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Two inspectors examining an insulated exterior wall on a building façade.
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Regulations

Construction products in EKR: a catalogue entry is not project eligibility

AI-generated editorial illustration, not a real installation or official EKR record. Product, measure and project evidence must be linked for the relevant case.

EED

EuConX Editorial Desk

Construction-procurement editors

8 min

The short answer

An EKR project involves three separate checks: whether the planned energy-efficiency measure meets the current regulatory conditions; whether the selected construction product and manufacturer documents fit the intended category and use; and whether the actual project is documented and verified as required. Buying an insulation product does not, by itself, create a HEM or guarantee eligibility.

Measures and key-product categories are different lists

Annex 1 of Hungarian Decree 18/2025 (VII. 31.) EM provides the regulatory basis for energy-efficiency measures considered under EKR. Annex 2 lists construction key-product categories. The two annexes address different questions: one concerns the intervention; the other concerns a product group used in construction. Check the current consolidated decree and amendments before relying on either list.

The CEEGEX product list and technical specifications govern market categorisation in the relevant process. They do not replace the measure requirements in the decree or prove that a particular building project qualifies. MEKH information can explain the system but likewise does not decide eligibility for every individual renovation. Read our source map before treating a market document as legislation.

Product paperwork is only one part of evidence

A Declaration of Performance, CE information, technical data sheet or EPD may describe declared product characteristics and intended use. Those papers do not on their own establish a building’s starting condition, area treated, installed thickness, contractor, measurement or the accounting method applicable to resulting savings. Project records and verification requirements depend on the measure and process.

A useful procurement file may include the exact product and variant, current DoP and technical sheet, relevant installation instructions, quantity and lot identification where needed, delivery/acceptance records, and the project documents maintained by the client and installer. This is a practical checklist, not a complete statutory list. Confirm the required evidence with the responsible verifier before work begins.

A safer sequence

Identify the measure and building baseline; check the current decree provision and annex; then confirm the CEEGEX category if the market transaction requires it. Before installation, agree with the verifier what evidence, measurements, declarations and deadlines are needed. Link the procurement records to the delivered product and work performed. The auction result guide describes prices, not eligibility.

Scope and method

NJT, MEKH and CEEGEX sources were checked on 23 September 2026. This article does not approve a product, determine a project’s HEM eligibility or provide legal advice. Current conditions and documents should be confirmed with the responsible specialist.

Three separate checks in one project

First check the planned building-energy measure against the current decree. Separately check the construction product category and manufacturer documents. Finally document the project baseline, work, installation and required verification.

  1. Decree 18/2025 EM · Annex 1

    Measures

    Check the measure and its applicable conditions.

  2. Decree 18/2025 EM · Annex 2

    Key-product categories

    A category listing alone does not prove project eligibility.

  3. Project evidence

    Case-specific

    Records depend on the measure and verification procedure.

Product documents can support the evidence file; they are not the savings calculation itself.

Sources & notes

EKRDecree 18/2025insulationconstruction productsdocumentation