The new CPR is in force. Your existing Declaration of Performance format stays legally valid until 2040, but the actual transition for your specific product family will likely come much sooner. The Commission has published the first CPR Working Plan covering 2026 to 2029.
Here is what that means in practice for manufacturers right now.
Regulation (EU) 2024/3110, the new Construction Products Regulation, has been published. For anyone currently issuing DoPs under Regulation (EU) No 305/2011, the practical impact on document formatting today is close to zero. But the path forward is now considerably clearer than it was six months ago.
The 15-year overlap, with a real timeline inside it
Article 94 of the new regulation repeals Regulation (EU) No 305/2011 as of 8 January 2026. However, Articles 4 to 9 (covering DoPs and CE marking) and Annex III (the DoP model itself) remain in force until 8 January 2040.
That 2040 date is the outer backstop. The real transition for any individual product happens earlier, when its specific harmonised technical specification is adopted under the new framework.
The Commission published the first CPR Working Plan for 2026 to 2029 on 16 December 2025. It lists every product family in Annex VII alongside indicative dates for each step: standardisation request, standard delivery, the implementing act that makes the standard mandatory, and the delegated act setting product requirements. Once the implementing act for your product family is adopted, manufacturers have one year to switch to the new “Declaration of Performance and Conformity” (DoPC) format, per Article 95(9).
When does your product family transition?
A few examples from the working plan to make this concrete.
For precast normal, lightweight and autoclaved aerated concrete products (family 1), the implementing act was already adopted in Q4 2025. New obligations apply from Q4 2026. Manufacturers in this family are first in line and should already be in transition mode.
For structural metallic products and ancillaries (family 20), the implementing act for the first batch landed in Q4 2025, with a follow-on implementing act expected Q3 2027 for standards not yet delivered. New obligations apply staggered, one year after each.
For cement, building limes and other hydraulic binders (family 15), the implementing act is targeted for Q4 2027. New obligations apply from Q4 2028.
For doors, windows, shutters and related hardware (family 2), thermal insulation (family 4), reinforcing steel (family 16), flat glass (family 30), and curtain walling (family 9), the implementing acts are projected for 2028 or 2029, with new obligations one year later.
Several families with later starts will not reach mandatory status until 2030 or beyond, including sanitary appliances, power and communication cables, free-standing chimneys, and the newly created “decorative paints and wallpapers” group.
The full schedule is in Table 3 of the working plan. Find your product family, look at the “Standard made mandatory” column, and add a year. That is when your old DoP format stops being acceptable for that product.
What format you must use right now
There is a useful distinction that often gets blurred in industry discussions. The new regulation entered into force, but its technical requirements have not yet entered into application for most product families.
For products covered by standards published under the old CPR, the old format remains the legally required format. You are obliged to use the model set out in Annex III of Regulation (EU) No 305/2011.
This is worth repeating because some manufacturers have started asking whether they should adopt the new DoPC format early. The answer is no, except where the working plan timeline has already triggered it (precast concrete, structural metallic products, cement). For everything else, implementing the new format before the relevant implementing act is adopted is not permitted.
What is worth doing during the transition
The format itself is stable for most product families through the late 2020s, but a few things are worth attending to now.
Identify your product family in the working plan and note your transition window. If you sit in a 2027 or 2028 cohort, your runway is short. If you sit in 2029 or later, you have more breathing room, but the direction of travel is fixed.
Retain your DoPs and technical documentation for at least 10 years after a product is placed on the market. The retention requirement is strict and unchanged from the old regulation.
Provide DoPs in the languages required by each Member State where the product is sold. Article 16(4) reinforces this. Translation gaps are one of the most common findings during market surveillance.
Begin thinking about machine-readable formats. The Digital Product Passport is a central pillar of the new CPR. Once a product family receives its implementing act, the DPP will eventually be made mandatory by separate delegated act. Documents that exist only as flattened PDFs, with no underlying structured data, will need to be rebuilt later.
Where Pelicopy fits in
Pelicopy is built for exactly this kind of transition. The platform handles the Annex III layout so the mandatory fields land in the right place every time, which removes a category of small errors that tend to creep into Word and InDesign templates. Translation into the required EU languages is part of the workflow rather than a separate process. And because the underlying data is structured rather than locked inside a PDF, the eventual move to the DoPC format and the Construction Digital Product Passport System should not require starting from scratch.
Approval workflows and version control are part of the platform too, which matters for Article 22(4): when a product changes, the re-assessment trail needs to be traceable.
For manufacturers tracking the working plan, the same Pelicopy documents can be repointed at the new format once your product family’s implementing act lands, without rebuilding the underlying data.
The short version
Regulation (EU) 2024/3110 is a major change in principle. The 2040 outer deadline gets quoted a lot, but it is misleading on its own. The Commission’s first working plan, published in December 2025, sets out the actual transition windows for each product family, and many of them fall between 2026 and 2030.
Find your product family in the working plan. Note the implementing act date. Add one year. That is when your old DoP format stops being acceptable for that product, and when the work you do now on documentation infrastructure pays off.
If you would like to see how Pelicopy handles this in practice, request a trial account. The platform is built by people who have spent years inside CPR documentation work.