Labelling of construction products - a special case in product law: CE, Ü or no mark at all?
Construction products occupy a special position within European product regulation. If the products are covered by a harmonised standard (hEN) or if a European Technical Assessment (ETA) is issued, a Declaration of Performance (DOP) must be issued for the products in accordance with the EU Construction Products Regulation (new EU CPR (EU) 2024/3110).
If a DOP is issued, the construction products must be CE labelled. If neither of these requirements is met, the product may not bear a CE mark.
For construction products without a DOP and CE, national construction law applies. In Germany, the corresponding requirements can be found in the state building regulations, which refer to the Model Administrative Provisions for Technical Building Rules (MVV TB). In Germany, this can lead to labelling with the Ü mark and the issue of corresponding approvals (abZ, abP, ZiE).
Some simple construction products are not subject to either CE or Ü labelling. They may be subject to labelling symbols defined in standards and statutory minimum information, but no formal verification symbols.
In practice, this often leads to uncertainties. We at asseso support you in making the correct categorisation and give you clarity in the assessment of your products.
Constancy of performance – A Demanding Proof
Another key element in construction product law is proof of constancy of performance. This is not just about meeting minimum legal standards, but also about specific performance characteristics that are specified in standards depending on the intended use of the product - for ex-ample resistance, fire behaviour or thermal insulation.
As a rule, these properties must be verified by laboratory tests. The decisive factor is always the application for which the construction product is intended and suitable (installation situation). The information obtained is incorporated into the technical documentation, on the basis of which either a DOP (for harmonised construction products) or a corresponding approval is issued.
In many cases, notified bodies or accredited testing laboratories must be involved in the procedures in order to provide the evidence in a legally compliant manner.
asseso – Your Partner for Compliance, Testing, and Documentation
We support you throughout the entire process – whether for individual issues or as a full-service partner.
We review existing documents, organize and coordinate the necessary steps, commission testing, prepare technical documentation, and handle the marking of products and packaging. We also draft your Declaration of Performance or prepare a national certificate of usability.
In short: We bring your construction products to market in a legally compliant, safe, and traceable manner – with expertise, structure, and a deep understanding of the regulatory specifics in the construction sector.