CE Marking Is Being Rebuilt — The New EU Construction Products Regulation and the Digital Product Passport

What has changed

The Construction Products Regulation that has governed CE marking since 2011 — Regulation (EU) 305/2011 — has been replaced by Regulation (EU) 2024/3110, which entered into force in January 2025. The replacement is not a tidy-up. It rebuilds how construction products are declared, moves environmental performance into the mandatory information set, and introduces a Digital Product Passport for construction products.

The transition is deliberately long. Existing harmonised standards and declarations of performance made under the old regime remain valid through an extended transitional period while new harmonised technical specifications are developed and adopted product family by product family. The honest summary for a stone exporter: nothing breaks this year, and everything changes over the next several.

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Refresher — what CE marking actually means for stone

Worth restating, because it is misunderstood on both sides of most transactions. CE marking is not a quality mark, and it is not a statement that the stone is good. It is a declaration that the manufacturer has tested the product against a harmonised European standard and is publishing the resulting performance values in a Declaration of Performance. A slab with mediocre flexural strength can be perfectly and legally CE marked — the mark says the number is declared and true, not that it is high.

Where a harmonised standard exists for the intended use, the DoP and the marking are mandatory for placing the product on the EU market. The stone-relevant product standards are:

• EN 1469 — slabs for cladding
• EN 12058 — slabs for floors and stairs
• EN 12057 — modular tiles
• EN 1341 / EN 1342 / EN 1343 — external paving slabs, setts and kerbs
• EN 771-6 — natural stone masonry units

Those sit on top of the test standards that generate the declared values: EN 1936 for density and open porosity, EN 12372 or EN 13161 for flexural strength, EN 14157 for abrasion resistance, EN 12371 for frost resistance, EN 14231 for slip resistance, EN 12407 for petrographic examination, and EN 12440 for the commercial denomination that stops a trader quietly renaming your stone.

The Digital Product Passport

The headline addition in the new regulation is a machine-readable product passport, reached through a data carrier on or with the product, holding its identification, its declared performance and — increasingly — its environmental data. The intent is that a specifier, a contractor, a building-passport database and a demolition contractor twenty years from now can all read the same authoritative record, rather than hunting for a PDF that no longer exists on a website that no longer exists.

The detailed mechanics arrive through implementing acts and the new harmonised specifications rather than all at once, and stone is not first in that queue. What is not delayed is the buyer-side behaviour: large European contractors and facade specialists have already started asking for structured, machine-readable product data, because their own digital handover obligations require it regardless of whether stone is formally in scope yet.

Environmental performance stops being voluntary

The other substantive change is that environmental sustainability characteristics — global warming potential across the product life cycle among them — move into the mandatory declared set as the new harmonised specifications are adopted, instead of living in a voluntary Environmental Product Declaration that only sustainability-minded clients ever requested.

Practically, that turns the EPD work many producers have been deferring into the foundation of a compliance obligation rather than a marketing asset. Producers who already hold life-cycle data — energy per square metre through quarry, saw, calibration and polish, plus transport — are converting it into declarations in weeks. Producers starting from no data at all are looking at a much longer project, and their competitors will finish it first.

What a non-EU producer specifically needs to sort out

• Who the manufacturer is, legally. If you produce outside the EU and want your name on the marking, you generally need an authorised representative established in the Union. If you do not appoint one, the obligations — and the commercial control that comes with them — sit with your importer.
• Initial type testing. The declared values must come from testing under the relevant harmonised standard. Use a laboratory whose reports European customers will accept; a domestic test report on a non-standard method will be rejected.
• Factory production control. A documented FPC system is required, and it is the part most often missing. It need not be elaborate, but it must exist on paper and match what actually happens in the plant.
• The right AVCP route. The assessment and verification path varies by product and intended use — some cases are manufacturer self-declaration, others require a notified body. Confirm which applies to your product rather than assuming the lightest one.
• Technical documentation retention. Keep the file for the period the regulation requires — a decade is the right planning assumption — and keep it retrievable, not in a drawer at the quarry.

A readiness checklist

• List every product you sell into the EU and identify the harmonised standard for each intended use.
• Check that your current DoPs are complete, current, and issued per product — not one generic document covering the whole catalogue.
• Confirm your EN 12440 denomination — commercial name, petrographic family, colour, origin — and use it consistently across listings and documents.
• Get or refresh test data for the properties your customers actually specify: flexural strength, water absorption, frost resistance, slip.
• Start collecting energy and transport data per square metre now, whether or not you have commissioned an EPD.
• Decide whether you will appoint an authorised representative or leave the obligations with importers — and price that decision.
• Ask your three largest EU customers what product data format they will require in two years, and build to that answer rather than to your own guess.

Why this is an opportunity, not a burden

Regulatory transitions redistribute market share. Every large European project already filters its supplier list on documentation, and the filter is getting narrower and more automated. A quarry that can hand over a complete, current, machine-readable performance and environmental record is not merely compliant — it is shortlisted, in a market where many of its competitors will spend the transition arguing that the paperwork is unreasonable. On LithoPrime, vendors who publish full specifications and certification documents on their profiles consistently receive more qualified enquiries than those who wait to be asked.

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Further reading

• Regulation (EU) 2024/3110 on EUR-Lex — the regulation text, including the transitional provisions.
• European Commission — Construction Products Regulation — implementation status and guidance.
• NANDO database — notified bodies by product and standard.
• CEN — the standards bodies developing the new harmonised specifications.
• EPD International — registry and programme rules for Environmental Product Declarations.

Implementation of the new CPR is phased through implementing acts and newly adopted harmonised specifications, and dates shift. Confirm the current position for your specific product family with the Commission, your notified body or a compliance adviser before making decisions.