Declaration of Performance (DoP) for Construction Products: An Overview

The Declaration of Performance (DoP) is an important element of the Construction Products Regulation. It provides information on a construction product’s performance relative to its essential characteristics, such as those set by applicable standards.

Manufacturers should issue the Declaration of Performance when their product is either covered by a harmonised standard or conforms to a European Technical Assessment. This guide addresses key questions surrounding the Declaration of Performance and its requirements.

What is the Declaration of Performance?

The Construction Products Regulation requires manufacturers to draw up the Declaration of Performance, which is a document that communicates that the product has met the technical specifications of relevant harmonised standards or European Technical Assessment.

The regulation defines ‘manufacturer’ as an entity responsible for manufacturing a construction product, or for having a construction product designed or manufactured, and marketing it under their name.

If they exist, manufacturers should comply with harmonised standards that are relevant to their product, in order to satisfy the required performances.

Alternatively, manufacturers may request a European Technical Assessment from a Technical Assessment Body (TAB), in order to determine the performance of construction products not covered by harmonised standards. The European Technical Assessment serves as the basis for drawing up the Declaration of Performance.

Which products require the Declaration of Performance?

Manufacturers need to create the Declaration of Performance for products that are either covered by harmonised standards or conform to a European Technical Assessment that was issued for them.

Here are several examples of construction products covered by harmonised standards:

• Smoke detectors
• Glass in buildings
• Shower trays for domestic purposes
• Wash basins (as a sanitary appliance)
• Decorative wall coverings
• Stairs
• Bidets
• Baths for domestic purposes
• Windows and doors
• Wood flooring

What products do not need a Declaration of Performance?

Manufacturers do not need to create a Declaration of Performance if their construction product:

• Is not covered by a harmonised standard and
• Does not conform to a European Technical Assessment

However, even when the construction product necessitates the creation of a Declaration of Performance due to the existence of a relevant harmonised standard, there are scenarios in which the manufacturer does not need to draw up the Declaration of Performance. The Construction Products Regulation lists the following scenarios:

a. When the construction product was custom-made or individually manufactured

b. When the construction product was manufactured on a construction site for incorporation in a compliant construction work

c. When the construction product was traditionally manufactured or in a way that aids heritage conservation

Article 5 of the Construction Products Regulation provides more details about this matter.

What should the Declaration of Performance contain?

The Declaration of Performance needs to contain the following items:

a. The unique identification code of the product-type, which according to the European Commission is created by the manufacturer and should have a structure such as Product-ABC-2025-04-25

b. The intended use or uses of the product

c. The manufacturer’s identity

d. The authorised representative’s identity, if applicable

e. The system of assessment and verification of constancy of performance (AVCP) that was used

f. If applicable, the harmonised standard or standards, and the notified body that conducted the AVCP

g. If applicable, the European Assessment Document related to the conducted European Technical Assessment, and information on the TAB that conducted the assessment

h. The declared performance or performances

i. The Appropriate Technical Documentation or Specific Technical Documentation

j. A conformity statement

k. The manufacturer’s name, place, date of issue, and signature

Annex III of the regulation provides detailed instructions for drawing up the Declaration of Performance.

To whom should I send the Declaration of Performance?

The Construction Products Regulation requires you to provide a paper or electronic copy of the Declaration of Performance of each construction product sold in the EU.

Construction product distributors, including wholesalers and retailers, are likely to request that you provide them with the Declaration of Performance. Market surveillance authorities can also request that you provide them with a DoP copy if they see the need to investigate the conformity of the construction product.

The sections below list different types of entities that may request a Declaration of Performance.

Authorised representatives

Manufacturers may need to appoint an authorised representative. Specifically, the Market Surveillance Regulation requires that you must appoint an authorised representative if you are based outside the EU and sell directly to consumers in the EU.

The Construction Products Regulation requires authorised representatives to retain the Declaration of Performance and provide it to competent national authorities upon request.

Importers

Importers need to ensure that the manufacturer has created the Declaration of Performance correctly and should request a copy of the Declaration of Performance. They should also:

a. Not sell a product unless it conforms to the Declaration of Performance

b. Ensure storage or transport conditions do not affect the construction product’s conformity with the Declaration of Performance

c. Retain a copy of the Declaration of Performance

d. Provide the competent national authority with a copy of the Declaration of Performance upon request.

Article 13 contains more details about the importer’s responsibilities regarding the Declaration of Performance.

Distributors

The Construction Products Regulation requires distributors to ensure covered products are in conformity with the Declaration of Performance before the products are sold. Article 14 contains more information concerning the distributor’s responsibilities.

Can an importer or a distributor issue the Declaration of Performance?

No, they cannot. The Construction Products Regulation states that the Declaration of Performance must be issued by the manufacturer.

Note, however, that the regulation considers importers or distributors to be manufacturers if said importers and distributors:

• Sell the product under their name, or
• Modifies a construction product already on sale

Can a construction product without a DoP be CE marked?

No. According to Article 8 of the Construction Products Regulation, if the manufacturer does not draw up a Declaration of Performance for a covered construction product, it cannot affix the CE marking.

Note that the provision of the CE marking is mandatory when a Declaration of Performance has been drafted. As already explained, a Declaration of Performance is necessary when:

a. The product is covered by harmonised standards, or

b. The manufacturer has requested and obtained a European Technical Assessment