Ahmet Alptekin Kasar
Founder, Managing Director
Updated: 2026-11-02
This guide is for contractors, site managers, energy consultants, builders' merchants and procurement teams at developers who have to document the products built into a project in Hungary or elsewhere in the EU. The general rules of CE marking are summarised in our CE marking guide. Here the question is narrower: which document to ask for with insulation, and what to look at in it. The examples are real documents: the declarations for ODE Starflex glass wool, ODE Isıpan XPS and the BK45 vapour control layer.
What a declaration of performance is
Under Article 4 of Regulation (EU) No 305/2011, the Construction Products Regulation (CPR), the manufacturer of a product covered by a harmonised standard draws up a declaration of performance when placing it on the market. By doing so, the manufacturer assumes responsibility for the product's conformity with the declared performance (Article 4(3)).
Hungarian law defines the same document. Point 15 of § 2 of Government Decree 275/2013 (X. 16.) (in Hungarian) calls it, in our translation, "a document issued by the manufacturer of a construction product that authentically certifies the product's performance in line with the technical specification for the product".
Article 6 and Annex III of the CPR fix the content: the product-type identification code, the intended use, the manufacturer, where relevant the authorised representative, the system of assessment and verification of constancy of performance (AVCP), the dated harmonised standard, the notified body and the declared performances. Where no performance is declared for an essential characteristic, the letters "NPD" (No Performance Determined) appear (Article 6(3)(f)).
Reading a real DoP line by line
The ODE Starflex declaration is No 101, revision 7, dated 3 February 2026. One declaration covers several products and variants: ODE Starflex, Lunaflex and Evomineral, as blanket and board. The table under point 7 gives the values per variant.
| DoP field | Value in the ODE Starflex DoP (No 101) | What to check | Source |
|---|---|---|---|
| Number | 101 (Rev.7, 2026-02-03) | the CE marking refers to this number | ODE DoP; CPR Article 9(2) |
| 1. Product type | ODE Starflex / Lunaflex / Evomineral, blanket and board | matches the label and delivery note | ODE DoP |
| 5. AVCP | System 1 and System 3 | a notified body is involved | ODE DoP; CPR Annex V |
| 6a. Harmonised standard | EN 13162:2012+A1:2015 | dated, fits the product family | ODE DoP; CPR Annex III |
| Notified bodies | NB 1020, NB 2164 | same number on the CE marking | ODE DoP; CPR Article 9(2) |
| 7. λD | 0.039 W/(m·K) in the 25–240 mm blanket column (RD 0.60–6.15 m²K/W) | at or below the requirement; EKR: λ ≤ 0.039 | ODE DoP; Decree 41/2025 (XII. 30.) EM, 1.3.1.1 eb) |
| 7. Reaction to fire | A1 (unfaced, glass tissue, woven glass textile, aluminium foil faced); C-s1,d0 (aluminium-kraft faced) | the class of the variant actually delivered | ODE DoP |
Each line can be checked on its own. The product type must match the label and the delivery note. The AVCP system tells you who assessed what: under System 1 a notified product certification body decides on the certificate of constancy of performance; under System 3 a notified laboratory assesses the performance (CPR Annex V). The standard is given with its date, the notified body with its identification number (Annex III).
Under point 7, read the column for the variant you are buying. The same declaration gives A1 for the unfaced product and C-s1,d0 for the aluminium-kraft faced one. Our article on reaction to fire classes explains the classes. Where point 7 shows NPD, the DoP makes no statement on that characteristic. In the ODE glass wool declaration, water vapour diffusion resistance is one such line.
The other two examples read the same way. The ODE Isıpan XPS declaration (No 201) cites EN 13164:2012+A1:2015 under System 3, with notified body NB 2164. Thermal conductivity is 0.035 (STD 100 and PRM 300) and 0.038 (STD 200), reaction to fire E. The BK45 vapour control layer declaration of performance (DOP-BBARIYER-LW-BK45/082025-01) is issued in Hungarian, English and German under System 3 and declares Sd 20 m. In the "authorised representative" field, EuConX ISO Kft. is named. What an Sd value means is covered in our Sd value guide.
When the DoP is enough
In Hungary, § 3 of Government Decree 275/2013 (X. 16.) links the DoP to the project. Under paragraph (1)(a) the designer sets the expected performance of the products in the design documents. Under paragraph (2)(a) conformity with that expected performance is, as a rule, proven by the manufacturer's declaration of performance. Paragraph (3), in our translation: "Where legislation sets a requirement for a construction product, it is a condition of the product's incorporation that the declaration of performance contains the product characteristic proving conformity with the requirement."
Two examples from the single-family house data sheet of Hungary's EKR energy-efficiency scheme (Decree 41/2025 (XII. 30.) EM, Annex 1, point 1.3.1.1). Sub-point eb) asks for a thermal conductivity of at most 0.039 W/(m·K) for non-blown insulation; the ODE Starflex DoP contains λD 0.039. Sub-point g) asks for a vapour control layer of at least Sd 20 m under the insulation; the BK45 DoP contains Sd 20 m. If a requirement concerns a characteristic marked NPD, the declaration does not prove it.
Whether a product may be built in is decided by the designer and the responsible site manager. This article quotes the regulations; it is not legal advice.
The CE marking follows the DoP
Under Article 8(2) of the CPR, the CE marking is affixed only to products for which the manufacturer has drawn up a declaration of performance. No DoP, no CE marking. Article 9(2) lists what follows the marking: the last two digits of the year it was first affixed, the manufacturer's name and address, the product-type code, the reference number of the DoP, the declared level or class, the harmonised technical specification, the notified body's number where applicable, and the intended use.
On site, the CE label can therefore be checked against the DoP. The DoP number, the standard and the notified body number should be the same on both. The CE marking is not a quality award: under Article 8 it shows that the manufacturer takes responsibility for the declared performance.
Voluntary certificates add to the DoP
The DoP is mandatory; the other papers are voluntary. A EUCEB certificate concerns the chemical composition of mineral wool fibres; see our EUCEB article. An EPD summarises environmental data; see our article on the ODE EPD (in Hungarian). Neither gives λD or a reaction to fire class in place of the DoP. Quality assurance for imported materials is covered in a separate article (in Hungarian).
How the DoP is supplied
Article 7 requires a copy of the DoP for each product made available, on paper or electronically. When a batch of the same product goes to a single user, one copy may accompany it. The recipient can ask for a paper copy. The DoP may also be made available on a website under conditions set by the Commission (Article 7(3)). Under Article 7(4) the declaration "shall be supplied in the language or the languages required by the Member State where the product is made available".
This comes up often with material shipped from Türkiye. The full sourcing process is described in our guide on sourcing insulation from Turkey.
The new Construction Products Regulation
Regulation (EU) 2024/3110 has applied since 8 January 2026. Under its Article 94, Articles 4 to 9 and Annex III of Regulation (EU) No 305/2011 are repealed only from 8 January 2040. Under Article 95(3) and (8), harmonised standards listed under the old regulation and in force on 8 January 2026 remain valid, and the old DoP and CE rules apply to the products they cover. The declarations shown here were drawn up under 305/2011 and cite EN 13162:2012+A1:2015 and EN 13164:2012+A1:2015.
What we send
With the quote and the delivery we send the declaration of performance and the related documents for the product: for ODE Starflex glass wool the DoP and the EUCEB certificate, for the BK45 and BD70 membranes their DoPs. Road transit from Türkiye to Hungary takes 3–5 days, about 5 on average, and we deliver across Hungary.
Ask for the product's DoP together with the quote: contact · +36 30 485 0258 · info@euconx.com. We reply the same working day.
Frequently asked questions
What is a declaration of performance (DoP)?
A document drawn up by the manufacturer that states the product's performance in relation to its essential characteristics. Under Article 4 of Regulation (EU) No 305/2011 it is mandatory for products covered by a harmonised standard.
What should I check in an insulation DoP?
The product type, the intended use, the AVCP system, the dated harmonised standard, the notified body number and the values under point 7: λD, reaction to fire and, for membranes, Sd. Read the column for the variant actually delivered.
Is the CE marking on the pack enough?
It does not replace the DoP. The CE marking may only be affixed when a DoP exists, and the DoP reference number must appear with it (CPR Articles 8 and 9).
Can a EUCEB certificate or an EPD replace the DoP?
No. Both are voluntary. EUCEB concerns the chemical composition of the fibres, an EPD the environmental data. λD and the reaction to fire class come from the DoP.
In which language must the DoP be supplied?
Under Article 7(4) of the CPR, in the language or languages required by the Member State where the product is made available. A paper copy can be requested.
What changed on 8 January 2026?
Regulation (EU) 2024/3110 became applicable. The DoP and CE rules of 305/2011 (Articles 4 to 9) still apply to products covered by harmonised standards listed under the old regulation, and are repealed only from 8 January 2040.
Sources
1. Regulation (EU) No 305/2011 (Construction Products Regulation), Articles 4, 6, 7, 8, 9, Annexes III and V, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0305
2. Government Decree 275/2013 (X. 16.), § 2 point 15 and § 3 (1)–(3), National Legislation Database (in Hungarian): https://njt.jog.gov.hu/jogszabaly/2013-275-20-22
3. Regulation (EU) 2024/3110, Articles 94, 95 and 96, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3110
4. ODE Starflex / Lunaflex / Evomineral declaration of performance No 101, Rev.7: https://ode.com.tr/_upload/pdf/GLASSWOOL_BLANKET-BOARD_DECLARATION_OF_PERFORMANCE_-_EN_13162.pdf
5. ODE Isıpan XPS declaration of performance No 201: https://ode.com.tr/_upload/pdf/ODE_ISIPAN_PERFORMANS_BEYANI_-_EN_13164.pdf
6. BK45 declaration of performance DOP-BBARIYER-LW-BK45/082025-01: https://euconx.com/downloads/dop/euconx-bk45-dop.pdf
7. Decree 41/2025 (XII. 30.) EM, Annex 1, 1.3.1.1 eb) and g), Magyar Közlöny 2025/160 (in Hungarian): https://magyarkozlony.hu/hivatalos-lapok/p1UZBNSoHiBBftW595F66949b7f7ae914/dokumentumok/5858f900426cb56e532a468a989dbb1417d9aef0/letoltes
8. EuConX company data (transit, reply time, delivery across Hungary)
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