Compliance Guide · CE EN 14041 · EU Procurement Reference
CE Declaration of Performance
for Flooring — A Complete Guide
for EU Importers and Contractors
By Ecoflors Export Team · May 2026 · 10 min read · EU Compliance Reference
The direct answer — what the CE DoP is and why it matters
The CE Declaration of Performance (DoP) is the legal document that gives the CE mark its validity under the EU Construction Products Regulation (CPR, Regulation 305/2011). A CE mark without a DoP is not legally valid. For flooring, the DoP is issued under harmonised standard EN 14041 and must declare the product’s performance against fire classification (Bfl-s1), dimensional stability, slip resistance, and other essential characteristics. Critically, for Dutch Bouwbesluit and German public building tenders, the name on the DoP must be your company — not the Chinese factory. A DoP naming a Chinese manufacturer is not a valid tender document in the Netherlands or Germany. Ecoflors reissues CE DoPs in the buyer’s company name as standard for all distributor programme members.
What the EU Construction Products Regulation Actually Requires
Most flooring importers know they need CE marking. Far fewer understand what CE marking legally consists of — and what it specifically requires of the party placing the product on the EU market. This distinction matters enormously for distributors sourcing from China.
The EU Construction Products Regulation (Regulation 305/2011, known as the CPR) requires that any construction product — including flooring — placed on the EU market must carry CE marking. Specifically, CE marking is not a quality mark or a safety approval. It is a declaration by the manufacturer or importer that the product meets the essential requirements of the relevant harmonised European standard. For resilient flooring, that standard is EN 14041.
EU CPR Article 4 — The legal obligation
CPR Article 4 states that manufacturers who place a construction product on the EU market must draw up a Declaration of Performance when the product is covered by a harmonised standard. The Declaration of Performance is the legal document — the CE mark on the packaging is simply its physical expression. A product carrying the CE symbol without a corresponding DoP is not CE-marked in the legal sense and cannot be lawfully sold in any EU member state. Furthermore, CPR Article 11 makes the manufacturer legally responsible for the accuracy of the DoP — and “manufacturer” under the CPR includes importers who place products on the EU market under their own name.
This last point is where most distributors sourcing from China encounter problems. If a Dutch distributor imports SPC flooring from a Chinese factory and sells it under their own brand name in the Netherlands, they become the “manufacturer” under the CPR — even though they did not physically produce the product. Consequently, the CE DoP should name the Dutch distributor as the issuing party, not the Chinese factory. Furthermore, the Dutch distributor is legally responsible for the accuracy of all declared performance values.
What a CE DoP Contains — Field by Field
A CE Declaration of Performance under EN 14041 has a standardised format. Every field is legally significant. Here is what each section means for a procurement manager reviewing a supplier’s documentation.
01
Unique product identifier
The specific product code or range name to which the DoP applies. Procurement managers should verify this matches the actual product being ordered — a DoP for one product does not cover a different SKU from the same factory.
Mandatory
02
Intended use
States the application for which the product is CE-marked — typically “floor covering for use in buildings for residential and commercial use.” If your project requires a specific use environment (e.g. healthcare, wet areas), confirm this is covered by the declared intended use.
Mandatory
03
Name and contact address of the manufacturer
This is the field that creates compliance problems for EU distributors sourcing from China. If this field names a Chinese factory, the DoP is issued by that factory — not by the EU distributor. For Dutch Bouwbesluit and German public procurement, the DoP must name the EU entity placing the product on the market. Ecoflors reissues this field in the buyer’s company name for all OEM programme members.
Critical for tenders
04
System of assessment and verification (AVCP)
For EN 14041, the AVCP system is System 3 — meaning a notified body conducts the initial type testing, but ongoing production control is managed by the manufacturer. The notified body number must be stated on the DoP.
Mandatory
05
Harmonised technical specification
States “EN 14041:2004+A1:2006” for resilient flooring. This confirms which version of the standard the product was tested against. Procurement managers should verify this matches the standard referenced in their project specification.
Key field
06
Declared performance table — essential characteristics
The performance table is the technical core of the DoP — the values that procurement managers actually use for specification compliance. This section must declare each characteristic either with a specific value (e.g. Bfl-s1 for fire), a class (e.g. EN 685 Class 33/42 for wear resistance), or “No Performance Determined” (NPD) where the manufacturer has not tested for that characteristic. NPD is a legitimate response — but an NPD for fire class on a commercial project specification is a tender failure.
Most important
07
Signature and date
The DoP must be signed by the named manufacturer and dated. An undated DoP is not valid. Furthermore, a DoP with a date more than 5 years old should be verified — EN 14041 was amended in 2006, and some older DoPs may reference superseded test methods.
Mandatory
The Declared Performance Values — What to Look for in the Table
The performance table in a CE DoP for EN 14041 flooring typically covers the following essential characteristics. Procurement managers should check each one against their project specification before accepting a supplier’s documentation.
| Characteristic |
Ecoflors declared value |
Standard / test method |
Why it matters for your project |
| Reaction to fire |
Bfl-s1 |
EN 13501-1 · EN 13823 |
Mandatory for EU commercial buildings. Dutch Bouwbesluit, German MVV TB, and UK Approved Document B all require Bfl-s1 minimum. An NPD here is a tender failure for any commercial project. |
| Dimensional stability |
≤0.10% (EN ISO 23999) |
EN ISO 23999 · ASTM F2199 |
Critical for SPC — determines whether the floor will remain stable under temperature cycling. ≤0.10% is required for EN 685 Class 33/42 commercial specification and for underfloor heating compatibility. |
| Slip resistance |
DS (EN 13893) · R10 (DIN 51130) |
EN 13893 · DIN 51130 |
Required for wet commercial zones — healthcare corridors, commercial kitchens, bathrooms. DS class under EN 13893 is the EU standard; R10 under DIN 51130 is the German standard. Both should be declared for EU commercial specification. |
| Electrical resistance |
NPD (not applicable) |
EN 1081 |
Only relevant for conductive or anti-static flooring in data centres or operating theatres. NPD is correct for standard commercial SPC and LVT. |
| Thermal resistance |
≤0.15 m²K/W |
EN 12664 · EN 12667 |
Relevant for underfloor heating — lower thermal resistance means better heat transfer. ≤0.15 m²K/W confirms UFH compatibility without significantly reducing system efficiency. |
| VOC emissions |
E1 (≤0.124 mg/m³ formaldehyde) |
EN 16516 · ISO 16000 |
Declared under EN 16516 as part of EN 14041 since 2018 amendment. E1 is the minimum threshold — Ecoflors products are significantly below E1 as confirmed by Eurofins IAC Gold. |
| Waterproofness |
Pass |
EN 13553 |
Confirms the flooring is suitable for wet area use where water may be present on the surface. Required declaration for bathrooms, commercial kitchens, and wet commercial zones. |
Why the Certificate Holder Name Changes Everything
This is the issue that catches most EU importers sourcing from China. When a Chinese factory issues a CE DoP, they are the “manufacturer” named on the document. The DoP is legally valid — but it names the factory, not the EU distributor.
“A DoP naming a Chinese factory is a valid CE document for product traceability. It is not a valid document for a Dutch Bouwbesluit tender — because the named party must be a legally accountable EU entity.”
Here is why this matters in practice. When a Dutch housing corporation (Woningcorporatie) or a German public building authority evaluates a tender submission, they need to be able to hold a legally accountable party responsible for the product’s performance claims. That party must be identifiable, reachable, and subject to EU law. A Chinese factory’s name and address satisfies the technical requirements of the DoP format — but it does not satisfy the legal accountability requirement of Dutch and German public procurement.
Furthermore, in the event of a product failure, the EU distributor who imported and sold the product is legally liable under CPR Article 13 — regardless of what the factory’s DoP says. Consequently, from a legal risk perspective, the EU distributor should be named on the DoP as the issuing party in any case.
🇳🇱
Netherlands — Bouwbesluit
CE DoP mandatory for all flooring placed on the NL market
Bouwbesluit requires Bfl-s1 fire classification declared on DoP for commercial buildings
Woningcorporaties tenders increasingly require DoP naming the NL distributor, not the factory
EN 685 Class 42 minimum for common areas — must be confirmed in product documentation (not part of CE DoP but required alongside it)
🇩🇪
Germany — MVV TB / DIBt
CE DoP mandatory — additionally, EN 16511 (Leistungsverzeichnis) required for most commercial tenders
Public buildings require AgBB VOC evaluation — not satisfied by CE DoP alone
Bfl-s1 required under MVV TB for schools, healthcare, government buildings
German procurement authorities often require the German-language DoP — request a DE version from your supplier
🇬🇧
United Kingdom — UKCA post-Brexit
Since January 2025: UKCA marking required for products placed on the UK market — CE mark alone no longer sufficient
UK suppliers must issue a UK Declaration of Performance under the equivalent UK standard to BS EN 14041
Bfl-s1 under BS EN 13501-1 required for Approved Document B compliance
Ecoflors provides UKCA documentation alongside CE DoP for all UK-bound shipments
🇫🇷
France — CE + COV A+
CE DoP mandatory — standard EU CPR requirement applies
COV Classe A+ mandatory additionally under Décret n°2011-321 — the CE DoP does not satisfy this requirement independently
VOC emissions class must be stated on product packaging in French — the A+ label is a separate legal requirement from the CE DoP
Eurofins IAC Gold test report covers COV A+ alongside CE for French market compliance
What to Request From Your Supplier — The Complete Checklist
Most procurement managers know to ask for “CE certification” — but a CE mark without the correct supporting documents is insufficient for EU commercial tender submissions. Here is the complete documentation checklist that every EU flooring importer and contractor should request before signing a purchase contract.
01
CE Declaration of Performance — in your company name
Request the DoP with your company named as the manufacturer/importer. Confirm the document references EN 14041:2004+A1:2006. Verify the fire class is stated as Bfl-s1 — not NPD. Check that the product identifier on the DoP matches the product you are ordering.
Mandatory
02
Bfl-s1 fire classification certificate — EN 13501-1
The DoP declares the fire class, but the underlying test report from the notified body is what procurement authorities request for verification. Specifically, request the EN 13823 (SBI test) and EN ISO 11925-2 (ignitability test) reports that support the Bfl-s1 classification. These are different documents from the DoP itself.
Mandatory · EU commercial
03
EN ISO 23999 dimensional stability test report
For SPC flooring, the dimensional stability figure (≤0.10%) is critical for commercial specification and UFH compatibility. The test report confirms the actual measurement — not just the declared class. Request this specifically for the thickness you are ordering, as stability can vary between thicknesses.
Critical for SPC
04
FloorScore certificate — SCS-FS-05154
Required for LEED v4 EQ Credit 2 and BREEAM Mat 03 IAQ credits. Quote the certificate number on your LEED/BREEAM submission. Can be verified directly on the SCS Global Services online database. Ecoflors certificate applies to all SPC and LVT product lines.
LEED · BREEAM
05
GREENGUARD Gold certificate — 135464-420 / 135462-420 / 135463-420
Required for WELL v2, NHS procurement, schools, and healthcare. Quote the product-specific certificate number — SPC click (135464-420), Dryback LVT (135462-420), or Loose Lay LVT (135463-420). Verifiable on the UL Product iQ database.
NHS · Schools · WELL
06
Eurofins IAC Gold test report — for EU national VOC requirements
Required for German public buildings (AgBB), France (COV A+), Belgium (Belgian VOC regulation), and any project targeting EU Taxonomy Article 9/10. This single document covers all EU national VOC schemes simultaneously. Request the full test report, not just the certificate number.
Germany · France · Belgium
07
ISO 9001:2015 quality management certificate
Confirms the factory operates a certified quality management system with annual surveillance audits. Required for most public procurement frameworks and strongly preferred by housing associations and institutional buyers in NL, DE, and UK.
Preferred
08
UKCA Declaration of Performance — for UK market only
Since January 2025, products placed on the UK market require UKCA marking and a separate UK DoP under the equivalent UK standard. CE marking alone is no longer accepted for UK building projects. Request this additionally if supplying UK buyers.
UK only
The Three Most Common CE DoP Mistakes — and How to Avoid Them
❌ Common mistake 1
Accepting a DoP with “NPD” for fire class
Some suppliers issue DoPs with “No Performance Determined” for reaction to fire — meaning they have not tested or certified the fire class. This is technically a valid DoP format, but a product with NPD for fire class cannot be specified for any EU commercial project. Dutch Bouwbesluit and German MVV TB require a declared Bfl-s1 minimum. Always check the fire class field explicitly.
✓ Correct approach
Verify Bfl-s1 is explicitly declared — not NPD
The performance table must state “Bfl-s1” (note: lowercase s, not S1) for reaction to fire under EN 13501-1. Request the underlying EN 13823 test report alongside the DoP to verify the classification was tested by an accredited notified body, not self-declared.
❌ Common mistake 2
Using a factory DoP for a Dutch or German tender
A DoP naming a Chinese factory as the manufacturer is valid for product traceability purposes — but it is not a suitable tender document for Dutch Woningcorporaties or German public building procurement, where the named party must be a legally accountable EU entity. Submitting a Chinese factory’s DoP to a Dutch housing association tender is a compliance risk.
✓ Correct approach
Request the DoP reissued in your company name
For OEM distributors, the CE DoP should name your company as the manufacturer/importer. Ecoflors reissues CE DoPs in the buyer’s company name as standard for all distributor programme members — making the document directly submittable on any EU tender without identifying the underlying factory.
❌ Common mistake 3
Confusing CE DoP with FloorScore or GREENGUARD
CE DoP (under EN 14041) and FloorScore/GREENGUARD Gold are completely different certification schemes serving different purposes. CE DoP is legally mandatory for EU market access. FloorScore and GREENGUARD Gold are voluntary IAQ certifications for green building programmes. They are not substitutes for each other — a project may require all three simultaneously.
✓ Correct approach
Understand which certification each tender clause requires
Read tender specifications carefully. CE DoP covers EU market access and fire classification. FloorScore covers LEED/BREEAM IAQ credits. GREENGUARD Gold covers NHS and school sensitive environment requirements. Eurofins IAC Gold covers German AgBB and French COV A+. Each serves a different compliance function.
How Ecoflors handles CE DoP for distributor programme members
For all Ecoflors distributor programme members, the CE Declaration of Performance is reissued naming your company as the certificate holder — not Ecoflors and not the factory. This makes the document directly submittable on any EU tender without identifying the underlying manufacturer. Furthermore, Bfl-s1 fire classification, EN ISO 23999 dimensional stability (≤0.10%), EN 13893 slip resistance (DS class), and EN 16516 VOC class are all declared on the DoP per shipment. German-language and French-language versions are available on request at no additional charge.
Frequently Asked Questions
What is a CE Declaration of Performance for flooring?
A CE Declaration of Performance (DoP) is a legal document issued under the EU Construction Products Regulation (CPR, Regulation 305/2011) that declares the performance characteristics of a flooring product against harmonised standard EN 14041. It covers reaction to fire (Bfl-s1), dimensional stability, slip resistance, thermal resistance, VOC emissions, and waterproofness. The DoP is mandatory for all flooring placed on the EU market — without it, a CE mark is not legally valid.
Why does the name on the CE DoP matter for EU tenders?
Dutch Bouwbesluit, German public procurement, and most EU institutional tender frameworks require the CE DoP to name the party legally responsible for placing the product on the EU market. If the DoP names a Chinese factory, the document may not be accepted for Dutch Woningcorporaties tenders or German public building specifications — because the named party must be a legally accountable EU entity traceable under EU law. EU distributors importing from China under their own brand should request the DoP reissued in their company name.
What is the difference between a CE mark and a CE Declaration of Performance?
The CE mark is the physical symbol applied to the product or packaging. The Declaration of Performance (DoP) is the underlying legal document that gives the CE mark its validity. A CE mark without a DoP is not legally valid. When a procurement manager asks for “CE certification”, they are asking for the DoP — the document that declares the specific performance values the product has been tested and certified to achieve.
Is a CE DoP the same as FloorScore or GREENGUARD certification?
No. CE DoP (under EN 14041) is legally mandatory for EU market access and covers fire classification, dimensional stability, and other structural performance characteristics. FloorScore and GREENGUARD Gold are voluntary certifications specifically for indoor air quality (VOC emissions), used for green building programme credits (LEED, BREEAM, WELL). They are not substitutes for each other — a project may require CE DoP and FloorScore and GREENGUARD Gold simultaneously, each serving a different compliance purpose.
What does Bfl-s1 mean on a CE DoP?
Bfl-s1 is the fire classification for floor coverings under EN 13501-1. “B” indicates the floor covering does not significantly contribute to fire spread when tested under EN 13823 (the Single Burning Item test). “fl” specifies this is a floor covering classification. “s1” indicates very limited smoke production when tested under EN ISO 11925-2. Bfl-s1 is the minimum fire class required for flooring in EU commercial buildings under Dutch Bouwbesluit, German MVV TB, and UK Approved Document B. Note: the correct notation is “Bfl-s1” with a lowercase “s” — not the incorrect form with an uppercase S.
Does a CE DoP expire?
CE DoPs do not have a formal expiry date under the CPR. However, if the product’s formulation changes significantly, the manufacturer must issue a revised DoP. Furthermore, if the underlying harmonised standard is revised, DoPs referencing the superseded version may need to be updated. For practical procurement purposes, request a DoP dated within the last 3 years — and verify the document references EN 14041:2004+A1:2006, which is the current version for resilient flooring.
CE EN 14041 · Bfl-s1 · DoP in your company name · Factory direct · EU + UK market
Request a CE DoP in Your Company Name
Every Ecoflors distributor programme member receives a CE Declaration of Performance naming their company as the certificate holder — ready for Dutch Bouwbesluit, German MVV TB, and UK Approved Document B tender submissions. Includes Bfl-s1 fire certificate, EN ISO 23999 stability report, FloorScore SCS-FS-05154, GREENGUARD Gold, and Eurofins IAC Gold per shipment.
