Transitional rules for the ETA route
Introduction
Starting on 7 January 2025, the revised Construction Products Regulation (EU) 2024/3110 entered into force. The regulation has been generally applicable since 8 January 2026. It brings changes to the ETA route, including the development of European Assessment Documents (EADs) which are used as the basis for ETAs. You can learn more about the changes below.
Regulation (EU) 2024/3110, the revised Construction Products Regulation – also referred to as revised CPR or CPR 2024 – introduces changes to the ETA route that are relevant for all stakeholders.
The following changes apply from 8 January 2026, the date of application of the revised CPR.
- An ETA may now only be issued if the underlying EAD is cited in the Official Journal of the European Union (OJEU)
- ETAs under CPR 2024 will contain 'predetermined environmental essential characteristics'. These are selected sustainability indicators in accordance with EN 15804 'Environmental product declarations – Core rules for the product category of construction products' and used for life-cycle assessment.
- There will be a digital product passport also for ETA products.
- Under CPR 2024, ETAs and EADs no longer have unlimited validity but are issued for defined periods.
- Finally, the relationship between EADs and ETAs and harmonised technical specifications has been revised.
Transitional rules apply to ETAs and EADs issued and developed under CPR 2011.
If your ETA is based on an EAD cited under CPR 2011, you can regularly use your ETA as a basis for the declaration of performance and CE marking until 9 January 2036.
| Note: You can access the citation status of EADs in the OJEU on the website of the European Organisation for Technical Assessment (EOTA): http://www.eota.eu/eads |
With the application of the revised CPR, ETAs that are based on ETAGs (European Technical Approval Guidelines, the predecessors of EADs) are no longer valid as a basis for the declaration of performance and CE marking. We have recommended that manufacturers update their ETA by transferring it to an EAD. DIBt remains ready to support you in this process.
| Note: Whether your ETA is based on an EAD or an ETAG is recorded on your ETA’s cover sheet. |
ETAs based on EADs that have not been cited under CPR 2011 by 8 January 2026 are treated as ETA requests under CPR 2024 (cf. Art. 95(6) of CPR 2024).

EADs cited under CPR 2011 can regularly be used to issue ETAs until 9 January 2031. Please check EOTA’s website for updates on citations.

These procedures are ongoing and will be finalised under CPR 2024. This step encompasses adapting the EAD to the revised CPR and extending it to include sustainability indicators. Afterwards, the ETA will be (re-)issued and can again be used for CE marking.
If you do not wish to continue your procedure under CPR 2024, please let us know at your earliest convenience.
If you currently plan to apply for a new ETA, please contact DIBt in advance for coordination.
In principle, you may continue to apply for ETAs as usual. If a relevant EAD under CPR 2011 is available, the ETA can be issued on this basis. Alternatively, you can ask for the EAD to already be adapted to meet the requirements of CPR 2024. We are happy to advise you on a case-by-case basis.
If there is no relevant EAD available, we will initiate the development of a new EAD under CPR 2024 at the European level in close coordination with you. Please note that there may be some delays initially, as the new procedures are still being implemented.
Under CPR 2024, ETAs will contain ‘predetermined environmental essential characteristics’. These are selected sustainability indicators in accordance with EN 15804 ‘Environmental product declarations – Core rules for the product category of construction products’. Step by step, those sustainability indicators need to be included in the declarations of performance and conformity.
The corresponding assessment methods will be specified in EADs under the revised CPR.
This is not yet mandatory for ETAs that are based on EADs under CPR 2011 (see Commission webpage Voluntary CE marking (EOTA route)). However, EADs can be extended to include sustainability indicators when the ETA request is submitted.
The digital product passport is an instrument originally devised under the Ecodesign Regulation (EU) 2024/1781 (former Ecodesign Directive) to provide information on the environmental sustainability of products. Under CPR 2024, the digital product passport will contain much more ample information, such as the declaration of performance and conformity and other technical documentation. The digital product passport system under CPR 2024 will be instituted by a separate delegated act of the Commission and will be mandatory 18 months thereafter.
In other words, the point in time at which sustainability performance needs to be declared and the deadline for the digital provision of that information may differ.
EADs that have been cited under CPR 2024 are initially valid for ten years after their citation in the OJEU. One year before that date, EOTA can submit the EAD to the Commission for renewal.
Usually, ETAs stay valid for five more years after the underlying EAD has expired unless the EAD has expired for other reasons.
EADs and ETAs under CPR 2011 are subject to the transitional rules: EADs can be used to issue ETAs until 9 January 2031 at the latest. ETAs based on those EADs can no longer be used as a basis for CE marking after 9 January 2036.
Under CPR 2024, European Assessment Documents (EADs) are no longer considered harmonised technical specifications.
However, if a manufacturer affixes the CE marking on the basis of an ETA, the product obtains the same status as products in accordance with harmonised technical specifications.
Background: The revised CPR summarises the following documents under the term 'harmonised technical specifications':
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As a new feature under CPR 2024, manufacturers may decide whether they want to market their product with a declaration of performance and conformity and CE marking, even after the ETA has been issued. They can also use the ETA as a stand-alone document.
From the date of mandatory application of a harmonised technical specification – usually a harmonised standard –
- adopted under the new CPR and
- covering the same product and the same intended use as a European assessment document
the EAD and corresponding ETA can no longer be used.
Under CPR 2024, EADs may only be developed if the product is not covered by a harmonised standard (or more precisely a harmonised technical specification). The same applies if a harmonised standard is to be delivered in a period shorter than one year, in accordance with the standardisation request.
Products are not covered by a harmonised standard if
- the declared use is different
- other materials are used than those covered by the standard
- the assessment procedures set out in the harmonised standard are not appropriate for the product
Under CPR 2024, the case ‘not fully covered by the harmonised standard’ no longer exists. In the past, this specific case has been used if a harmonised standard was incomplete – that is, if there were no assessment methods for essential performance characteristics.
EADs and ETAs that have been developed under CPR 2011 to close this gap will continue to be valid until a harmonised standard under the revised CPR becomes mandatory.
Usually, yes.
However, the ETA may only be used for CE marking until the harmonised standard under CPR 2024 becomes mandatory. Afterwards, it can still be used as technical documentation.
Additionally, there may be cases where no ETA can be issued due to the lack of an applicable EAD. This could occur because, under CPR 2024, EADs may no longer be developed if they would overlap with a harmonised standard to be delivered in less than a year.