Thermal insulation products placed on the EU market under the Construction Products Regulation must be CE marked according to the relevant harmonised standard for the material type, with declared values for thermal conductivity, reaction to fire, and other essential characteristics. CEProCon helps insulation manufacturers identify the correct standard and AVCP system, run the required testing, and prepare compliant Declarations of Performance.
Applicable Harmonised Standards
Thermal insulation products are CE marked under product-specific harmonised standards depending on the material: EN 13162 for mineral wool, EN 13163 for expanded polystyrene (EPS), EN 13164 for extruded polystyrene (XPS), EN 13165 for rigid polyurethane foam, and similar standards for other insulation materials. Each standard defines the test methods and essential characteristics that must be declared, including thermal resistance, reaction to fire, dimensional stability, and water absorption.
AVCP System: System 1, 3, or 4
The applicable Assessment and Verification of Constancy of Performance (AVCP) system for insulation products depends on the product’s reaction-to-fire classification. Products with a declared fire performance based on testing (rather than without further testing) typically fall under System 1 or System 3, requiring a notified product certification body or notified testing laboratory. Most standard insulation products fall under System 3, where a notified laboratory determines reaction-to-fire and other characteristics while the manufacturer maintains factory production control (FPC). System 4 applies where no third-party involvement is required and the manufacturer self-declares performance.
Documentation and Testing Requirements
Manufacturers must establish and maintain a factory production control (FPC) system, obtain initial type testing of essential characteristics from an accredited or notified laboratory, and prepare a Declaration of Performance (DoP) covering thermal resistance, reaction to fire, water absorption, and other declared properties. The CE marking, accompanied by the DoP reference, must appear on the product, packaging, or accompanying documentation. CEProCon helps insulation manufacturers manage testing schedules, FPC documentation, and DoP preparation.
Looking for more detail on harmonised standards? See our guide to harmonised standards under the CPR and how to find the right one for your products. If you’re unsure whether CE marking applies to your product, check does my product need CE marking? for a quick overview. Our Technical File & Declaration of Performance Preparation and CPR Compliance Audit & Gap Analysis services can help with the full compliance process.
Need help achieving CE marking for your insulation products? CEProCon supports manufacturers with standard selection, AVCP system determination, notified body coordination, thermal and fire performance testing, and full Declaration of Performance documentation.