The declaration of performance today
A manufacturer placing a construction product covered by a designated standard on the Great Britain market must draw up a declaration of performance and mark the product. The declaration states the performance of the product in relation to its essential characteristics, expressed against that standard, for a declared intended use. Drawing it up is what makes the manufacturer legally responsible for the conformity of the product with that declared performance.
GOV.UK guidance notes that manufacturers supplying both the GB and EU markets may need declarations that meet each set of requirements separately. That is worth designing for rather than discovering.
It can already be electronic
A copy must be supplied with the product, but it may be supplied electronically, and a delegated regulation sets out the conditions under which it may instead be made available on a website: the declaration must not be altered after it is made available, it must remain available for the period required, and access must be free of charge.
Read as system requirements, those conditions describe immutability, retention and open access. They are a reasonable specification for how any published product record should behave, whether or not the law compels it.
What the EU changes
Under Regulation (EU) 2024/3110 the declaration of performance becomes a declaration of performance and conformity. Articles 13 to 16 cover drawing it up, exemptions, its content and how it is supplied, and Article 15 requires the model set out in Annex V. The declaration is also the first item the construction digital product passport must carry, under Article 76(2).
The regulation applies from 8 January 2026, with a small set of provisions that applied from 7 January 2025 and Article 92 applying from 8 January 2027. It repeals Regulation (EU) No 305/2011 from 8 January 2026 but keeps a long list of its provisions alive until 8 January 2040 for products still covered by the old harmonised standards. Nobody should read a single switch-on date into any of that.
The Great Britain position, stated carefully
There is no instrument in Great Britain that requires a machine-readable declaration. The Construction Products (Amendment) Regulations 2025 allow compliance with corresponding provisions of the new EU regulation to be relied on here, which is a bridge rather than an adoption.
Proposals about product information in the Construction Products Reform White Paper carry the status CONSULTATION. Anything more specific — a format, a schema, a date — is EXPECTED at best.
What to do now
Hold the content of the declaration as data rather than as a document: product type and identification, intended use, the standard, each essential characteristic and declared performance, the assessment route, and the notified or approved body where one is involved.
If those fields live in a structured record, producing a PDF, a web page, a JSON export or whatever is eventually asked for is a rendering problem. If they live only inside a PDF, every new format is a re-typing exercise with a fresh opportunity to introduce an error.