Old safety approvals on building products are expiring

Many building products in Europe are certified under technical approvals that are now being phased out. New EU rules replace the old system step by step. Manufacturers can no longer use the oldest approvals when they place new CE-marked products on the market. Here is what that means for your suppliers and your paperwork.

The transition to the revised European regulatory framework for construction products is now active, altering the technical baselines required for CE marking. Regulation (EU) 2024/3110 of the European Parliament and of the Council, adopted on 27 November 2024 [3] and published in the Official Journal of the European Union on 18 December 2024 [3], repeals the previous Construction Products Regulation, Regulation (EU) No 305/2011 [1]. According to the Deutsches Institut für Bautechnik (DIBt) FAQ guidance last updated February 2026, the revised regulation entered into force on 7 January 2025 and has been generally applicable since 8 January 2026 [2]. Under this regulation, manufacturers and other economic operators are required to provide a declaration of performance and conformity for construction products [3].

This regulatory shift has immediate consequences for European Technical Assessments (ETAs). Under the previous 2011 framework, manufacturers used ETAs to secure CE marking for products not covered by fully harmonised European standards. Many of these older assessments were based on European Technical Approval Guidelines (ETAGs). Under the new rules, this pathway is closed. Manufacturers can no longer use ETAG-based ETAs as a basis for the declaration of performance and CE marking [2] [3].

For ETAs based on European Assessment Documents (EADs) that have not yet been cited in the Official Journal, the regulation provides a conversion mechanism. These assessments are converted into CPR 2024 assessment requests, at no cost to the manufacturer under Article 95(6), and can be re-issued [2] [3]. However, if an ETA is based on an EAD that was cited under the 2011 Construction Products Regulation, it can regularly be used as a basis for the declaration of performance and CE marking until 9 January 2036 [2] [3]. This ten-year transition window offers stability, provided the ETA is based on an EAD cited in the Official Journal under the 2011 regulation [2] [3]. The timeline has two steps: according to the DIBt, EADs cited under the 2011 regulation can still be used to issue new ETAs until 9 January 2031, while existing ETAs based on them remain usable until the 2036 cut-off [2].

Under the revised regulation, ETAs will incorporate “predetermined environmental essential characteristics,” which are selected sustainability indicators aligned with EN 15804 [2]. However, these EN 15804 sustainability indicators are being introduced step by step and are not yet mandatory for ETAs based on EADs under the 2011 Construction Products Regulation [2]. This gradual integration means that while environmental performance is becoming a core part of the technical baseline, the immediate compliance requirements vary depending on the underlying assessment document.

The European Commission is implementing these changes through a structured timeline. Under the new regulation, the Commission had a legal obligation to publish its first working plan covering the years 2026 to 2029 no later than 8 January 2026 [1]. The Commission met this requirement by publishing its Communication on 16 December 2025, under document reference COM(2025) 772 final [1]. This working plan outlines the priority product families that will be targeted for regulatory updates.

These priority families cover a wide range of high-volume materials. They include aggregates (AGG), curtain walling, cladding, structural sealant glazing, fixed fire fighting equipment (FFF), road construction products (RCP), floorings (FLO), building kits, units, prefabricated elements (KAS), internal and external wall and ceiling finishes (WCF), gypsum products (GYP), structural bearings (SBE), and space heating appliances (SHA) [1].

According to the DIBt, a digital product passport system will be established under CPR 2024 to contain the declaration of performance and conformity alongside other technical documentation [2]. This system will be instituted by a separate delegated act of the Commission and will become mandatory 18 months after that act is established [2].

To manage this transition smoothly, procurement directors can take several practical steps to verify compliance across their inventory.

First, review current inventory against the priority product families listed in the Commission’s working plan of 16 December 2025 [1]. Focus initial efforts on high-volume categories like aggregates, floorings, and gypsum products [1]. Identifying which product categories are subject to the working plan allows procurement teams to prioritize their supplier outreach.

Second, verify the technical basis of the CE marks with manufacturers. Specifically, confirm whether their ETAs are based on older ETAGs or newer EADs. If they rely on ETAGs, manufacturers can no longer use them as a basis for the declaration of performance and CE marking when placing new products on the market. Asking for a clear timeline on how and when they will transition to the newer standards helps ensure continuity of supply.

Third, update procurement templates and agreements. Ensure that future contracts prompt manufacturers to provide the necessary environmental indicators as they become mandatory, and prepare for the eventual integration of digital product passport data.

[1] single-market-economy.ec.europa.eu — https://single-market-economy.ec.europa.eu/document/download/cad28304-4b49-4396-81a8-6a816d8f1a93_en [2] dibt.de — https://www.dibt.de/en/service/faqs/transitional-rules-for-the-eta-route [3] eur-lex.europa.eu — https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng