Custom software for the Construction Products Regulation and CE marking
With the declaration of performance, you take responsibility for how your product performs. It relates to one product type, one version of the standard and one assessment system, and it may need to be produced years later. It is usually stored as a PDF in a folder nobody dares to touch.
What the regulation requires of you
The rules are set out in Regulation (EU) No 305/2011, known in the Netherlands as the construction products regulation. Article 4: if your product falls under a harmonised standard or a European Technical Assessment, you must draw up a declaration of performance when placing it on the market. Article 8 links the CE marking to this: if no declaration has been drawn up, the marking may not be affixed. The Besluit bouwwerken leefomgeving, article 2.13, requires you to provide the declaration in the Dutch language.
A successor is in place. Regulation (EU) 2024/3110 of 27 November 2024 entered into force on 7 January 2025 and applies from 8 January 2026. It calls the document the performance and conformity declaration and repeals the old regulation on that date, with a long tail: the articles on the declaration, the marking and the obligations of economic operators continue to apply until 8 January 2040 for products covered by the old standards.
The transition proceeds by product family: the new obligations start only one year after the implementing act for that family is adopted. For a time you will therefore have two kinds of declaration in the same warehouse, the new ones also containing environmental characteristics. If you manage them as loose files, that distinction is nowhere visible; if you manage them as data, you can show per product type which standard and which system apply.
How we build this
A declaration is not a file but an outcome: of a product type, a standard and an assessment. We build that chain and let the document follow from it.
Not with the article number in your order system. The product type is the unit the regulation speaks about.
Type testing, test reports, the certificate from the notified body and the standard with its version. Without that reference, a declaration is merely an assertion.
A new version of a standard or a changed composition calls for a new declaration. The old one stays in place, because the products supplied under it still exist.
Every customer must be able to access it, in the language of the Member State where you supply. That is a publication matter, not an email matter.
What the software actually does
A register of product types with their supporting evidence holds the whole together. What else you need depends on the number of types and the countries you sell in.
Declaration per product type and version
Each declaration relates to one product type, with its intended use, essential characteristics and performance. If anything changes, a new version is added.
Type testing and certificates underneath
Test reports, type calculations and the notified body's certificate, with their validity. In an inspection, this is exactly what is asked for.
The standard and system alongside
The reference number of the harmonised standard or assessment document, with the corresponding system from the annex. That determines where a notified body comes into the picture.
Providing it to your customers
The declaration may be published on a website, provided it is tamper-proof, free of charge, machine-readable and linked to the unique identification code of the product type. We build that publication, or a wider portal drawing on the register.
Retention period and validity
Documentation and the declaration are retained for ten years after the product is placed on the market. The new regulation also requires you to produce documents within ten days of a request.
Connecting to your order system
Product types, articles and documents only need to exist in one place. We retrieve them via integrations instead of maintaining them twice.
Who we build for
Your role in the chain determines what you need to be able to show. Four scenarios.
Manufacturers of construction products
You draw up the declaration and are liable for what it states. The focus lies on substantiation and version control. If the evidence originates on the shop floor, see the factory and delivery app or joinery factory software.
Importers and distributors
You do not draw up the declaration, but you check that it exists, travels with the product and that the marking is correct. If you supply under your own brand, the manufacturer's obligations apply to you.
Assemblers and installation companies
You process products from third parties and sometimes supply an assembled whole. The question is which declarations you collect and whether they belong to the right party. See also structural steel software and, for civil infrastructure works, civil engineering software.
Consultants and quality departments
You support several manufacturers. A single setup per client avoids rebuilding the same structure each time; verification runs through audit software.
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Standards are replaced and the content of the declaration changes accordingly. Standard versions, essential characteristics and languages should therefore be configurable.
Why Appfront
The marking follows from the declaration
Article 8 leaves no room: without a declaration of performance, the CE marking may not be affixed. We therefore build the declaration as the outcome of the file.
A declaration belongs to a version
Standards are revised and products change. We keep versions apart, so that for a delivery from three years ago you show the declaration that applied at the time.
The passport is coming
The new regulation establishes a system of digital product passports for construction, with the declaration and technical documentation within it. We record your data now in such a way that it can carry over later.
We do not determine your system
Which assessment system applies to your product family follows from the regulations, and you discuss it with your notified body. We build the file that substantiates it.
Security and privacy
A register of declarations does not contain your formulation, but it does contain the substantiation beneath it: test reports, type calculations and measured values. We set access by role and by product group, give a consultant or notified body only its own scope, and log every inspection.
The durability of the document is the entire point here. A declaration that can be quietly updated afterwards is precisely the element that becomes disputed in a claim, and you must be able to look back ten years. We record every version unalterably, with timestamp, person and the substantiation that lay beneath it at the time. How we handle security ourselves is set out in our information security policy; reports from outside come through our vulnerability disclosure policy.
Frequently asked questions about the Construction Products Regulation
Regulation (EU) No 305/2011 of 9 March 2011, known in the Netherlands as the Bouwproductenverordening and internationally as the CPR. The document is called the declaration of performance. From 8 January 2026, Regulation (EU) 2024/3110 takes over, which calls it the performance and conformity declaration.
Regulation (EU) 2024/3110 applies and 305/2011 is repealed, except for a set of articles that continue until 8 January 2040 for products under the old harmonised standards. The transition happens by product family: the new obligations only apply one year after the implementing act for that family.
Then it falls outside the harmonised area and CE marking does not apply. You can opt for a European Assessment Document with a technical assessment; the declaration then follows regardless. If you don't, you demonstrate performance with a construction quality declaration, which is what article 2.14 of the Besluit bouwwerken leefomgeving refers to.
Article 5 of the old regulation lists three: custom-made products from a non-series process installed in a single identified construction work, a product manufactured on the building site itself, and work made in a traditional way or for heritage conservation. The new regulation retains the first and the third.
Yes, subject to conditions. The content must be in a non-editable electronic format, both human- and machine-readable, downloadable and freely accessible, and continuously available. There must also be a link between the product and the declaration via the unique identification code of the product type.
The manufacturer draws up the declaration, affixes the marking and keeps the technical documentation. The importer checks in advance that this documentation exists, that the marking is correct and that the declaration accompanies the product, and adds their own name and address. The distributor checks that the marking, declaration and user information are present.
The declaration is a European obligation when placing a product on the market and is tied to a harmonised standard. KOMO is a national quality mark with an assessment guideline and an institute that tests periodically. In your factory they overlap, but in the regulations they do not. For that file there is certificate management for KOMO and BRL.
That depends on the number of product types, how many standards apply, how many languages you deliver in and whether integrations are needed. The register with the declaration per type is usually quick to put into use and shows which evidence is still missing. We provide a reasoned estimate after the discovery phase.
Do you know which standard version your declaration is based on?
Take a product you supplied three years ago and ask for the declaration that applied at the time, with the test report underneath. If the current version comes up, you are managing documents, not a file. We build this as a standalone application and as part of custom software, alongside software for construction companies.