does.

In practice the declaration becomes its own data record with an item reference, version number, validity, language, file and checksum. The item points at whichever version is currently valid; earlier versions stay reachable, because an order placed in 2027 needs the 2027 version and not the one from 2031. The same separation between item and document is required by safety data sheets and instructions for use – build it once and it serves three sets of duties. How the documents reach the detail page depends on the product data pipeline.

The core in one sentence

The declaration itself is not the problem; the problem is knowing which version applied at the moment of the order – and only a versioned document answers that, never an overwritten file.

Display before the contract, not inside the parcel

Article 25(3) is the sentence that changes the shop: the distributor displays to customers, in a visible manner, before they are bound by a sales contract, the information which must be provided under the regulation – and that includes distance selling. Article 29(2) adds a requirement for the online offer: where required, it has to state clearly and visibly the CE marking, the information listed in Article 18(2), the marking under Article 22(9) and a data carrier linked to a digital product passport. Seven further items follow the CE marking (Art. 18(2)), starting with the last two digits of the year in which the marking was first affixed.

CE marking

Visible on the item, not only in the data sheet. Together with the items that follow the marking under Article 18(2).

Declaration of performance and conformity

Linked or embedded, with a version number and date. The link points at an unalterable format, not at a folder.

Safety information

Instructions for use and safety information belong on the detail page, not in an insert that arrives with the goods.

Language

Per destination country, the language the member state has laid down, or one that can easily be understood by users.

Basket and checkout

The information stays reachable up to the order. The customer is bound only on submission; it has to be visible before that.

Data carrier

Where a digital product passport is required, the matching data carrier belongs on the same line as the other mandatory details.

For the implementation, sequence matters more than styling. Visible does not mean in the fourth tab, two clicks away. In list and search views a short note with a link is enough; on the detail page the mandatory block belongs near the buying decision, so above or directly beside the basket area. Anyone running a customer portal has an easier job: the same block can be reused in quotes and in the order history.

What the item master has to support

The fields are manageable; their provenance is not. In most merchants the declaration comes from the supplier, the CE details from goods-in and the language version from the translation process. That leaves the release hanging on three sources that do not know each other. A PIM pipeline is not a luxury here but the only place where completeness can be checked before the item reaches the channel. For builders' merchants we have described the pattern on the sector page.

A flag recording whether the item is covered by a harmonised technical specification or a European Technical Assessment
A link to the valid declaration of performance and conformity with version number, validity and language
CE details under Article 18(2), starting with the year the marking was first affixed
Product information, instructions for use and safety information as separate documents on the item
A language flag per document and per destination country so the shop serves the right version
A release rule: no sales channel without a complete set, checked on import rather than by the customer

Filling these fields is diligence work; keeping them is process work. A supplier who sends a new version without marking the old one creates exactly the state the regulation sets out to prevent. That is why the import pipeline needs a rule that creates a new version instead of overwriting an existing one – the same discipline that batches and serial numbers demand. The technical connection for that runs over the usual integrations.

Retention and the ten-day deadline

Article 20(4) puts two deadlines side by side. An economic operator has to keep all documentation and information referred to in that chapter available for the competent national authorities for ten years after the date on which the operator supplied or was supplied with the product. And the operator presents the documentation within ten days of receiving a request from the competent national authority. The first number concerns the archive, the second concerns findability. Ten years are easy as long as nobody asks; ten days are short when the answer sits on a network drive with no item reference. What an archive that carries both deadlines looks like is described in the article on the document archive in the customer account.

Four failure patterns you can find before go-live

First: the item is visible while the document link leads nowhere because an import run replaced the file. Second: the declaration exists only in the supplier's language, but the goods ship to a country that has laid down its own language (Art. 22(6)). Third: the mandatory details are on the detail page but missing from the quote and the order confirmation – exactly where the binding arises. Fourth: the archive holds only the current state, not the state at the time of delivery; a request six years later then turns into a search operation.

Transition: two rule sets side by side

The cut-off date does not change everything at once. Harmonised standards whose references are listed under the old regulation and which are in force on 8 January 2026 remain valid under Regulation (EU) No 305/2011 until the Commission withdraws them or they are otherwise repealed. European Assessment Documents whose references are listed on 8 January 2026 under Article 22 of the old regulation remain valid until 9 January 2031 (Art. 95(3) and (4)). For products covered by those standards a whole series of articles of the old regulation also continues to apply (Art. 95(8)).

For data maintenance that means the old rules are not a museum piece. Regulation (EU) No 305/2011 requires a copy of the declaration of performance to be supplied in paper form if the recipient requests it (Art. 7(2)), and it requires the technical documentation and the declaration of performance to be kept for ten years after the product was placed on the market (Art. 11(2)). Website provision was possible there too, but only under four conditions (Delegated Regulation (EU) No 157/2014), among them free access for purchasers of construction products for ten years after the product was placed on the market. A shop carrying both populations therefore needs a flag on the item recording which rule set applies – comparable to the distinction made for supplier declarations of origin.

Take stock before rebuilding

Three queries are enough for a first picture. How many items in the range are covered by a harmonised technical specification? How many of those carry a document link pointing at an address without a version number? And for how many does the mandatory detail sit only in the description text rather than in a field? The result is usually a list that can be sorted by supplier and worked through in waves – starting with the suppliers that account for the largest share of the range.

The rebuild in four waves

A range with several thousand construction products cannot be converted over a weekend. A sensible order creates visibility early and only then goes into depth.

Scope: decide for every item whether it is covered by a harmonised technical specification or a European Technical Assessment. Without that flag every further rule runs dry.
Display: a mandatory block on the product detail page, in the basket and in the quote, fed from the fields you already have. That satisfies the requirement in Article 25(3) even while data quality is still uneven.
Document model: declarations as versioned data records with version number, validity and language rather than as files in a folder. From here the condition in Article 16(2) also holds technically.
Automation: import rules that create new versions instead of overwriting, plus a release check that keeps items without a complete set out of the channel in the first place.

Follow that order and the display duty is already satisfied after the second wave, with depth and automation coming afterwards. Anyone who also carries electrical equipment meets the same structure under a different duty. Questions about implementing this in your own range reach us through the contact form, and how a builders' merchant range is structured in the shop is set out on the sector overview.

Sources and legal basis

This article draws on Regulation (EU) 2024/3110 on construction products, Regulation (EU) No 305/2011 and Delegated Regulation (EU) No 157/2014, each in the version published via EUR-Lex. The articles, deadlines and dates named refer to the state retrievable there. It does not replace a legal review of your own range.