New verification systems for EU construction products: what manufacturers must do in 2026

Key data

If you manufacture, import or distribute construction products in the EU, you have a new compliance obligation from 17 September 2026. The Delegated Regulation (EU) 2026/1310 completes the framework of Regulation (EU) 2024/3110 and establishes, product by product and characteristic by characteristic, which assessment and verification system you must apply before being able to market in the European market.

The regulation does not invent a system from scratch: it adapts and provides continuity to the AVCP systems (Assessment and Verification of Constancy of Performance) that already existed under Regulation 305/2011, but reorganises and clarifies them for each product family or category. The stated objective is to minimise administrative burdens without reducing safety and environmental protection standards.

What does this regulation establish?

Delegated Regulation (EU) 2026/1310 defines three levels of assessment and verification applicable to construction products according to the family or category to which they belong and the characteristics they declare:

A key aspect: manufacturers must identify which system applies to them before the harmonised technical specifications of their product become applicable. This means that the obligation to conduct prior analysis is immediate, although full implementation depends on the schedule for each technical specification.

The regulation also ensures continuity with Regulation 305/2011: existing AVCP systems are adapted, not eliminated. Companies that already operated under the previous framework do not start from scratch, but must verify that their assigned system remains correct under the new Regulation (EU) 2024/3110.

Economic and operational impact

The direct economic impact depends on the system that applies to each product. The regulation is expressly designed to minimise administrative burdens, which translates into:

• System 4: Operating cost is minimal. It does not require intervention by external notified bodies. The manufacturer self-assesses and declares presumed performance without prior testing.
• Horizontal systems (reaction to fire, hazardous substances): They involve more demanding verification processes, with possible third-party intervention and additional testing or certification costs.
• Category-specific systems: Cost varies according to the applicable harmonised technical specification. Companies must consult the specification of their product family to know the exact level.

The main economic risk is not the cost of the system itself, but marketing without having correctly identified the applicable system before the corresponding harmonised technical specification enters into force. This can block the marketing of the product in the European market.

Who does it affect?

• Manufacturers of construction products with presence in the European market: must identify the assessment system applicable to each product family or category they market.
• Importers of construction products in the EU: responsible for verifying that the products they introduce to the market comply with the corresponding assessment system.
• Distributors of construction products: must ensure that the products they distribute have passed through the correct system before being made available on the market.
• Notified bodies that participate in the assessment and verification processes of construction products.
• Compliance, quality and export departments of companies in the construction and materials sector.

Practical example

Imagine a Spanish company manufacturing facade panels that currently operates under Regulation 305/2011 with an assigned AVCP system. With the entry into force of Delegated Regulation (EU) 2026/1310 on 17 September 2026, this company must:

1. Review the characteristics it declares for its panels (for example: mechanical resistance, reaction to fire, thermal insulation).
2. For the reaction to fire characteristic, identify that a horizontal system applies to it, with a higher level of requirement and possible intervention by a notified body.
3. For characteristics with presumed performance without testing (for example, certain standardised dimensional properties), apply the simplified system 4, without need for testing or third parties.
4. Complete this analysis before the harmonised technical specification of its product family becomes applicable, to avoid blocking commercialisation.

The result: the company can maintain the simplified system for part of its declarations and strengthen only critical characteristics, optimising costs without breaching the regulation.

What should companies do now?

1. Inventory affected products: Identify all families and categories of construction products that the company manufactures, imports or distributes in the EU.
2. Determine the applicable system for each product: Review Delegated Regulation (EU) 2026/1310 to assign the correct system (system 4, horizontal or category-specific) to each product family and declared characteristic.
3. Verify continuity with the previous AVCP system: Check that the system that was being applied under Regulation 305/2011 remains valid under the new framework of Regulation (EU) 2024/3110.
4. Anticipate the schedule for harmonised technical specifications: Identify when the harmonised technical specifications for each product will become applicable to complete the analysis before that date.
5. Update technical documentation and performance declarations to reflect the correct assessment system according to the new regulation.
6. Consult with notified bodies in cases where the assigned system requires third-party intervention (especially for reaction to fire or hazardous substance characteristics).

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R1310