Regulation (EU) 2024/3110 and the New Era for Construction Products

What is changing in general for the construction sector and

specifically for the Cyprus’s Wood and Furniture Sector

Regulation (EU) 2024/3110 on construction products marks a significant change in the way the European Union addresses the safety, performance, sustainability and information requirements associated with products used in construction.

The Regulation entered into force on 7 January 2025, and its main provisions have applied since 8 January 2026. This does not, however, mean that all its new requirements apply immediately and simultaneously to every construction product.

The transition will take place gradually, product family by product family, as new harmonized technical specifications are adopted and become applicable.

Regulation (EU) 2024/3110 will therefore coexist with the previous Regulation (EU) No 305/2011 for a considerable period.

This transitional period should not be regarded as a period of waiting. It is the time available to businesses, professionals, architects, engineers, designers and competent public authorities to understand the changes and prepare for them.

TTR Centre has already begun preparing a more extensive study, which is expected to be completed and published in the coming period. The study examines the changes in greater detail, the timetable for their implementation and, most importantly, the challenges they create for micro-enterprises.

What is changing

Regulation (EU) 2024/3110 retains key elements of the previous European framework, including CE marking and harmonised technical specifications, but considerably broadens its underlying approach.

Greater importance is placed on technical documentation, traceability and product information. Where required, the Declaration of Performance evolves into a Declaration of Performance and Conformity. The responsibilities of manufacturers, importers, distributors and other economic operators are strengthened, while environmental information based on life-cycle assessment will gradually be incorporated into the regulatory framework. At the same time, the transition towards a circular economy is strengthened, with greater emphasis on product durability, repairability, reuse, disassembly and recycling.

The Regulation also introduces a European Digital Product Passport system. This will make it possible to bring together, in digital and machine-readable form, the Declaration of Performance and Conformity, safety information, instructions for use and other information required for the particular product.

The Digital Product Passport is not simply a QR code, nor does it already apply to every construction product. Relevant acts of the European Commission, technical infrastructure and new specifications for individual product families are still required. The direction of travel, however, is clear: in the future, it will no longer be sufficient merely to state that a product complies. The information supporting it will need to be reliable, accessible and capable of accompanying the product throughout its life cycle.

Particular importance is also attached to the installation of products in construction works. For products and systems whose declared performance depends on the way they are installed, compliance with the manufacturer’s instructions, the use of the specified materials and components and, where required, the recording of key application details are critical links in the chain of safety and conformity. This need is not limited to fire-resisting doors but extends more broadly to doors, windows, structural timber elements, cladding and other products incorporated into construction works. The Regulation does not establish a general requirement for the certification of every installer or a uniform installation file for every product. It does, however, strengthen an environment in which correct and documented application is essential to preserving declared performance, safety and traceability.

What this means for the wood and furniture sector

Our sector does not constitute a single product category. Structural timber products, wood flooring, cladding, structural timber, doors, windows and other products intended for permanent incorporation into construction works may fall within the scope of the Regulation, depending on their intended use and the applicable technical specification.

However, not all furniture, fitted kitchens or bedroom wardrobes automatically fall within the scope of the Regulation. The name of a product, or the mere fact that it is fixed to a building, is not sufficient in itself to reach a safe conclusion. Its intended use, the way it is placed on the market and the applicable technical specification must be examined.

This does not mean that products falling outside the scope of Regulation (EU) 2024/3110 remain outside the legislative framework. Depending on the product and its use, they may be covered by other European legislation and requirements concerning matters such as general product safety, chemicals and formaldehyde, eco-design, deforestation, the origin of raw materials and environmental performance.

The first task of every business is therefore not to assume that all its products fall within the new Regulation. It is to know precisely which products it places on the market, their intended uses, the technical documents accompanying them and the legislation applying in each case.

The major challenge for micro-enterprises

Most businesses in Cyprus’s wood and furniture sector are micro-enterprises. The same is true across much of Europe. These are often family-run workshops and businesses employing fewer than ten people, without separate legal, compliance, environmental or digital systems departments.

The Regulation includes simplified procedures and specific provisions that may, under certain conditions, be used by micro-enterprises. The existence of a simplification in a legal text, however, does not automatically mean that it can be used easily in practice.

Europe must ensure that technical documentation, environmental data, digital systems and verification procedures are genuinely accessible and economically workable. Otherwise, micro-enterprises may face costs, technical knowledge requirements and bureaucracy that are disproportionate to their size and actual capabilities.

Experience from previous European legislation, such as Directive 2013/34/EU on annual financial statements, reminds us that providing for simplification and making timely and effective use of it at national level are two different things. In Cyprus, unlike in most other Member States, the possibility of meaningful relief for micro-undertakings remained unused for years and, in practical terms, remains unused to this day. A European simplification intended to reduce administrative burdens thus became, in practice, relief in name only.

This precedent should concern us. We should not wait for the same situation to be repeated with Regulation (EU) 2024/3110 as the new technical and digital requirements begin to apply to the different families of construction products.

This is the message that must also reach the European Commission in good time: Europe’s smallest businesses do not need only good intentions written into a Regulation. They need common and affordable tools, practical documentation templates, training, technical support and transitional periods that reflect their actual capabilities.

Preparation without panic but also without complacency

Regulation (EU) 2024/3110 does not require Member States to introduce a particular system for regulating professions, nor does it automatically make the certification of every craftsperson or installer mandatory. Requirements that the Regulation does not contain should not be attributed to it.

It does, however, create an environment in which the quality of application, correct product use, compliance with manufacturers’ instructions, technical documentation and the ability to demonstrate what was used and how it was applied become increasingly important.

Timely information, training and professional competence are therefore not unnecessary burdens. They are prerequisites for enabling the wood and furniture sector, as well as all professional and manufacturing sectors involved in construction and construction products, to remain safe, competitive and reliable within the new European environment.

The transition will be lengthy. Preparation, however, should already have begun. Where it has not, it must begin now with micro-enterprises, not without them.

Michalis Socratous

Director, TTR Centre

President, Cyprus Association of Furniture Manufacturers and Woodworkers

This article is for information purposes, reflects the author’s views and is solely an initiative of TTR Centre. It does not represent an official position of the Cyprus Association of Furniture Manufacturers and Woodworkers, nor does it constitute legal or technical advice or an official interpretation of Regulation (EU) 2024/3110. When applying the Regulation to a particular product or case, reference should be made to the official text, the harmonised technical specifications applicable at the relevant time and the guidance of the competent authorities.