Declaration of performance and conformity under the CPR: required fields and Annex V template

The declaration of performance is the document everything in construction product law hangs on. Without it, no product covered by a harmonised technical specification may be made available; with it, the manufacturer takes on liability for every declared figure. Regulation (EU) 2024/3110 leaves that principle untouched — but it changes the document’s name, its content and the route by which it reaches the recipient.

The declaration of performance becomes the declaration of performance and conformity. It follows a new model in Annex V, it carries environmental data as mandatory fields for the first time, and it may live inside a digital product passport instead of a PDF file. This article walks through the model field by field — and answers first the question that affects nearly every manufacturer in practice: whether any of it applies today.

Key takeaways

The old declaration of performance (DoP) and the CE declaration of conformity merge into one document: the declaration of performance and conformity, governed by Articles 13 to 16 of Regulation (EU) 2024/3110.
The model is set out in Annex V and consists of a header (manufacturer, declaration code, version number, date of that version) and eleven numbered blocks.
The Regulation has applied since 8 January 2026. But the obligations of economic operators bite for a product family only one year after the implementing act that makes the new harmonised technical specification mandatory for that family (Article 95(9)). Until then, the declaration of performance under Regulation (EU) No 305/2011 remains the right instrument for that product.
New and demanding: the declaration must state environmental performance over the life cycle — phased in on 8 January 2026, 9 January 2030 and 9 January 2032 — calculated with the free software provided by the Commission.
Supply is electronic, per product, or via a website under six conditions — or through the digital product passport. The passport is not an extra channel; it replaces individual supply.
Anyone providing the documents through the passport is released from the ten-year retention duty towards national authorities (Article 20(4)).
myDPP is not a notified body or a technical assessment body. We do not issue declarations and we do not carry out testing. We store, version and deliver the data the declaration is made of — and the data carrier that opens it.

Why the document changes its name

Under Regulation (EU) No 305/2011 there were two papers side by side. The declaration of performance stated what performance a product achieved for its essential characteristics. The CE marking and the associated conformity statement said the product complied with Union law. Two documents, two data sets, two version histories — and, in practice, two filing systems that drifted apart.

The new Construction Products Regulation brings them together. Article 13 knows only the declaration of performance and conformity. That is more than a rename: one document means one field set, one version number and one place it can live. This is exactly what Article 15(5) targets, empowering the Commission to amend the Annex V model so that it satisfies digital product passport requirements and interoperates with the construction digital product passport system.

The underlying mechanism is unchanged. By drawing up the declaration, the manufacturer assumes responsibility for the product’s conformity with its declared performance and any applicable product requirements, and becomes liable under Union and national law. In the absence of objective indications to the contrary, Member States must presume the declaration accurate and reliable. Where a declaration is required and missing, or where the product does not comply, the product may not be made available on the market.

When you actually need the new declaration

This question comes first because its answer sets the order of all the other work — and because it is regularly answered wrongly.

8 January 2026 is the date the Regulation applies and Regulation (EU) No 305/2011 is repealed. But the repeal is staged: Article 2, Articles 4 to 9, 11 to 18, 27 and 28, 36 to 40, 47 to 49, 52 and 53, Article 55 and Articles 60 to 64 of the old Regulation, together with its Annexes III and V, are repealed only with effect from 8 January 2040. Annex III is the model of the old declaration of performance. It therefore has fourteen more years to run.

The reason sits in Article 95. Paragraph 3 keeps harmonised standards whose references were listed under Article 17(5) of Regulation 305/2011 and in force on 8 January 2026 valid until the Commission withdraws them. Paragraph 8 confirms that the surviving articles of the old Regulation apply precisely to the products those standards cover. And paragraph 9 sets the decisive deadline:

The requirements and obligations of economic operators set out in Chapters I, II and III apply to a given product family or product category only from one year after the date of adoption of the implementing act making a harmonised standard mandatory or laying down common specifications for that family, unless a later date is specified in that act.

In practice: as long as no such implementing act has been adopted for your product family and a year has passed since, you continue to issue the declaration of performance under Annex III of Regulation 305/2011. Anyone who wants to move sooner may: Article 95(9) expressly allows economic operators to apply the new harmonised technical specifications from their entry into force and to run the procedure leading to a declaration of performance and conformity.

Two more transitional rules belong in the same plan. European assessment documents whose references were published by 8 January 2026 remain valid until 9 January 2031; products may not be placed on the market on the basis of European technical assessments issued under them after 9 January 2036. And certificates, test reports and ETAs from the old regime may be used as the technical basis under the new CPR where the product type corresponds and the requirements and assessment methods remain valid in the light of the applicable specification.

The right order of work follows on its own: first map your product list to families and their standardisation status, then rebuild the declarations — not the other way round.

Who does not have to draw one up

Article 14 provides two exemptions, and both are narrow.

The first covers individually manufactured or custom-made products. Four conditions must be met cumulatively: manufacture using a non-series process, production in response to a specific order, installation in a single identified construction work by a manufacturer who is also responsible for the safe incorporation of the product, and compliance with applicable national rules under the supervision of those designated as responsible for the safe execution of the works. If one condition falls away — because the manufacturer supplies but does not install, say — the exemption does not apply.

The second covers products manufactured exclusively for heritage conservation in a non-series process, to adequately renovate construction works officially protected as part of a designated environment or for their special architectural or historic merit, again in compliance with applicable national rules.

Relying on either exemption also removes the duty to undergo the applicable assessment and verification. That makes them attractive — and makes their boundaries a standard check in market surveillance.

The eleven blocks of the Annex V model

Annex V does not provide a fillable file; it prescribes a structure. The header names the manufacturer, the declaration code, the version number and the date of that version. Eleven blocks follow.

1. Product description

Eight items: unique identification code of the product type and, where available, the batch or serial number; product category as defined by the harmonised technical specification or European assessment document; declared uses within the scope of that specification; nominal dimensions or grading; key parts, where applicable; estimated average and minimum service life for the declared use; variants, if any, with descriptions; and — where the product was previously installed in a construction work — the date and place of the latest deinstallation.

The last two are new, and they reveal the direction of the Regulation: durability becomes a declared property, and reused construction products get a place in the system.

2. Permalinks or data carriers

For three groups of information a reference suffices instead of the full text — unless the information is already in the digital product passport under Article 76: the manufacturer’s product registrations in Union databases, information required under REACH Regulation (EC) No 1907/2006, and the general product information, instructions for use and safety information under Annex IV.

Here the Regulation hides its digital core: the data carrier is not an accessory to the declaration but part of its structure.

3 to 6. The parties

Four blocks, each with the same field set — name, registered trade name, registered place of business, postal address, telephone, email address, website:

manufacturer (block 3),
authorised representative, where applicable (block 4),
notified body or bodies, where applicable, plus identification number (block 5),
technical assessment body (TAB), where applicable, also with identification number (block 6).

Seven to eight mandatory fields per party, where a single line of name and address used to do. Anyone maintaining many declarations discovers here first that master data is not a text snippet.

7. Certificates and validation reports

Reference to the certificates or validation reports issued by notified bodies and TABs.

8. Technical reference documents

Either the harmonised technical specifications applied, with reference number and date of issue — or the European assessment document applied, with reference number and date of issue, plus the European technical assessment issued, with TAB, reference number and date of issue.

The date of issue is not a formality. A standard reference without a year is the single most frequent defect in conformity documents anywhere, because it ties the declaration to a moving target.

9. Declared performances and sustainability characteristics

The core of the document, with four requirements:

the complete list of essential characteristics determined in the specification for the product category and for which a performance is declared, together with the applicable assessment and verification system;
the performance itself, as calculated values, levels or classes, or as a description. Values, levels and classes must be reproduced in the declaration itself and cannot be expressed solely by reference to other documents. Where no performance is declared, the word “NULL” must be inserted. Only structural behaviour may be expressed by reference to attached production documentation or structural design calculations;
the environmental sustainability for the applicable essential characteristics of the applicable life cycle modules, in accordance with Article 15(2);
a reference to the version of the software provided by the Commission and used for the calculation.

10. Product requirements

The product requirements specified by harmonised technical specifications, the assessment and verification system applicable to them and the reference to the voluntary harmonised standard or common specifications applied, including the date — and, where applicable, the performance of the product measured against those requirements.

11. Declarations

Three statements: that the performance of the product is in conformity with the declared performances under point 9, that the sustainability data have been correctly calculated on the basis of the applicable product category rules, and that the product conforms to the requirements listed under point 10.

Below that, the signature for and on behalf of the manufacturer, with name, function, place and date of issue. The person signing must be authorised under national law to represent the manufacturer, either on the basis of a mandate or by virtue of their role as legal representative.

Two Annex V footnotes that matter in practice: where no product requirements from delegated acts under Article 7(1) apply to the product, point 10 and point 11(c) are omitted. And only one unique, unequivocal declaration code may be used per product type, even where variants exist — variants being variations that do not influence performance or conformity. Different versions of the same declaration are expressly foreseen, for instance to correct mistakes or add complementary information.

In addition, Article 15(4) prohibits any marking other than the CE marking on the declaration. Test logos, quality marks and association logos do not belong on the document. And under Article 15(6), the information referred to in Article 31 or 33 of REACH must be provided together with the declaration — the bridge to the notification duty in the SCIP database.

Template: what the structure looks like

DECLARATION OF PERFORMANCE AND CONFORMITY
under Article 15 and Annex V of Regulation (EU) 2024/3110

Manufacturer:            Example Building Materials Ltd
Declaration code:        EBM-DOPC-0042
Version:                 3
Date of that version:    5 September 2026

1. PRODUCT DESCRIPTION
   Product type code:    EBM-WD-035-100
   Batch/serial:         see print on the packaging
   Product category:     <per harmonised technical specification>
   Declared use:         thermal insulation, external wall, rendered
   Nominal dimensions:   1000 x 500 x 100 mm
   Key parts:            not applicable
   Service life:         average <years> / minimum <years>
   Variants:             thicknesses 60 to 200 mm, same formulation
   Previous deinstall.:  not applicable (new product)

2. PERMALINKS / DATA CARRIERS
   Union databases:      <permalink>
   REACH information:    <permalink>
   Instructions (Ann.IV):<permalink or data carrier>

3. MANUFACTURER        name, trade name, place of business, address,
                       telephone, email, website
4. AUTH. REPRESENTATIVE not applicable
5. NOTIFIED BODY       name, ID number, place of business, address,
                       telephone, email, website
6. TAB                 not applicable

7. CERTIFICATES / VALIDATION REPORTS
   <number, issuing body, date>

8. TECHNICAL REFERENCE DOCUMENTS
   <specification, reference number, date of issue>

9. DECLARED PERFORMANCES AND SUSTAINABILITY CHARACTERISTICS
   Characteristic             | Performance | System
   <complete list>            | <value>     | <1, 1+, 2+, 3, 4>
   characteristics not declared| NULL       |
   Environmental (Annex II)   | <values per life cycle module>
   Software version:          <version of the Commission software>

10. PRODUCT REQUIREMENTS
    <requirement, system, standard applied with date>

11. DECLARATIONS
    (a) performance conforms to the performances declared under 9
    (b) sustainability data correctly calculated per category rules
    (c) product conforms to the requirements under 10

Signed for and on behalf of the manufacturer by:
[name, function]
At <place>, on 5 September 2026
Signature: ______________________

The angle brackets are deliberately left open. They mark the fields that cannot be copied from a template but come from the specification, the test report and the calculation.

The environmental data: the genuinely new part

Until now the environmental product declaration was a voluntary document, produced when a building certification scheme or a contracting authority asked for one. Article 15(2) makes it a mandatory field of the declaration — and even prescribes the calculation tool.

What must be declared is environmental performance over the life cycle for the predetermined environmental essential characteristics of Annex II, for those characteristics that are declared. The calculation expressly covers the packaging used or most likely to be used, and must use the latest version of the software made available free of charge on the Commission’s website. Updates of that software become mandatory one year after publication; they may be applied voluntarily from the date of publication.

The scope grows in three stages. Annex II lists nineteen characteristics from (a) to (s):

From	Annex II characteristics
8 January 2026	(a) to (d): climate change effects — total, fossil, biogenic, land use and land use change
9 January 2030	(e) to (m): ozone depletion, acidification, eutrophication (freshwater, marine, terrestrial), photochemical ozone, abiotic depletion (minerals/metals and fossil fuels), water use
9 January 2032	(n) to (s): particulate matter, ionising radiation, freshwater eco-toxicity, human toxicity cancer and non-cancer, land use related impacts

To this are added those essential characteristics which must always be declared under delegated acts adopted pursuant to Article 5(5). And harmonised technical specifications are to cover, as far as possible, the capability to temporarily bind carbon and other carbon removals.

Note the interaction with the transitional rules: stage (a) to (d) from 8 January 2026 bites for a specific product only once the obligations of Chapters I to III apply to its product family at all. For most manufacturers the phased dates are therefore a planning horizon, not a deadline. Building the data foundation is not — anyone who starts collecting primary data from raw material and energy suppliers only when the implementing act arrives has already spent the one-year transition. Our guide to calculating the product carbon footprint describes where that work begins.

Supply: electronic, website or passport

Article 16 governs the route to the recipient, and it knows three variants.

First, the default rule. The manufacturer supplies by electronic means a copy of the declaration for each product made available on the market. Where a batch of the same product goes to a single user, one copy for the batch is enough.

Second, the website route. By way of derogation, the declaration may be made available on a website — but only if the manufacturer meets all six conditions:

the content is available in an unamendable electronic format;
the declaration is human- and machine-readable, with the option to download a copy in a commonly readable format;
the website is monitored and maintained so that it and the declarations are continuously available to recipients;
access is free of charge for recipients;
recipients receive instructions on how to access the website and the declarations;
there is a link between the product and the declaration through the unique identification code of the product type — a data carrier, including a permalink, may be used for this, provided condition 1 is met.

Condition 2 is where an uploaded PDF stops being sufficient: machine-readability means structured data, not searchable text. Article 16(3) allows the Commission to request guidelines from the European standardisation organisation on the interoperability of these formats.

Third, the digital product passport. The duty of individual electronic supply falls away where the declaration is included in a digital product passport that fulfils the conditions of Article 76 and is available through the construction digital product passport system established under Article 75. The passport is therefore not an additional channel alongside delivery; it is its substitute.

Languages. All three variants are subject to Article 16(4): the declaration must be provided in the language or languages required by each Member State in which the manufacturer intends to make the product available. Where another economic operator makes the product available in an additional Member State, that operator must provide the translation — together with the respective original version. For manufacturers selling across Europe, this is the reason to keep declarations as a data set rather than a document: what gets translated is field values, not layouts.

Retention — and how the passport dissolves it

Article 20(4) requires every economic operator to keep all documents and information referred to in that Chapter at the disposal of competent national authorities for ten years after supplying or being supplied with the product. The rider is the real news: unless the documents or information have been made available through the digital product passport referred to in Article 76.

The Regulation has thereby converted an administrative duty into a data duty. Whoever runs the passport no longer needs a ten-year document archive — they need to keep the passport available. Article 76 requires for that purpose that the system remain accessible for twenty-five years after the last product of the type was placed on the market, and that the economic operator make the passport available for at least ten years.

For construction products the arithmetic is particularly favourable: their service life is measured in decades, and deconstruction happens long after the company file share has been migrated three times. How such a data foundation is built is the subject of DPP and PIM.

Six mistakes that make a declaration worthless

Standard reference without a date of issue. Annex V point 8 requires reference number and date of issue. Without the date it is unclear which version was tested against.
An empty field instead of “NULL”. Where no performance is declared, “NULL” must be inserted. An empty field is not a declaration; it is a gap.
Performance values only as a reference. Values, levels and classes must appear in the declaration itself. Structural behaviour is the sole exception.
Several declaration codes for one product type. Variants share the code. Assigning a new code per variant destroys the link between product and declaration on which Article 16(2)(f) relies.
Third-party logos on the document. Article 15(4) allows no marking other than the CE marking.
A signature without authority to bind. The signatory must be able to represent the manufacturer under national law. That is not a formality but the basis of the assumption of liability under Article 13(2).

Five steps from declaration to data model

1. Map product families and their dates

A list of every product, mapped to product families, to the harmonised standards in force today and to the drafting status of the new specifications. It answers, for each product, whether Annex III of the old Regulation or Annex V of the new one applies today.

2. Build the Annex V fields as a data model

Not as a document template but as a structure: header, eleven blocks, the field list per block. Declaration code and version number become key fields with their own assignment rule.

3. Clean up the master data of the parties

Four blocks with seven to eight fields per party. Notified bodies and TABs come with identification numbers. This data rarely changes, but it appears in every declaration — one error multiplies.

4. Set up the environmental calculation as a repeatable process

Collect primary data from raw material and energy suppliers, calculate with the Commission software, document the software version and version the results. A change of formulation or a different electricity mix produces new values — and therefore a new version of the declaration.

5. Decide the supply route

Individual electronic supply, website under six conditions, or the passport. That decision determines the technical work: the website route demands machine-readability and continuous availability, the passport demands an identifier and a data carrier but relieves you of retention. Our DPP implementation checklist works through the sequence.

Frequently asked questions

Is there an official template to download?

No. Annex V of Regulation (EU) 2024/3110 prescribes a structure — a header plus eleven numbered blocks — not a fillable file. The declaration must be drawn up “using the model set out in Annex V”; format and tooling are the manufacturer’s choice.

Do I have to switch to the new declaration from 8 January 2026?

For most products, no. The obligations of Chapters I to III apply to a product family only one year after the implementing act that makes the new harmonised technical specification mandatory for that family. Until then, the declaration of performance under Annex III of Regulation (EU) No 305/2011 remains the right route — its Annexes III and V are repealed only with effect from 8 January 2040.

Does the digital product passport replace the declaration?

No. It replaces its delivery. The duty to draw the declaration up and the manufacturer’s liability are unchanged. Where the declaration sits in the passport and is available through the construction passport system, individual electronic supply under Article 16(1) falls away — and so, under Article 20(4), does the ten-year retention for the benefit of national authorities.

Is a PDF on my own website enough?

Only if all six conditions of Article 16(2) are met. The second requires a human- and machine-readable format plus a downloadable copy. A plain PDF generally does not satisfy machine-readability.

Do I need a separate declaration for each variant?

No. Exactly one unique declaration code must be used per product type, even where variants exist — as long as they do not influence performance or conformity. Variants are described in block 1(g).

Who signs?

A person authorised under national law to represent the manufacturer, either by mandate or as legal representative. Name and function, place and date of issue must be stated.

What about products with no harmonised technical specification?

A manufacturer may issue a declaration of performance and conformity on the basis of a European assessment document and a European technical assessment. There is no obligation to do so.

Can myDPP issue the declaration for me?

No. The manufacturer issues the declaration and carries the liability. myDPP holds the Annex V fields as a versioned data set, links them to the product through the unique identification code and serves them through a data carrier and an API — human- and machine-readable.

Sources

Regulation (EU) 2024/3110 — construction products — EUR-Lex (Articles 13 to 16, Article 20, Articles 94 and 95, Annexes II and V)
Regulation (EU) No 305/2011 (repealed in stages) — EUR-Lex
Regulation (EC) No 1907/2006 (REACH) — EUR-Lex