For EU construction product manufacturers and importers under CPR 2024/3110: split your EU sales by declaration route (hEN, ETA, no DoP). ETAs on old EADs cannot place products after 9 January 2036; national penalties apply from 8 January 2027 (Ireland: up to €500,000 per offence).
Do you place construction products on the EU market? Since 8 January 2026 Regulation (EU) 2024/3110 runs alongside parts of Regulation 305/2011. Products on ETAs issued under old EADs cannot be placed on the market after 9 January 2036, and national penalties apply from 8 January 2027. Type your EU sales by declaration route to see what to fix now and what rides on the 2036 cut-off.
| EU sales checked | - |
| EU sales with no DoP: fix now | - |
| Share of EU sales with no DoP | - |
| EU sales on ETAs: stop 9 Jan 2036 unless re-assessed | - |
| Share of EU sales on ETAs | - |
| EU sales needing a new or fixed declaration | - |
| Years until old EADs expire (9 Jan 2031) | - |
| Years until old-ETA placing ends (9 Jan 2036) | - |
| ETA product types to re-assess per year | - |
| Years you must still keep documents (Art. 20(4)) | - |
| Fine ceiling if each no-DoP type is one offence | - |
Everything updates as you type. Nothing is uploaded. This runs in your browser.
Full version — $21 once (.xlsx with a 40-row product register flagging each product type by route and cut-off date, plus a 12-point CPR checklist with articles) Get it →
Sources: Regulation (EU) 2024/3110, OJ L 18.12.2024 — Art. 92 (penalties, from 8 January 2027; rules notified by 8 December 2026), Art. 95(3) (old hENs valid until withdrawn), Art. 95(4) (old EADs valid until 9 January 2031; no placing on their ETAs after 9 January 2036), Art. 20(4) (documents kept 10 years after supply). Ireland, S.I. No. 225/2013 Regulation 18 (up to €500,000 on conviction on indictment). Not legal advice.
$21 once: an .xlsx with a 40-row product register (route, hEN or EAD, DoP date, cut-off flags, retention year) and a 12-point CPR checklist with articles.
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Regulation (EU) 2024/3110 (OJ L, 18.12.2024): applies from 8 January 2026; Article 92 (penalties) applies from 8 January 2027 and Member States must notify their penalty rules by 8 December 2026. Art. 95(3): harmonised standards l
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Real numbers from this tool, line by line.

A compliance manager at an EU construction product manufacturer with €12,000,000 of EU sales a year finds €600,000 of them sold with no declaration of performance, and €2,400,000 riding on ETAs that stop placing products on the market on 9 January 2036.
| Example manufacturer, EU sales per year | Old answer: "we have CE marks" | Route by route under CPR 2024/3110 |
|---|---|---|
| Sales with a DoP under a cited hEN | €9,000,000 OK | €9,000,000 OK until the hEN is withdrawn |
| Sales on ETAs under old EADs | €2,400,000 OK | €2,400,000 to re-assess before 9 January 2036 |
| Sales with no declaration | €600,000 not checked | €600,000 to fix now |
| Sales needing action | €0 | €3,000,000 |
That is 5.00% of sales to fix now and 20.00% to re-assess within 10 years. Together, €3,000,000 of EU sales need a new or fixed declaration. The worked example is a panel and insulation maker with five product types: two on harmonised standards, two on European Technical Assessments, one new fire-stop product with no declaration.
Why the old checklist misses it. Since 8 January 2026, Regulation (EU) 2024/3110 applies, but it does not switch everything over at once. Article 95(3) keeps harmonised standards listed under Regulation 305/2011 valid until the Commission withdraws them. Article 95(9) makes the new obligations apply to a product family one year after the implementing act for that family is adopted. So a declaration of performance under an old hEN is still the right document today for many product types.
The ETA route has fixed end dates. Under Article 95(4), European assessment documents listed by 8 January 2026 stay valid until 9 January 2031, and products shall not be placed on the market on the basis of ETAs issued under them after 9 January 2036. A product type that sells on such an ETA needs a re-assessment plan, and the sales column shows how much rides on it.
Penalties are national and start soon. Article 92 applies from 8 January 2027, and Member States must notify their penalty rules to the Commission by 8 December 2026. Today's Irish rules, S.I. No. 225/2013 Regulation 18, allow a fine of up to €500,000 on conviction on indictment. The calculator multiplies your Member State's ceiling by the product types with no declaration and labels it an upper bound, not a forecast: one type gives up to €500,000.
Records outlive the product. Article 20(4) requires economic operators to keep documents for 10 years after supplying the product. Supply a product type in 2026 and its file stays until 2036.
How the result changes. A manufacturer whose whole range sits on harmonised standards, with €9,000,000 of sales, sees €0 to fix and €0 on the ETA cut-off. An importer with €1,500,000 on hENs, €4,000,000 on six ETA product types and €900,000 across three undeclared types sees €4,900,000 needing action, 14.06% of sales with no declaration, and a fine ceiling of up to €1,500,000. Run the same importer in 2030 and the years left drop to 1 for the old EADs and 6 for ETA placing.
The free calculator returns all 11 results for your company in your browser, with nothing uploaded. The paid spreadsheet adds a 40-row product register that flags each product type by route and cut-off date, totals sales with no declaration and sales on old ETAs, and computes each row's keep-documents-until year, plus a 12-point checklist that cites the article and date behind every point.
You type your annual EU sales split by declaration route: product types with a declaration of performance under a cited harmonised standard, product types CE-marked through a European Technical Assessment, and product types with no declaration. It returns the sales to fix now, the sales riding on old ETAs until 9 January 2036, years left, document retention and a fine ceiling.
Compliance, quality and regulatory managers at manufacturers and importers who place construction products on the EU market: insulation, sandwich panels, fixings, membranes, sealants. Since 8 January 2026 Regulation (EU) 2024/3110 applies alongside parts of Regulation 305/2011, so each product type can sit on a different route with a different end date.
Most free answers still describe Regulation 305/2011 alone, or say the new rules replace it overnight. The text of Regulation 2024/3110 keeps old harmonised standards valid until withdrawn, keeps old EADs valid until 9 January 2031, and stops products being placed on the market on those ETAs after 9 January 2036. The dates differ by route.
The web calculator is free with no limit: all 11 results for your company, run in your browser, nothing uploaded. The paid file is $21 once, not a subscription: the same formulas in an .xlsx, a 40-row product register that flags each product type by route and cut-off date, and a 12-point checklist citing each article.
A product sold without a declaration can be withdrawn by market surveillance, and from 8 January 2027 the penalty rules each Member State notifies under Article 92 apply. In Ireland, S.I. No. 225/2013 Regulation 18 allows a fine of up to €500,000 on conviction on indictment. The calculator shows that as a ceiling, not a predicted fine.
Member States must notify the Commission of their penalty rules under Regulation 2024/3110 by 8 December 2026, and Article 92 on penalties applies from 8 January 2027. After that, the next fixed dates are 8 January 2030 for re-designating notified bodies, 9 January 2031 for old EADs and 9 January 2036 for placing products on old ETAs.
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