CEPROCON.COM • BLOG ARTICLE • WEEK 9

The CE marking process for construction products: a step-by-step overview

From first assessment to affixing the mark — the complete picture

CE marking a construction product is not a single action — it is a process. It involves a sequence of interconnected steps, each of which must be completed correctly before the next can begin. Miss a step, get one wrong, or do them in the wrong order, and the resulting CE mark rests on an unstable foundation that could unravel under scrutiny.

This article provides a clear, end-to-end overview of the CE marking process for construction products under the Construction Products Regulation (CPR). Whether you are a manufacturer beginning the journey for the first time, or a professional looking to understand the full picture before advising clients, this is the map you need.

The process described here follows the harmonised standard (hEN) route — the most common pathway. Where the EAD/ETA route differs, those differences are noted.

The process at a glance

Step	Stage	What it involves
1	Determine whether CE marking applies	Confirm the product is a construction product; identify whether a harmonised standard or EAD/ETA route applies; verify the mandatory date.
2	Identify the applicable harmonised standard	Find the correct hEN, confirm version currency in the OJEU, and read the scope clause to confirm applicability.
3	Read Annex ZA and identify essential characteristics	Establish which characteristics must be assessed, which AVCP system(s) apply, and whether a Notified Body is required.
4	Engage a Notified Body (if required)	Select and contract an appropriate Notified Body for the applicable AVCP system. Verify scope via NANDO.
5	Carry out type testing	Test the product against all relevant essential characteristics using the methods specified in the standard.
6	Establish Factory Production Control (FPC)	Set up and document the internal production control system required by the harmonised standard.
7	Complete AVCP tasks with Notified Body	Notified Body conducts FPC assessment, issues certificate (systems 1+, 1, 2+) or test report (system 3).
8	Draw up the Declaration of Performance	Prepare the legally compliant DoP based on all assessment results and Notified Body documentation.
9	Affix the CE mark	Apply the CE mark and accompanying information to the product, packaging, or accompanying documents.
10	Maintain compliance over time	Keep the FPC operating, the DoP current, and documentation updated as products or standards change.

Step 1: Determine whether CE marking applies

The first question is whether CE marking under the CPR applies to your product at all. This means confirming that the product is a construction product — permanently incorporated into construction works — and that a harmonised standard or EAD covers it.

If a harmonised standard exists and its co-existence period has ended, CE marking is mandatory. If the standard is in co-existence, it is voluntary but increasingly expected by buyers. If no harmonised standard exists, the EAD/ETA route may be available for innovative products. And if neither applies, CE marking under the CPR is not required.

Getting this determination right before investing in testing and documentation is essential. Applying CE marking to a product that is out of scope is prohibited; failing to apply it to a product within scope is a legal breach.

Step 2: Identify the applicable harmonised standard

Once CE marking is confirmed as applicable, the next task is to identify the correct harmonised standard — and the correct version of it. Check the OJEU for the current listing, obtain the standard from your national standards body, and read Clause 1 (Scope) carefully to confirm your product and its intended use fall within it.

Some products are covered by multiple standards, or by a family standard with several parts. Some standards cover a broad product category with different AVCP requirements for different sub-types. All of this must be established before moving on.

Step 3: Read Annex ZA and identify essential characteristics

With the correct standard confirmed, go directly to Annex ZA. This is the CE-marking-specific annex that lists the essential characteristics your product must be assessed against, the AVCP system(s) that apply to each, and what the CE mark label must show.

From Annex ZA, establish:

The full list of essential characteristics to be assessed for your intended use
The AVCP system(s) assigned to each characteristic
Whether a Notified Body is required, and if so, what type
Which clauses of the standard contain the test methods or assessment procedures for each characteristic

This step is the foundation of the entire project plan. The AVCP system determines the cost, timeline, and the parties involved. It is worth taking time to get this right.

Step 4: Engage a Notified Body (where required)

If the AVCP system requires a Notified Body — systems 1+, 1, 2+, or system 3 for specific characteristics — this engagement must happen before type testing begins (for systems 1+ and 1) or before FPC certification can proceed (for system 2+).

Select a Notified Body whose NANDO scope explicitly covers your harmonised standard, obtain a quotation, agree timelines, and formalise the engagement. Do not begin testing under systems 1+ or 1 without the Notified Body’s involvement — test results obtained without the required Notified Body participation are not valid for CE marking purposes.

For products being CE marked via the EAD/ETA route, Notified Body involvement may similarly be required depending on the AVCP system specified in the EAD. Note also that in this route, the Technical Assessment Body (TAB) responsible for developing the EAD and issuing the ETA is a distinct body from any Notified Body subsequently involved in AVCP.

Step 5: Carry out type testing

Type testing is the process of assessing the product’s performance against the essential characteristics using the methods specified in the harmonised standard. Depending on the AVCP system, this is carried out by the manufacturer’s own (or an independent) laboratory, or by a Notified Testing Laboratory.

Key points to manage during type testing:

Use the correct test standard for each characteristic — referenced in the harmonised standard and confirmed as the current version.
Ensure samples tested are representative of the product as manufactured — not a specially prepared prototype that does not reflect production reality.
Retain all test reports, including raw data where available — these are part of the technical documentation that supports the DoP.
Where results fall short of the performance level the manufacturer intended to declare, address the issue at this stage — either by modifying the product or adjusting the declared performance level — before proceeding.

Step 6: Establish Factory Production Control

Factory Production Control (FPC) is the manufacturer’s internal quality system for ensuring that the product continues to be manufactured consistently with the product type that was tested. It is required under all AVCP systems — even system 4, where no Notified Body is involved.

An FPC system typically includes:

Written procedures for all production steps that affect product performance
In-process and finished product inspection and testing records
Raw material and component controls
Equipment calibration and maintenance records
Non-conformance handling and corrective action procedures
Traceability records linking each batch of product to its production and test records

The specific requirements for FPC are set out in the harmonised standard. For products under systems 1+, 1, or 2+, the FPC must be ready for audit before the Notified Body can issue its certificate.

Step 7: Complete AVCP tasks with the Notified Body

For products under systems 1+, 1, 2+, and 3, the Notified Body now completes its assigned tasks — conducting or reviewing type tests, auditing the FPC, and issuing the relevant certificate or test report.

The documents issued at this stage are:

System 1+ and 1: a Certificate of Constancy of Performance, issued by the Notified Product Certification Body.
System 2+: a Certificate of Conformity of the FPC, issued by the Notified Inspection Body.
System 3: test report(s) from the Notified Testing Laboratory.

These documents are essential inputs for the Declaration of Performance. The certificate or test report reference(s) must be included in the DoP. Keep originals securely and include copies in the technical file.

Step 8: Draw up the Declaration of Performance

With type testing complete and — where applicable — Notified Body documentation in hand, the manufacturer draws up the Declaration of Performance. This is the legal document through which the manufacturer formally declares the product’s assessed performance and takes responsibility for it.

The DoP must include:

A unique identification code for the DoP
A clear description of the product type and its intended use
The harmonised standard or EAD reference
The applicable AVCP system
The Notified Body name and number, and the certificate or test report reference (where applicable)
A declared performance table listing each essential characteristic and its assessed performance value or class

The DoP must be provided in the language(s) required in each market where the product is sold, and must be retained for ten years after the product is placed on the market.

Step 9: Affix the CE mark

Once the DoP has been drawn up, the manufacturer can affix the CE mark. The CE mark may be placed on the product itself, on its packaging, or on an accompanying document — the harmonised standard’s Annex ZA.3 specifies which information must accompany the mark.

The CE marking must be accompanied by:

The last two digits of the year in which it was affixed
The manufacturer’s name, registered trade name, or registered trademark, and contact address
The unique identification code of the product type (where applicable)
The reference number of the DoP
The four-digit identification number of the Notified Body (where applicable)
The declared performance for each essential characteristic, as applicable to the product’s intended use

The CE mark must not be affixed before the DoP is drawn up. Affixing CE marking without a valid DoP, or without the required Notified Body involvement, constitutes a serious regulatory breach.

Step 10: Maintain compliance over time

CE marking is not a one-time event. Once the mark has been affixed, a set of ongoing obligations begins. Many manufacturers underestimate this phase — and it is where compliance tends to quietly deteriorate.

Ongoing obligations include:

Keeping the FPC system operational and properly documented at all times
Cooperating with Notified Body surveillance audits (for systems 1+, 1, and 2+)
Reviewing the DoP whenever the product changes in a way that could affect its performance, and issuing a revised DoP where necessary
Monitoring the OJEU for revisions to the applicable harmonised standard, and updating testing, FPC, and documentation accordingly when a revised standard becomes mandatory
Retaining all technical documentation for ten years after each product is placed on the market
Cooperating with market surveillance authorities if they request access to documentation or samples

How the EAD / ETA route differs

For products without an applicable harmonised standard, the EAD/ETA route follows broadly the same logic but with some important differences:

Step 2 is replaced by an application to a Technical Assessment Body (TAB) for a European Technical Assessment. The TAB develops an EAD specific to the product, which then serves the same function as a harmonised standard’s Annex ZA — defining essential characteristics and the applicable AVCP system.
The TAB is distinct from any Notified Body subsequently involved in AVCP. Both may be required in the same project.
The EAD process is significantly more time-consuming and expensive than the harmonised standard route. Timelines of one to three years from application to ETA issuance are not uncommon.
The DoP references the ETA rather than a harmonised standard, and the ETA number and issuing TAB are included in the CE marking information.

Summary

CE marking a construction product involves ten distinct stages, from determining whether CE marking applies all the way through to maintaining compliance after the mark has been affixed. Each stage depends on the previous one. Skipping steps, taking shortcuts, or treating CE marking as a one-time administrative task rather than an ongoing compliance programme are the most common routes to regulatory exposure.

The process is manageable — but it requires the right knowledge, careful planning, and disciplined documentation. The upcoming articles in this series will cover each stage of the process in greater technical depth.

Looking for expert guidance on any stage of the CE marking process?

CEProCon supports manufacturers at every stage — from the initial scope determination through to DoP preparation and ongoing compliance management. We also deliver professional training for those building expertise in the full CE marking process for construction products.

contact@ceprocon.com • ceprocon.com