CEPROCON.COM  •  BLOG ARTICLE  •  WEEK 6

Which system applies to your construction product — and what does it actually require?

Understanding AVCP systems for construction products is essential for any CE marking project. When manufacturers first encounter CE marking for construction products, one of the most common sources of confusion is the AVCP system. The letters stand for Assessment and Verification of Constancy of Performance — which, while accurate, does not immediately make things clearer.

In plain terms, the AVCP system answers two questions: who is responsible for assessing and verifying the performance of a construction product, and how much independent third-party involvement is required? The answer depends on the product and its potential impact on health, safety, and structural integrity — and it is determined by the harmonised standard that applies to the product, not by the manufacturer.

There are five AVCP systems under the CPR: 1+, 1, 2+, 3, and 4. Each places different tasks on the manufacturer and, in most cases, on an independent Notified Body. This article explains each system clearly, sets out what it requires in practice, and helps you understand which one is likely to apply to your product.

Why do AVCP systems exist?

The fundamental principle behind AVCP systems is proportionality. Not all construction products carry the same risk if they fail to perform as declared. A structural steel beam that fails to meet its declared load-bearing capacity can cause catastrophic structural collapse. A decorative tile adhesive that performs slightly below specification is unlikely to endanger lives.

The CPR therefore establishes a graduated system: the higher the potential consequences of performance failure, the more stringent the assessment and verification requirements, and the greater the mandatory involvement of an independent Notified Body. This is why a simple mortar might fall under system 4 — allowing the manufacturer to assess and declare everything themselves — while a fire door falls under system 1, requiring ongoing involvement from a notified third party.

The AVCP system for any given product and characteristic is specified in Annex ZA of the applicable harmonised standard. A single product may have different AVCP systems for different characteristics — for example, system 3 for reaction to fire testing and system 4 for all other characteristics.

The two categories of tasks: manufacturer and Notified Body

Before examining each system, it helps to understand the two categories of tasks that AVCP systems distribute between manufacturers and Notified Bodies:

Task category	Manufacturer tasks	Notified Body tasks
Type testing (TT)	Testing the product against relevant characteristics using the methods in the hEN. Manufacturers may use their own laboratory (if accredited) or commission a third-party laboratory.	In systems 1+ and 1, the Notified Body conducts or oversees TT. In systems 2+ and 4, it is a manufacturer task. In system 3, a Notified Body laboratory conducts TT.
Factory Production Control (FPC)	The manufacturer’s internal quality system for ensuring ongoing consistency of production. Required in all AVCP systems.	In systems 1+ and 1, the Notified Body continuously audits the FPC. In system 2+, the Notified Body certifies the FPC but does not continuously audit product samples. In systems 3 and 4, no Notified Body involvement in FPC.

The five AVCP systems in detail

System 1+ — The most stringent

System 1+ involves the deepest level of independent third-party oversight. Under this system, a Notified Product Certification Body (NPCB) is responsible for the type testing of the product, initial inspection of the manufacturing plant and FPC system, and continuous surveillance, assessment, and evaluation of the FPC — including taking further samples from the market or factory for testing.

The “+” in system 1+ refers to this additional requirement: the Notified Body must not only certify the FPC but must also conduct or supervise ongoing product sampling and testing to verify that performance remains consistent over time.

What the manufacturer does:

• Operates and maintains the Factory Production Control system
• Draws up the Declaration of Performance based on the Notified Body’s certificate
• Affixes the CE mark

Typical products:

Fire doors and fire-rated glazing; structural anchors used in concrete for critical applications; explosive-actuated fasteners; products used in safety-critical structural applications where failure could result in loss of life.

System 1 — Third-party certification without ongoing market sampling

System 1 is very similar to system 1+, with one key difference: the Notified Body certifies the FPC and conducts type testing, but is not required to carry out ongoing sampling and testing from the market or factory after certification.

The Notified Body still performs ongoing surveillance of the FPC system through periodic audits, but the continuous product testing obligation that characterises system 1+ does not apply.

Typical products:

Many structural products including prefabricated concrete elements, structural timber products, load-bearing metal components; products with significant fire performance requirements such as fire-resistant products for facades; certain waterproofing systems.

System 2+ — FPC certification only

Under system 2+, the manufacturer takes responsibility for type testing, while a Notified Inspection Body (NIB) is responsible for certifying the Factory Production Control system. The NIB conducts an initial inspection of the manufacturing plant and the FPC, and carries out ongoing surveillance audits to ensure the FPC continues to function correctly.

Crucially, under system 2+ the Notified Body does not assess or certify the product’s performance directly — that is the manufacturer’s responsibility. What the Notified Body certifies is the robustness of the system the manufacturer uses to ensure consistency of production.

Typical products:

Many facade products including curtain walling and cladding systems; certain internal partition systems; some insulation products; a range of flooring products.

System 3 — Third-party testing only

System 3 is a hybrid: type testing is carried out by a Notified Testing Laboratory (NTL), but the manufacturer is responsible for the Factory Production Control system and there is no Notified Body involvement in FPC certification or surveillance.

This system is frequently applied to specific characteristics within a standard rather than to the whole product. It is common for the reaction to fire characteristic to be assessed under system 3 even when other characteristics of the same product fall under system 4, because fire test results from accredited laboratories provide stronger independent assurance without requiring full third-party FPC certification.

Typical products / characteristics:

Reaction to fire testing for many product types; some sealants and adhesives; certain insulation products; building blocks and masonry units for non-load-bearing applications.

System 4 — Manufacturer self-declaration

System 4 is the least stringent of the five systems. The manufacturer carries out all assessment and verification tasks independently — type testing, FPC operation, and maintenance — with no mandatory involvement from a Notified Body at any stage.

This does not mean system 4 products are low quality or that their CE marking carries less credibility. It simply reflects that the EU legislator has determined that for this product category and these characteristics, the risk profile does not require mandatory independent verification. The manufacturer remains fully legally responsible for the accuracy of their declarations.

Typical products:

Many mortars (excluding structural uses); some tile adhesives and grouts; certain paint systems; decorative products; some wood-based products for interior applications.

AVCP systems at a glance: comparison table

System	Who does TT?	FPC certified by NB?	Ongoing NB surveillance?	NB document issued
1+	Notified Body	Yes	Yes + product sampling	Certificate of constancy of performance
1	Notified Body	Yes	Yes (FPC audits)	Certificate of constancy of performance
2+	Manufacturer	Yes	Yes (FPC audits)	Certificate of conformity of FPC
3	Notified testing lab	No	No	Test report(s)
4	Manufacturer	No	No	None required

How to determine which system applies to your product

The AVCP system is not chosen by the manufacturer. It is specified in Annex ZA of the harmonised standard that covers the product. This annex contains a table listing each essential characteristic covered by the standard and the AVCP system that applies to it.

Several important points follow from this:

• Different characteristics of the same product may be subject to different AVCP systems. It is entirely normal for a product to require, for example, system 3 testing for reaction to fire and system 4 self-declaration for all other characteristics.
• A product’s AVCP system can change if a revised harmonised standard is published. It is important to check Annex ZA when a standard is updated.
• The intended use stated in the DoP affects which AVCP system applies. The same physical product declared for different intended uses may fall under different systems.
• If a Notified Body is required, the manufacturer must engage one before the CE mark can be affixed. Affixing CE marking without the required Notified Body involvement is a serious regulatory breach.

Practical implications for planning your CE marking project

Understanding the AVCP system early in a CE marking project is essential for realistic planning. The system determines:

• Cost: Notified Body involvement adds certification fees, audit costs, and annual surveillance fees. Systems 1+ and 1 are significantly more expensive to maintain than systems 3 or 4.
• Timeline: Engaging a Notified Body, scheduling audits, and obtaining certificates takes time. For systems 1+ and 1, allow several months from initial contact with the Notified Body to certificate issue.
• Ongoing obligations: Systems 1+, 1, and 2+ create ongoing contractual and audit relationships with a Notified Body that the manufacturer must manage for as long as the CE mark remains in use.
• FPC requirements: All systems require the manufacturer to operate an FPC system. However, the rigour and documentation required will be influenced by whether the FPC is subject to third-party certification and audit.

Summary

AVCP systems are the CPR’s mechanism for calibrating the level of independent oversight required for different construction products. The higher the potential consequences of performance failure, the more stringent the system and the greater the mandatory role of a Notified Body.

The applicable system is always defined in Annex ZA of the harmonised standard. Understanding it early — before testing begins or a DoP is drafted — is one of the most important steps in planning a CE marking project. Get it wrong and the entire CE marking exercise may need to be repeated.

Not sure which AVCP system applies to your product?

Misidentifying the AVCP system is one of the costliest mistakes in CE marking. At CEProCon, we help manufacturers read Annex ZA correctly, understand what their system requires, identify the right Notified Body where needed, and plan a realistic, cost-effective CE marking programme from the start.

If you need help confirming the AVCP system for your product or finding and engaging the right Notified Body, our Notified Body Liaison & AVCP System Selection service handles this end to end. And since the AVCP system is defined within Annex ZA, our guide on how to read and interpret a harmonised standard can help you locate and interpret that section correctly.

contact@ceprocon.com  •  ceprocon.com