## Conclusion: The starting point of CPR compliance is the AVCP system, not test reports. For construction products exported to the EU, CE marking is based on Regulation (EU) No 305/2011 (CPR). Many companies focus on testing but overlook the determination of the AVCP (Assessment and Verification of Constancy of Performance) system. If the system is misjudged, subsequent DoP, factory production control (FPC), and notified body involvement methods will all be wrong. In practice, the Shuwang Testing and Certification Platform has observed that most cases of CPR documentation being returned or questioned by buyers stem from a mismatch between the AVCP system and the actual use of the product. This article breaks down the system determination logic and the DoP self-check list. ## AVCP System Determination: How to Distinguish 1+, 1, 2+, 2, 3, and 4 CPR divides AVCP into multiple systems, with the specific applicability depending on the harmonized standard (hEN) or European Technical Assessment (ETA) to which the product belongs. Common comparisons are as follows (reference ranges; the specific hEN Annex ZA for the product shall prevail): | AVCP System | Degree of Notified Body Involvement | Typical Product Examples | Manufacturer Responsibilities | | --- | --- | --- | --- | | 1+ | NB conducts type testing + continuous surveillance + factory audit | Steel for load-bearing structures, prestressed components | FPC + DoP | | 1 | NB conducts type testing + factory audit | Some structural products | FPC + DoP | | 2+ | NB conducts factory audit + continuous surveillance; manufacturer self-tests | Some fire-resistant materials, some structural products | Testing + FPC + DoP | | 2 | NB conducts factory audit; manufacturer self-tests | Some non-load-bearing products | Testing + FPC + DoP | | 3 | NB conducts type testing; manufacturer self-controls | Some insulation materials, some doors and windows | Testing + FPC + DoP | | 4 | Manufacturer self-declaration | Low-risk products | Testing + FPC + DoP | Key points for determination: First determine the harmonized standard or ETA corresponding to the product, then check the AVCP system specified in Annex ZA of that standard. Do not apply based on experience. If the system is misjudged, the NB involvement method will not match the DoP content. ## DoP Declaration of Performance Self-Check List The DoP (Declaration of Performance) is the core document of the CPR and is signed by the manufacturer. The following are common industry self-check items: | Self-Check Item | Requirement | Common Issues | | --- | --- | --- | | Product model and use | Consistent with test reports and FPC scope | Model does not cover variants | | Harmonized standard or ETA | Cite the current valid version | Standard version expired | | AVCP system | Consistent with hEN Annex ZA | System misjudged | | Performance parameters | Listed as required by the standard; no blanks allowed | Key performance missing | | Test reports | Issued by qualified partner laboratories | Samples inconsistent with mass production | | FPC records | Factory production control documents | Incomplete records | | NB certificate number | Filled in under applicable system | Number missing or incorrect | | Manufacturer signature | Authorized by legal representative | Unsigned or signed by proxy | The Shuwang Testing and Certification Platform can assist companies in determining the AVCP system, matching notified bodies with the corresponding authorization scope, organizing DoP preparation and pre-review, and following up on NB factory audit scheduling. Testing is completed by partner laboratories with reports issued, and NB certificates are issued by notified bodies. ## Time and Cost Reference Ranges The CPR compliance cycle is typically 20–60 working days (reference range), with costs of 20,000–80,000 RMB (reference range). Systems 1+ or 1 tend toward the upper limit due to factory audits and continuous surveillance; Systems 3 or 4 are relatively shorter. Actual timelines are subject to NB scheduling and factory audit arrangements. ## Implementation Self-Check
Four actions: 1. **Lock down hEN or ETA**: Confirm the harmonized standard version corresponding to the product and check the AVCP system in Annex ZA. 2. **Align testing with DoP**: The performance parameters in the test report must be able to support the DoP declaration and must not exceed the scope of the report. 3. **FPC first**: Factory production control documents should be traceable before the NB audit, avoiding records being supplemented during the on-site audit. 4. **DoP signing and marking**: The DoP is signed by the manufacturer, and the CE marking and NB number are marked in accordance with regulations. If you need system determination and DoP pre-review for specific construction products, you can visit https://www.shuwang-cert.com to submit product and standard information, and an engineer will provide an assessment opinion. ## One-sentence conclusion The order of CPR compliance is: first determine hEN/ETA, then determine the AVCP system, and finally align the test report, FPC, and DoP; the Shuwang Testing and Certification Platform can assist with system determination, NB liaison, and DoP pre-review, while testing and certification are completed by partner laboratories and notified bodies respectively. > **Service boundary statement**: The Shuwang Testing and Certification Platform is an export certification solution service provider and does not engage in testing activities, nor is it a certification body. The testing described on this page is completed by partner laboratories with CNAS/CMA or equivalent qualifications, and certificates are issued by EU notified bodies (NB) or institutions authorized by the standards bureau of the destination country. The cycle times and fees on this page are public industry reference ranges, and the actual ones are subject to engineer assessment and institution scheduling.