MARMOTEST · TECHNICAL INSIGHTS

CE marking of construction products

From stone performance to supply documentation: what to check, who is responsible, and how to navigate CE and UKCA.

01 · When CE marking applies

  • Under Regulation (EU) 305/2011, the manufacturer draws up a declaration of performance when the product is covered by a harmonised standard or conforms to a European Technical Assessment (ETA) issued for that product, subject to the specified exemptions.
  • Always check the product, intended use and applicable technical reference. Being a construction material does not automatically make the requirement applicable.
  • The marking communicates the declared performance. Suitability for the works requires comparison with project requirements: loads, environment, safety and installation conditions.

02 · The European framework is changing gradually

  • The Regulation (EU) 2024/3110 entered into force on 7 January 2025; its main provisions apply from 8 January 2026.
  • The transition takes place by product family and harmonised specification: the two regulations coexist. For products still covered by standards cited under CPR 2011, that route generally remains applicable.
  • The new framework introduces the declaration of performance and conformity (DoPC), environmental characteristics and a future digital product passport. The application of individual obligations depends on the provisions and acts applicable to the product family.

03 · Documentation to check

  • Identity and traceability: manufacturer, product-type code and identification of the supply.
  • Declaration: DoP or DoPC according to the applicable regime, intended use and relevant technical reference.
  • Performance: declared values or classes for the required characteristics, consistent with the product and intended use.
  • Marking and accompanying information: CE information and instructions required under the applicable route.
  • Technical documentation: assessments, test reports and factory production control; involvement of a notified body where required by the applicable system. Technical documentation does not necessarily correspond to everything that must accompany each delivery.

Completing the DoP · practical outline

Summary of section 4.1 of the CONFORMA guide, referring to the route under Regulation (EU) 305/2011. Before using a template, check the regime applicable to the product during the transition to CPR 2024.

1 · Identify the DoP and the product

Assign a number to the declaration and a unique product-type code; ensure traceability.

2 · Define the intended use

State the use covered by the harmonised specification, consistent with the supply.

3 · Identify the manufacturer

Company name and address; include the authorised representative where relevant.

4 · Identify the technical reference

Harmonised product standard and version, or ETA and relevant references. The characteristics are derived from the harmonised part, rather than a generic list of tests.

5 · Enter the performance

List the essential characteristics for the intended use: give a value, class or NPD where permitted for each, together with the technical reference.

6 · Sign and accompany the supply

Name and position of the signatory, place, date and signature on behalf of the manufacturer; include instructions, safety information and REACH information where required.

NPD = No Performance Determined. This does not mean zero performance or a compliant product. It does not replace a mandatory performance declaration: consider the applicable requirements, intended use and destination market. Under the ETA route, the performance of the essential characteristics included in the assessment is declared.

The key point: the DoP concerns the essential characteristics of the harmonised specification. Any additional properties are communicated separately.

Historical note: sections 4.1.3 and 4.1.4 of the guide describe the CPD–CPR transition on 1 July 2013. They do not set out the rules for the transition to the new CPR 2024.

DoP example · slabs for internal floors and stairs

Example supplied for MARMO ESEMPIO · System 4. Select Explanation next to a field to open the note from page 25 of the guide. Text and values are reproduced as supplied; the signature and date remain to be completed.

DECLARATION OF PERFORMANCE

1. Unique identification code of the product type: 29617-240
2. Type, batch, serial number or any other element allowing identification of the construction product as required under Article 11 c4: 29617-240 - MARMO ESEMPIO
Fictitious material and origin: Example Quarry - Italy
3. Intended use or uses of the construction product, in accordance with the applicable harmonized technical specification, as foreseen by the manufacture: NATURAL SLABS USED AS INTERNAL FLOORING AND STAIRS
4. Name, registered trade name or registered trademark and contact address of manufacturer as required under Article 11 c5: PIETRE ESEMPIO S.R.L.
VIA DEL MARMO 100
54033 CARRARA (MS) - ITALY
Fictitious name and address, used solely for this example.
5. Where applicable, name and contact address of the authorized representative whose mandate covers the tasks specified in Article 12 c2: Not applicable
6. System or system of assessment and verification of constancy of performance of the construction product as set out in CPR, Annex V: System 4
7. In case of the declaration of performance concerning a construction product covered by a harmonized standard: EN 12058:2015
8. In case of the declaration of performance concerning a construction product covered by a European Technical Assessment has been issued: Not relevant

9. Declared performance

Essential characteristics Performance Harmonized technical specification
Resistance to fireClass A1EN 12058:2015
Breaking strength as flexural strength
- lower expected value
- mean value
- standard deviation

16.6 MPa
22.3 MPa
2.9 MPa
EN 12058:2015
Slip Resistance
- (SRV) Honed 180

61 Dry – 42 Wet
EN 12058:2015
Direct airborne sound insulation
- mean value

2850 Kg/m3
EN 12058:2015
Thermal conductivity - mean value3.5 W/(mK)EN 12058:2015
Water absorption at atmospheric pressure - higher expected value0.1 %EN 12058:2015
Open porosity - mean value0.4 %EN 12058:2015
Abrasion resistance
- mean value
- higher expected value

22.8 mm
24.0 mm
EN 12058:2015

10. The performance of the product identified in points 1 and 2 is in conformity with the declared performance in point 9. This declaration of performance is issued under the sole responsibility of the manufacturer identified in point 4.

Signed for and on behalf of the manufacturer by the managing directors:

First name Surname
Carrara, date
Signature: __________________

CONFORMA GUIDE · PAGE 25

Text from the 2013 guide. The letter reference relates to the original Figure 1a.

04 · What this means for natural stone

  • Identify the finished product and intended use: cladding, flooring, stairs or an external element each require a specific check of the product reference.
  • Select tests representative of the material and the characteristics relevant to the project; consider natural variations and conditions of use.
  • Compare declared performance with specification requirements. A test report alone does not complete the marking process.
  • Ensure consistency between tested samples, product designation and identification, technical documents and supply.

05 · Responsibilities and penalties in Italy

Italian Legislative Decree 106/2017 distinguishes operators’ obligations and the corresponding breaches. Articles 19 and 20 provide, among other things:

  • Manufacturer: failure to draw up a mandatory declaration: an administrative penalty of €4,000 to €24,000; for structural or fire-safety use, detention of up to six months and a fine of €10,000 to €50,000.
  • Contractor, works director, execution director and acceptance inspector: non-compliant use within their respective responsibilities: an administrative penalty of €4,000 to €24,000; for structural or fire-safety use, detention of up to six months and a fine of €10,000 to €50,000.
  • Designer: non-compliant specification: an administrative penalty of €2,000 to €12,000; for structural or fire-safety use, detention of up to three months and a fine of €5,000 to €25,000.

The specific circumstances, exemptions and applicable regime must be checked in the legislation. The amounts above concern the specified breaches, rather than every documentary irregularity.

06 · UKCA: the destination market matters

  • In Great Britain (England, Scotland and Wales), the official construction products guidance confirms recognition of CE marking; the UKCA route may also be used.
  • Where third-party assessment is required, the CE and UKCA routes refer to bodies recognised under their respective regimes.
  • The jurisdiction ofNorthern Ireland follows separate rules: check the dedicated guidance before supply.

07 · Before accepting a supply

  • Does the document identify the actual product to be delivered?
  • Does the intended use correspond to its use in the works?
  • Do the declared characteristics cover the project requirements?
  • Are the marking, declaration and documents consistent?
  • Have acceptance checks and traceability been defined?

Marmotest provides laboratory testing and technical support for the characterisation of dimension stone and review of product documentation.