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Analysen · 2026-10-03

Construction products, where conformity and fitness are two questions

This is the only category in the series where passing the standard does not finish the job, because the core document is a declaration of performance. That shapes the questions a buyer has to ask, and it explains why the EU changeover has two separate timetables.

Conformity and fitness are two different questions

In toys, appliances or PPE, conformity is the finish line: clear the standard and the product can be sold. Construction products do not work that way. Their central document is a declaration of performance, and what it declares is the level a product reaches on its essential characteristics: fire resistance, load-bearing capacity, sound insulation, thermal performance.

So a product can be fully compliant and still not be fit for the job. A panel that meets the fire class it declares does not thereby belong in your building; whether it is good enough is a judgement the designer makes against the project requirements. That difference changes the question a buyer asks. Not whether it passed, but how much was declared, and whether that is enough.

EU: two timetables in the changeover

The regulation currently in force is (EU) No 305/2011, published on 4 April 2011. It is being replaced by (EU) 2024/3110, published on 18 December 2024, and its date structure is more tangled than in the earlier articles.

Part of the new regulation, including certain articles and annexes, applies from 7 January 2025. The repeal of the old regulation sits in Article 94: it is repealed with effect from 8 January 2026, but with a list of exceptions. Article 2, Articles 4 to 9, Articles 11 to 18, Articles 27 and 28, Articles 36 to 40, Articles 47 to 49, Articles 52 and 53, Article 55, Articles 60 to 64, and Annexes III and V continue to apply, and a further provision repeals what remains with effect from 8 January 2040.

That makes the widely repeated statement that the new regulation applies from 8 January 2026 inaccurate. That date is when most of the old regulation is repealed, not when the new one starts to apply, and the repeal itself carries exceptions. Working out which text governs a given product on a given date means reading the new regulation's application provisions and the Article 94 exception list together.

EU: the manufacturer declares, the system grades the assessment

Assessment in the EU is graded by system, and the old regulation uses numbered designations such as System 1+. Under System 1+, the manufacturer declares performance on the basis of specified items, including factory production control and assessment involving a notified body.

What the grade changes is how far a notified body is involved. Some systems require a notified body to carry out initial type testing and to keep supervising factory production control; others leave factory production control with the manufacturer. In every case the declaration itself is issued by the manufacturer. The notified body assesses whether the declaration has a basis, not whether the product is good.

Structural components carry a further grading. Steel and aluminium structures use the EN 1090 series with execution classes, EXC in short, and a higher class brings stricter requirements on factory production control, welding and personnel competence. A steel fabricator building ordinary sheds and one building bridges are not clearing the same bar.

US: no federal act, building codes do the work

There is no unified federal construction products admission act in the US. The real obligation comes from state and local building codes: once a jurisdiction adopts a model code such as the International Building Code, the standards that code references, ASTM and AISC and AISI among them, become local requirements. The same piece of steel can face different requirements in two states, depending on which version of the code each has adopted.

The structure is the same as in the machinery and PPE articles. There is no national product passport; the obligation comes from who adopts what. A buyer checks the code and the design documents of the project's location, not a federal mark.

For this section we hold the regime only. This library has not collected ASTM or AISC texts, which sit in the paid standards layer.

China: design standards and product standards are two systems

Two things need separating in China. Product standards, such as those for the mechanical properties of fasteners, govern the product's own indicators. Engineering construction standards, such as the design standard for steel structures, govern design and construction. The second belongs to a different system with a different basis of obligation, where fully mandatory general specifications sit alongside recommendatory provisions.

Only a few construction products sit inside the CCC catalogue, safety glass among them, and most do not. This library holds search entries rather than texts for the relevant Chinese standards, so the page states the structure and no clauses.

Japan, Korea, Canada, Australia-NZ, Brazil, Gulf

Japan regulates under its building standards act, with JIS standards for structural steel and bolts and the JIS mark licensing scheme. Korea works through its building act and KS certification. Canada relies on provincial building codes modelled on the national code, plus CSA standards. Australia and New Zealand use the National Construction Code plus AS standards. Brazil has ABNT NBR standards and INMETRO certification for construction materials. The Gulf states regulate under the GSO construction products technical regulation, with Saudi Arabia routing through SABER.

For these markets we currently hold the regime described but no primary text, so the page states the regime and no document numbers.

Ten markets side by side

Two columns, what the evidence is and where the obligation comes from:

The first column is the one to remember. Only the EU has made the declaration of performance a standard instrument; elsewhere what you receive is usually a test report plus documentation of code compliance. The forms differ but the purpose is the same, which is to let someone judge fitness rather than to announce conformity.

What to ask before you order

Ask four things about construction products: which essential characteristics the declaration or test report covers, item by item across fire, load, thermal and acoustic performance; what the declared values are and under which system they were assessed; what the conditions of use are, since thickness, substrate and installation method all move the numbers; and who supervises factory production control and whether that supervision continues as the system requires.

The first question is the one most often skipped and the one that surfaces on site. Saying we have CE means very little in this category. It shows that a declaration was made and a procedure followed; it says nothing about whether the declared values suit your building. To work through these in order, start with the free verification checklist. The previous article in this series is pressure equipment; the next, wires and cables, runs on reaction-to-fire classes instead. To see how certifications and compliance documents are recorded, look at a report sample, or get in touch.