Construction Products Regulation: transition period and how long the old rules apply
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
The Construction Products Regulation transition period runs per product family. Regulation (EU) 2024/3110 has applied since 8 January 2026 and replaces Regulation 305/2011 step by step. Article 94 repeals the articles of the old Regulation that continue to apply with effect from 8 January 2040. What decides for you is when new harmonised specifications apply to your product family.
Art. 94 and Art. 95(9) Regulation (EU) 2024/3110
The dates in order
These dates are confirmed:
- 7 January 2025: Regulation (EU) 2024/3110 enters into force.
- 8 January 2026: the Regulation applies.
- Per product family: the declaration of performance and conformity replaces the declaration of performance one year after the adoption of the implementing act on the new specification, or later (Article 95(9)).
- 8 January 2040: the articles of Regulation 305/2011 that continue to apply are repealed (Article 94).
- Product passport for construction products: by delegated act, date open. The duty applies 18 months after that act enters into force (Article 22(7), Article 80(1)).
Why the text says 2040 and the Commission page says 2039
The primary source is Article 94 of Regulation (EU) 2024/3110: the listed articles of Regulation 305/2011 “are repealed with effect from 8 January 2040”. The Commission’s page on the Regulation names 2039 instead, without giving a reason. We follow the text of the Regulation.
An earlier date often matters more to you. The new requirements and obligations apply per product family from one year after the adoption of the implementing act (Article 95(9)).
What this means for manufacturers
Until the new specifications apply to your product family, you keep working with the declaration of performance. After that you need the declaration of performance and conformity. So watch for the publication of new harmonised specifications for your families.
What you can do now
Prepare without guessing.
- Assign every product to a product family.
- Record which specification applies today.
- Check every quarter whether anything changes for your families.
- Keep declarations digitally, with version and date.
Frequently asked questions
Does Regulation 305/2011 still apply?
It is being replaced step by step. For product families that have no new specifications yet, the previous system remains decisive.
Is there a fixed end date?
Yes, for the repeal: Article 94 names 8 January 2040. The Commission page names 2039. The switch itself happens earlier, per product family.
When does the product passport for construction products come?
By delegated act; the date is open. The duty applies 18 months after that act enters into force (Article 22(7), Article 80(1)).
With ProofPass
The ProofPass deadline check (in German) shows the dates for your product group profile, each with the date of the last check. In the product passport module you enter which products are affected and see when something changes.
The terms and legal notices are in German, and the German version is binding.
Sources
As of 3 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.