A Spanish manufacturer wants to sell thermal insulation panels in Portugal. The product already carries CE marking, has been tested, and meets the applicable harmonised standards. One document is still missing. The Declaration of Performance, the DoP, has to be available in Portuguese before the product reaches a Portuguese customer. Without that translation, the product's market placement is in technical default, even though the product itself is fully compliant.
Regulation (EU) No 305/2011, the Construction Products Regulation (CPR), requires manufacturers to make the DoP available in the language or languages required by the Member State where the product is placed on the market. Portugal requires Portuguese. There is no exemption for manufacturers already selling in other EU countries with a DoP in another language: each destination market has its own linguistic requirement, and it falls to the manufacturer (or its authorised representative, or the importer) to ensure compliance.
What the DoP is and why translation is a regulatory requirement, not an option
The Declaration of Performance is the document in which the manufacturer takes legal responsibility for a construction product's performance characteristics against a harmonised standard (EN) or a European Technical Assessment. It covers parameters such as reaction to fire, mechanical resistance, thermal insulation, and release of dangerous substances, depending on the product family.
Article 7 of the CPR states that the DoP must be provided on paper or electronically, in the language required by the Member State where the product is made available. This is not a best-practice suggestion. It carries the same legal weight as CE marking or type testing. A market surveillance officer or an institutional buyer, such as a local authority or a public sector contracting body, can request the Portuguese DoP at any point, and its absence is treated as a documentary non-conformity.
Translating a DoP is not a generic linguistic task. It involves:
- Exact normative terminology (designations for EN standards, test methods and performance classes cannot be paraphrased)
- Precise correspondence between reported numerical values, units and the source text
- Preservation of the document's formal structure, which follows the model set out in Annex III of Delegated Regulation (EU) No 574/2014
- Consistency with other technical documents for the same product, such as datasheets and manuals
Critical terminology in a DoP
Translation errors in DoPs tend to cluster in four areas:
- Fire reaction classes: A1, A2-s1,d0, B, C, D, E, F. Never translate or reword the notation, only the surrounding text
- Harmonised standard designations: keep the exact EN reference (for example, EN 13501-1) without adapting the number or the wording of the standard's title
- Intended use: the description of the product's intended use must match the technical assessment exactly, without broadening or narrowing its scope
- Declared performance per essential characteristic: every line in the performance table must correspond one-to-one with the source document, including cases where the correct entry is "NPD" (No Performance Determined)
A mistranslated DoP that widens a product's intended use, even through what looks like a minor translation slip, exposes the manufacturer to civil liability if the product is used under those conditions and fails.
Who signs off and how the translation is validated
The DoP does not typically require certified translation in the sense of notarial or lawyer authentication, because it is not generally a document submitted to a public authority for civil registration or judicial purposes. It is, however, a legally binding document with direct manufacturer liability attached, so the correct practice is:
- Translation by a linguist with technical experience in the construction sector and working knowledge of CE normative terminology
- Review by a second technical reviewer, checked term by term against the source
- Preservation of the layout and section numbering matching the model in Delegated Regulation 574/2014
Manufacturers exporting to several EU markets at once end up needing multiple language versions of the same DoP, all with consistent terminology across them. This matters particularly when the same product family also appears in installation and maintenance manuals, which must use exactly the same technical terms as the DoP. A terminology mismatch between a DoP and the maintenance manual for the same product line creates documentary inconsistency that a market auditor can flag, similar to the issues we cover in our guide to translating industrial maintenance manuals.
How M21Global handles DoP translation
M21Global works with manufacturers and importers in the construction sector who need to place products on the Portuguese, Spanish, French or German market with correct technical documentation. For a DoP, the requirement is always handling by a specialised technical linguist, with validated normative terminology kept consistent across the rest of the product's documentation, following the same discipline described in our technical document translation services overview.
As an ISO 17100 certified provider, M21Global handles regulatory documents like the DoP under its Estratégica tier, which includes translation, review by a second linguist and dedicated quality control, the level of rigour appropriate for a document where a terminology error carries direct legal consequences for the manufacturer. Request a quote for your Declaration of Performance translation and get a response within three business hours.
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Frequently Asked Questions
Does the DoP need to be translated into Portuguese even if the product already has CE marking?
Yes. CE marking confirms the product's conformity, but Article 7 of the CPR requires the DoP to be available in the language required by the destination Member State, which for Portugal is Portuguese, before the product is placed on the market.
Who is responsible for ensuring the DoP is translated correctly?
The manufacturer holds primary responsibility, but the authorised representative or the importer placing the product on the Portuguese market is also accountable for making the translation available.
Does a DoP translation need certification or an apostille?
Generally not. A DoP is not typically a document subject to notarial authentication; what matters is terminological accuracy and consistency with the model set out in Delegated Regulation (EU) No 574/2014.
What does NPD mean in a DoP and how should it be handled in translation?
NPD stands for No Performance Determined, meaning that characteristic was not assessed; the translation must preserve this exactly rather than substituting a free interpretation.
Can the same DoP be used across several EU countries?
The technical content is the same, but each Member State can require its own language version, so manufacturers exporting to multiple markets need several translated versions with consistent terminology across all of them.
