CE MARKING
COMMON MISTAKES
CHECKLIST
CE Marking Declaration of Performance Errors: 10 Common DoP Mistakes
By PZVAR Technical Editorial Team
8 Min Read
14 Aug 2026
Table Of Contents
Key Takeaways
Documentations
Process Flow
Tips
Checklist
Introduction
A Declaration of Performance (DoP) is a key document for CE-marked construction products. It communicates the product’s declared performance against the applicable technical specification and supports the CE marking process.
A mistake in the DoP can create inconsistencies between the product, testing, technical documentation and CE marking.
Common problems include using the wrong standard, declaring incorrect performance, providing outdated information or failing to update documentation after a product change.
For manufacturers preparing products for the European market, checking the DoP carefully before placing a product on the market is therefore essential.
This guide covers 10 common CE marking Declaration of Performance errors and explains how manufacturers can avoid them.
2026 update: EU construction-product rules are transitioning under Regulation (EU) 2024/3110, which introduces a revised framework including the Declaration of Performance and Conformity (DoPC). Manufacturers should verify which requirements and transition provisions apply to their specific products.
What Is a Declaration of Performance?
A Declaration of Performance (DoP) is a manufacturer’s declaration of the performance of a construction product against the relevant essential characteristics and applicable technical specification.
Depending on the product and applicable route, the declaration can include information such as:
- Product identification
- Intended use
- Applicable harmonised technical specification
- Assessment and Verification of Constancy of Performance (AVCP) system
- Declared performance
- Manufacturer details
- Notified-body information, where applicable
The DoP should be supported by appropriate technical documentation and assessment evidence.
In simple terms:
Product → Assessment → Performance → DoP → CE Marking
Any inconsistency in this chain can create a compliance problem.
10 Common CE Marking Declaration of Performance Errors
1 Incorrect Product Identification
The product described in the DoP must correspond to the product actually placed on the market.
Common mistakes include:
- Wrong product name
- Incorrect model number
- Wrong product type
- Outdated product reference
- Inconsistent product identification
For example, the product name in the DoP may differ from the name appearing on the test report or CE marking.
How to avoid it
Use one controlled product identification across:
Technical Documentation → Test Reports → DoP → Product Label → CE Marking
2 Wrong Harmonised Standard
Using the wrong technical specification is a serious DoP error.
Manufacturers sometimes:
- Select a standard for a similar product
- Use an outdated reference
- Confuse a product standard with a test standard
- Fail to verify the applicable harmonised specification
Before preparing the DoP, confirm the exact technical specification applicable to the product and its intended use.
3 Incorrect Intended Use
The intended use stated in the declaration should accurately represent the product’s application under the applicable technical framework.
Problems occur when manufacturers:
- Use vague descriptions
- Copy the intended use from another product
- Use marketing language instead of technical terminology
- Declare applications that are not supported by the assessment
The intended use should be consistent across the relevant standard, technical documentation and DoP.
4 Incorrect Declared Performance
The declared performance is one of the most important parts of the DoP.
Errors can include:
- Incorrect values
- Wrong performance classes
- Incorrect units
- Results from the wrong product
- Outdated test results
- Transcription errors
Every declared value should be traceable to appropriate testing or assessment evidence.
Simple check
Declared Performance = Supporting Evidence
If the evidence does not support the declaration, the DoP needs to be reviewed.
5 Incorrect AVCP System
The Assessment and Verification of Constancy of Performance (AVCP) system determines how product performance is assessed and verified.
A manufacturer may use the wrong AVCP system because of:
- An outdated template
- Incorrect interpretation of the applicable standard
- Copying another product’s DoP
- Confusion about notified-body responsibilities
Always verify the applicable AVCP system against the relevant technical specification.
6 Incorrect Notified Body Information
Where notified-body involvement is required, the information must be accurate.
Common errors include:
- Wrong notified-body number
- Incorrect certificate reference
- Expired certificate
- Certificate outside its scope
- Using old notified-body information
The DoP, certificate and related documentation should all identify the correct assessment route and third-party information.
7 DoP Does Not Match Technical Documentation
A DoP should not be treated as an isolated document.
For example:
- DoP Technical Documentation
- Product A Product B
- Class 2 Class 3
- Standard X Standard Y
Such inconsistencies can raise questions about whether the declared performance is properly supported.
Best practice
Cross-check the DoP against:
- Technical documentation
- Test reports
- Certificates
- Product specifications
- FPC records
- CE marking
8 Using Outdated DoP Information
An old declaration should not automatically be reused.
Information may become outdated because of:
- Standard changes
- Product changes
- New test results
- Certificate changes
- Regulatory changes
- Updated manufacturing processes
This is particularly important in 2026, as the EU construction-products regulatory framework is transitioning under Regulation (EU) 2024/3110.
Manufacturers should periodically review their templates and supporting documentation.
9 Failing to Update the DoP After Product Changes
A product change should trigger a compliance review.
Examples include:
- Raw-material changes
- Supplier changes
- Product redesign
- Manufacturing-process changes
- Production-location changes
- New product variants
- Changes affecting product performance
The key question is:
Does this change affect the product’s declared performance or the evidence supporting it?
If yes, the DoP and related technical documentation should be reviewed.
10 Inconsistent CE Marking Information
The DoP and CE marking should form a consistent compliance package.
Check that the relevant information concerning:
- Product identification
- Manufacturer
- Declaration
- Technical specification
- Notified body, where applicable
- Required marking information
is accurate and consistent.
Under the new CPR framework, CE marking remains directly connected with the required declaration of performance and conformity.
CE Marking DoP Compliance Checklist
Before approving a Declaration of Performance, check:
Product
Product identification is correct
Product type is correct
Intended use is correct
Product information matches technical documentation
Technical Requirements
Correct harmonised technical specification
Correct assessment methods
Correct AVCP system
Applicable requirements have been verified
Performance
Declared values are supported by evidence
Correct performance classes are used
Correct units are used
Test reports correspond to the product
Documentation
DoP matches technical documentation
DoP matches certificates
Product changes have been reviewed
Outdated documents are controlled
CE Marking
Product identification is consistent
Required information is present
Declaration information is correct
Notified-body information is correct where applicable
How to Prevent DoP Errors
A simple five-step review can significantly reduce documentation problems.
Step 1: Identify the Product
Confirm the exact product type, model and intended use.
Step 2: Verify the Technical Basis
Confirm the applicable harmonised technical specification and assessment route.
Step 3: Verify Performance
Match every declared performance value with its supporting evidence.
Step 4: Cross-Check Documents
Compare: DoP ↔ Test Reports ↔ Technical Documentation ↔ Certificates ↔ CE Marking
Step 5: Control Changes
Review the DoP whenever product, manufacturing, testing or regulatory changes could affect the declared information.
DoP Errors vs CE Marking Problems
A DoP error does not always mean that the entire CE marking process is automatically invalid.
The significance depends on the nature of the error.
Administrative error
Example:
- Typographical mistake
- Incorrect date
Technical documentation error
Example:
- Wrong test report referenced
- Incorrect product type
Performance error
Example:
- Declared performance is not supported by the applicable evidence
- The more closely an error affects the technical basis or declared performance, the more important it is to investigate and correct it.
DoP and the 2026 CPR Transition
Manufacturers should pay particular attention to Regulation (EU) 2024/3110, the new Construction Products Regulation.
The regulation introduces a revised framework for construction products and includes the concept of a Declaration of Performance and Conformity (DoPC). It also introduces changes involving digital product information and environmental sustainability requirements.
Therefore, manufacturers should not simply copy an old DoP template into their 2026 compliance process.
Instead, they should verify:
- Which regulation applies
- Which technical specification applies
- Whether transition provisions apply
- What declaration is required
- Whether existing assessment evidence remains applicable
- Whether documentation needs to be updated
Frequently Asked Questions
What are the most common Declaration of Performance errors?
The most common errors are incorrect product identification, wrong standards, incorrect intended use, unsupported performance values, incorrect AVCP information, outdated documentation and inconsistencies between the DoP and technical documentation.
Can a DoP error affect CE marking?
Yes. The DoP is an important part of the CE marking documentation for construction products. An error can create a compliance issue, particularly where it affects the declared performance or technical basis.
Should the DoP match the test report?
Yes. The product and relevant declared performance should be supported by appropriate technical evidence.
Can manufacturers use an old DoP?
Only after verifying that the information remains applicable. Manufacturers should review old declarations against current product specifications, technical requirements and applicable regulatory provisions.
What is the difference between DoP and DoPC?
DoP means Declaration of Performance under the previous CPR framework. DoPC means Declaration of Performance and Conformity, introduced under Regulation (EU) 2024/3110 as part of the revised construction-products framework.
Conclusion
A Declaration of Performance is more than a compliance form. It connects the product’s technical assessment, declared performance and CE marking documentation.
The most common errors involve:
Wrong Product → Wrong Standard → Wrong Intended Use → Wrong Performance → Wrong AVCP → Incorrect Documentation → Incorrect CE Marking
Manufacturers can reduce these risks by introducing a structured DoP review before the product is placed on the market.
In 2026, this review is even more important because of the transition to the new EU construction-products framework under Regulation (EU) 2024/3110.
Before finalising your CE marking documentation, make sure the product, technical specification, assessment evidence, declared performance, DoP and CE marking all tell the same technical story.