Which AVCP system applies to cables under EN 50575?

Commission Decision 2011/284/EU sets it by reaction to fire class: system 1+ for Aca, B1ca, B2ca and Cca, system 3 for Dca and Eca, and system 4 for Fca. Under system 1+ a notified product certification body determines the product type, inspects the plant and the factory production control, keeps them under continuous surveillance and audit-tests samples taken before placing on the market. Under system 3 a notified testing laboratory determines the product type and the manufacturer runs the factory production control alone. Cca is therefore a system 1+ class, not a system 3 class.

What do s1a, d1 and a1 mean in a cable classification?

They are the additional classifications of Delegated Regulation (EU) 2016/364, Table 4. Smoke s1 means TSP1200 of 50 m2 or less and peak SPR of 0.25 m2/s or less in EN 50399; s1a adds a transmittance of at least 80 % in EN 61034-2, s1b at least 60 % and below 80 %. Droplets d0 means no flaming droplets within 1200 s, d1 none persisting longer than 10 s. Acidity is measured with EN 60754-2: a1 is a conductivity below 2.5 µS/mm and pH above 4.3, a2 below 10 µS/mm and pH above 4.3. These additional classes exist only for B1ca, B2ca, Cca and Dca.

Does Regulation (EU) 2024/3110 already change the cable DoP?

Not yet. The new CPR entered into force on 7 January 2025 and applies from 8 January 2026, but Article 95(3) keeps harmonised standards cited under Regulation 305/2011 valid until withdrawn, and Article 95(8) keeps the old DoP rules for products covered by them. EN 50575 is such a standard. The new obligations, including the declaration of performance and conformity, apply to a product family only one year after the Commission adopts an implementing act covering it (Article 95(9)). Manufacturers may opt in earlier once such an act exists.

Is LSZH the same as a CPR Euroclass?

No. LSZH (low smoke zero halogen) is a commercial description and does not appear in Regulation 305/2011 or in Delegated Regulation 2016/364. The legal performance is the reaction to fire class with its smoke, droplet and acidity additional classifications, for example Cca-s1b,d1,a1. A cable can be advertised as LSZH and hold any class.

Does the CPR CE marking on a cable replace LVD compliance?

No. Decision 2011/284/EU states in a footnote that power, control and communication cables rated between 50 and 1000 V AC or 75 and 1500 V DC are also subject to the Low Voltage Directive. A fixed-installation power cable can therefore carry obligations under both texts: the CPR DoP covers its declared reaction to fire performance, the LVD covers electrical safety. Data cables below those voltages fall outside the LVD but remain within the CPR when permanently installed.

Can a distributor sell a cable under its own brand with its own DoP?

Yes, but it then becomes the manufacturer. Article 15 of Regulation 305/2011 makes an importer or distributor that places a product on the market under its own name or trademark subject to all manufacturer obligations. Article 36(1)(b) lets it declare performance using the test results of the original manufacturer, with that manufacturer's authorisation. For system 1+ classes (Aca to Cca), Article 36(2) requires a notified product certification body to verify that documentation.

Who decides the minimum Euroclass for a building?

The Member States. The CPR harmonises how performance is assessed and declared, not the level required. Article 8(4) of Regulation 305/2011 forbids a Member State to impede the use of CE-marked products when the declared performance corresponds to its requirements for that use, and Article 8(6) requires national methods to follow the harmonised standards. The required class for a given building and cable route comes from national building and fire safety rules.

CPR and EN 50575: cable Euroclasses, AVCP, CPR 2.0

Hugues Orgitello updated 7 Oct 2026 13 min read

A power, control, data or optical fibre cable that is installed permanently in a building is a construction product. Under Regulation (EU) No 305/2011 (the CPR) it is placed on the EU market with a Declaration of Performance (DoP) and the CE marking, against one harmonised standard: EN 50575 with amendment A1:2016. The classes it declares (Aca to Fca, with smoke, droplet and acidity additional classifications) and their numerical criteria are set by Delegated Regulation (EU) 2016/364; who has to test and audit is set by Decision 2011/284/EU. This page works from those texts and from the new CPR, Regulation (EU) 2024/3110, which applies since 8 January 2026 but does not yet change the rules for cables.

Key dates

Date	Event	Source
24 April 2011	Regulation 305/2011 enters into force	Regulation 305/2011, Article 68
12 May 2011	Decision 2011/284/EU fixes the attestation systems for cables (1+ for Aca to Cca, 3 for Dca and Eca, 4 for Fca)	Decision 2011/284/EU, Annex III
1 July 2013	Core provisions of Regulation 305/2011 (DoP, CE marking, AVCP, Annexes III and V) apply	Regulation 305/2011, Article 68
4 April 2016	Delegated Regulation 2016/364 enters into force (published OJ L 68, 15 March 2016) and repeals Decision 2000/147/EC	Delegated Regulation 2016/364, Articles 2 and 3
10 June 2016	EN 50575:2014 and A1:2016 first published in the Official Journal (OJEU) under the CPR	OJ C 209, 2016/C 209/03
1 July 2017	End of the coexistence period: CE marking under EN 50575 is the only route for cables in scope	OJ C 209, 2016/C 209/03
7 January 2025	Regulation 2024/3110 enters into force; Articles 1 to 4 and several standardisation articles apply	Regulation 2024/3110, Article 96
8 January 2026	Regulation 2024/3110 applies; Regulation 305/2011 repealed except the articles kept for legacy standards	Regulation 2024/3110, Articles 94 and 96
8 January 2027	Penalties article (Article 92) of Regulation 2024/3110 applies	Regulation 2024/3110, Article 96
8 January 2030	Latest date for notified bodies designated under 305/2011 to be reassessed and designated anew	Regulation 2024/3110, Article 95(2)
8 January 2040	Remaining legacy articles of 305/2011 (Articles 2, 4 to 9, 11 to 18, Annexes III and V and others) repealed	Regulation 2024/3110, Article 94

Scope: when a cable is a construction product

Article 2(1) of Regulation 305/2011 defines a construction product as a product or kit produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof, whose performance has an effect on the performance of the works with respect to the basic requirements. Article 4(1) then requires a DoP when such a product is covered by a harmonised standard.

For cables, that standard is EN 50575: power, control and communication cables for general applications in construction works subject to reaction to fire requirements. In the last consolidated list of standards under Regulation 305/2011 (OJ C 92, 9 March 2018), EN 50575 and its amendment are the only CENELEC entries. Fire detection and alarm products (EN 54 series) are also on that list, but junction boxes (EN 60670), conduit systems (EN 61386), trunking (EN 50085) and building-integrated photovoltaic modules (EN 50583) are not.

Two consequences follow:

Reaction to fire only. Decision 2011/284/EU also foresees resistance to fire classes for cables (P15 to P120, PH15 to PH120, all under system 1+), but no harmonised standard for them is cited. A fire-resistant cable is CE marked under EN 50575 for its reaction to fire; its circuit integrity performance is not part of that DoP.
The LVD still applies to power cables. A footnote to Decision 2011/284/EU states that cables rated between 50 and 1000 V AC or 75 and 1500 V DC are also subject to the Low Voltage Directive. The CPR DoP and the LVD EU declaration of conformity are different documents with different content, and neither covers EMC, which has its own directive (2014/30/EU).

A cable that is not incorporated permanently in works, such as an appliance cord or a cable inside a cabinet, is not a construction product, so no CPR DoP applies to it.

AVCP systems and the class that triggers them

Annex V of Regulation 305/2011 defines five systems of assessment and verification of constancy of performance (AVCP). Decision 2011/284/EU assigns them to cables by reaction to fire class.

System	Manufacturer does	Notified body does	Cable classes (Decision 2011/284/EU)
1+	Factory production control (FPC), further testing of samples taken at the factory	Product certification body: determines the product type, initial inspection of plant and FPC, continuous surveillance of FPC, audit-testing of samples taken before placing on the market; issues the certificate of constancy of performance	Aca, B1ca, B2ca, Cca
1	FPC, further testing of factory samples	Product certification body: product type, initial inspection, continuous surveillance (no audit-testing)	None for reaction to fire
2+	Product type, FPC, testing of factory samples	FPC certification body: initial inspection and continuous surveillance of FPC	None for reaction to fire
3	FPC	Testing laboratory: determines the product type by type testing on samples taken by the manufacturer	Dca, Eca (and the dangerous substances characteristic)
4	Product type and FPC	No task	Fca

The class drives the route: a manufacturer moving a product from Dca to Cca moves from a notified testing laboratory under system 3 to a notified product certification body with continuous surveillance under system 1+. The NB must be notified for EN 50575.

Two simplifications in Regulation 305/2011 matter for smaller players. Article 37 lets a micro-enterprise treat a system 3 product as system 4, demonstrating equivalence in a Specific Technical Documentation; for cables this concerns Dca and Eca only. Article 36(1)(b) lets a manufacturer use test results of another manufacturer for the same product type, with its authorisation; for system 1+ classes the resulting documentation must be verified by a notified product certification body (Article 36(2)).

Euroclasses: criteria from Delegated Regulation 2016/364

Table 4 of the Annex to Delegated Regulation 2016/364 sets the classes for electric cables. These are the legal criteria; EN 13501-6 is the CEN classification standard that applies them.

Class	Test method	Classification criteria	Additional classifications
Aca	EN ISO 1716	Gross calorific value PCS ≤ 2.0 MJ/kg (product as a whole excluding metallic materials, and any external component such as the sheath)	None
B1ca	EN 50399, 30 kW flame source, and EN 60332-1-2 (the European adoption of IEC 60332-1-2)	FS ≤ 1.75 m, THR1200s ≤ 10 MJ, peak HRR ≤ 20 kW, FIGRA ≤ 120 W/s; H ≤ 425 mm	s, d, a
B2ca	EN 50399, 20.5 kW flame source, and EN 60332-1-2	FS ≤ 1.5 m, THR1200s ≤ 15 MJ, peak HRR ≤ 30 kW, FIGRA ≤ 150 W/s; H ≤ 425 mm	s, d, a
Cca	EN 50399, 20.5 kW, and EN 60332-1-2	FS ≤ 2.0 m, THR1200s ≤ 30 MJ, peak HRR ≤ 60 kW, FIGRA ≤ 300 W/s; H ≤ 425 mm	s, d, a
Dca	EN 50399, 20.5 kW, and EN 60332-1-2	THR1200s ≤ 70 MJ, peak HRR ≤ 400 kW, FIGRA ≤ 1300 W/s; H ≤ 425 mm	s, d, a
Eca	EN 60332-1-2	H ≤ 425 mm	None
Fca	EN 60332-1-2	H > 425 mm	None

FS is flame spread, THR total heat release, HRR heat release rate, FIGRA fire growth rate, H the burnt length in the single-cable vertical test. Dca has no flame spread limit.

Additional classification	Criterion (Delegated Regulation 2016/364, Table 4 notes)
s1	TSP1200 ≤ 50 m² and peak SPR ≤ 0.25 m²/s (EN 50399)
s1a	s1 and transmittance ≥ 80 % in EN 61034-2
s1b	s1 and transmittance ≥ 60 % and < 80 % in EN 61034-2
s2	TSP1200 ≤ 400 m² and peak SPR ≤ 1.5 m²/s
s3	Not s1 or s2
d0	No flaming droplets or particles within 1200 s
d1	No flaming droplets or particles persisting longer than 10 s within 1200 s
d2	Not d0 or d1
a1	EN 60754-2: conductivity < 2.5 µS/mm and pH > 4.3
a2	EN 60754-2: conductivity < 10 µS/mm and pH > 4.3
a3	Not a1 or a2

The smoke class declared for B1ca must come from the 30 kW EN 50399 test, and for B2ca, Cca and Dca from the 20.5 kW test. A declaration therefore reads, for example, Cca-s1b,d1,a1.

Fca is a measured class (the cable failed the 425 mm limit), not "no performance determined". The recitals of Delegated Regulation 2016/364 explain that the earlier F classes meaning "no performance determined" could not be classes under the CPR and were replaced; where a manufacturer declares nothing for a characteristic, Article 6(3)(f) of Regulation 305/2011 requires the letters NPD instead.

Declaration of Performance and CE marking

The DoP model is Annex III of Regulation 305/2011 as replaced by Delegated Regulation (EU) No 574/2014.

DoP point (Annex III, 574/2014 model)	Content for a cable
No	Reference number of the DoP
1	Unique identification code of the product type
2	Intended use(s), as worded in EN 50575
3	Manufacturer: name and contact address
4	Authorised representative, where appointed
5	System(s) of AVCP (1+, 3 or 4 depending on class)
6a	Harmonised standard (EN 50575:2014+A1:2016) and notified body(ies)
7	Declared performance(s), such as the class with s, d and a
8	Appropriate or Specific Technical Documentation, where used
Signature	Name, place and date of issue

Article 7 of Regulation 305/2011 already allows the DoP copy to be supplied on paper or by electronic means, with a paper copy on request; Article 7(3) and Delegated Regulation (EU) No 157/2014 allow it to be made available on a website instead. Article 6(5) requires the REACH Article 31 or 33 information to be supplied with the DoP. Article 11(2) requires the manufacturer to keep the technical documentation and the DoP for 10 years after placing on the market.

Article 9(2) lists what follows the CE marking: the last two digits of the year it was first affixed, manufacturer name and address, unique identification code of the product type, DoP reference number, declared class, the harmonised standard, the notified body number where applicable, and the intended use. Article 9(1) allows it on the product, a label attached to it, the packaging or the accompanying documents when affixing to the product is not possible or not warranted.

Regulation (EU) 2024/3110: what changed and what has not yet

Regulation 2024/3110 was adopted on 27 November 2024, published on 18 December 2024, entered into force on 7 January 2025 and applies from 8 January 2026 (Article 96). It replaces the DoP by a declaration of performance and conformity, which Article 16 requires to be supplied by electronic means (or through a digital product passport, or on a website meeting the conditions of Article 16(2)). A construction digital product passport system is set up under Article 75, and Article 93 asks the Commission to evaluate, by 9 January 2033, how the regulation correlates with the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781.

For cables, the transitional provisions in Article 95 decide what applies today:

Article 2024/3110	What it says	Effect on EN 50575 cables in October 2026
94	305/2011 repealed from 8 January 2026, except Articles 2, 4 to 9, 11 to 18, 27, 28, 36 to 40, 47 to 49, 52, 53, 55, 60 to 64 and Annexes III and V, repealed from 8 January 2040	The DoP, CE marking, AVCP and simplification articles used for cables remain in force
95(3)	Harmonised standards on the 305/2011 list in force on 8 January 2026 remain valid under 305/2011 until withdrawn	EN 50575:2014+A1:2016 remains the basis of the DoP
95(8)	The kept 305/2011 articles apply only to products covered by those standards	Cables keep the 305/2011 DoP regime
95(9)	New obligations for economic operators apply to a product family one year after an implementing act covering it, unless the act sets a later date; voluntary early application is possible	The new declaration of performance and conformity becomes mandatory for cables only after such an act
95(10)	Within one year of that date, the Commission withdraws the old references covering the same family	EN 50575 under 305/2011 stops only then
95(2)	Notified bodies under 305/2011 are deemed notified, and must be reassessed by 8 January 2030 at the latest	Existing cable notified bodies keep working
95(7)	Certificates and test reports under 305/2011 may be used as technical basis under the new rules, under Article 62 conditions	Existing cable test results can be reused

Article 22(7) ties the digital product passport obligation to a delegated act under Article 75(1): it applies 18 months after that act enters into force.

Member State requirements

The CPR harmonises how performance is assessed and declared, not the level a building requires. Article 8(4) of Regulation 305/2011 forbids a Member State to impede the use of CE-marked products when the declared performances correspond to its requirements for that use, and Article 8(6) requires national requirements to use the harmonised methods. The class required for a given building type and cable route therefore comes from national building and fire safety rules, which must be checked in each destination country. A cable with a valid DoP in a low class is lawfully on the market but may not be usable on a route where the national rule asks for a higher class.

Claims the texts contradict

Common claim (including earlier versions of this page)	What the text says
"Cca cables fall under AVCP system 3"	Decision 2011/284/EU, Annex III: Aca, B1ca, B2ca and Cca are system 1+; only Dca and Eca are system 3
"Fca means no performance determined"	Delegated Regulation 2016/364 redefined Fca as H > 425 mm in EN 60332-1-2; "no performance determined" is declared as NPD (Article 6(3)(f) of 305/2011)
"s1a and s1b are based on light transmittance in EN 50399"	s1a and s1b are based on transmittance in EN 61034-2; s1 itself comes from EN 50399
"The a rating uses EN 60754-1 and EN 60754-2"	Table 4 note 29 defines a1 to a3 on EN 60754-2 conductivity and pH only
"Most CPR 2.0 provisions apply from January 2026 and the DoP becomes digital by default for cables"	2024/3110 applies from 8 January 2026, but under Article 95(3), (8) and (9) EN 50575 cables stay under the 305/2011 DoP until an implementing act covers them and one more year passes
"Under 305/2011 the DoP is delivered on paper"	Article 7(1) allows paper or electronic means; Article 7(3) and Regulation 157/2014 allow a website
"The DoP must show the type, batch or serial number"	The Annex III model as replaced by 574/2014 has no such point; it uses the unique identification code of the product type
"For fixed building cables the LVD does not apply to the cable"	Decision 2011/284/EU footnote: cables rated 50 to 1000 V AC or 75 to 1500 V DC are also subject to the LVD
"EN 60670, EN 61386, EN 50085 and EN 50583 are CPR harmonised standards"	The 2018 list of standards under 305/2011 contains EN 50575 as its only CENELEC entry, and none of those four references
"A rebranded cable must always be retested"	Article 15 makes the rebranding distributor a manufacturer; Article 36(1)(b) lets it use the original test results with authorisation, verified by a notified product certification body for system 1+ classes
"The recipient must keep the DoP for ten years"	Article 11(2) puts the 10-year retention on the manufacturer

Practical workflow for a cable placed on the EU market

Confirm scope. Is the cable produced for permanent incorporation in works (CPR, EN 50575) or not? If rated 50 to 1000 V AC or 75 to 1500 V DC, plan the LVD file as well.
Check the class required in each destination Member State for the building type and cable route, and choose the target class.
Derive the AVCP system from Decision 2011/284/EU: 1+ for Aca to Cca, 3 for Dca and Eca, 4 for Fca.
Engage the right body: a notified product certification body for 1+, a notified testing laboratory for 3, none for 4.
Run the tests named in Table 4 of 2016/364: EN 50399 and EN 60332-1-2 for B1ca to Dca, plus EN 61034-2 when claiming s1a or s1b and EN 60754-2 for the acidity class; EN ISO 1716 for Aca; EN 60332-1-2 alone for Eca and Fca.
Operate factory production control, under continuous surveillance for system 1+.
Draw up the DoP on the 574/2014 model, with the REACH information (Article 6(5)), and supply it on paper, electronically or on a website under 157/2014.
Affix the CE marking with the Article 9(2) information.
Keep the DoP and technical documentation for 10 years (Article 11(2)).
Watch for an implementing act under Regulation 2024/3110 covering cables; the new declaration becomes mandatory one year after it unless the act sets a later date.

What to remember

EN 50575:2014+A1:2016 is the harmonised standard for cables under Regulation 305/2011, cited since 10 June 2016, mandatory route since 1 July 2017.
Classes and criteria come from Delegated Regulation 2016/364, Table 4: Aca to Fca, with s1, s1a, s1b, s2, s3, d0 to d2 and a1 to a3 for B1ca to Dca.
AVCP comes from Decision 2011/284/EU: 1+ for Aca, B1ca, B2ca and Cca; 3 for Dca and Eca; 4 for Fca.
Regulation 2024/3110 applies since 8 January 2026, but cables stay on the 305/2011 DoP until an implementing act covers them, plus one year.
Power cables rated 50 to 1000 V AC are also within the LVD; the CPR DoP does not replace the LVD declaration.
Member States set the class required for each use; the CPR sets how it is tested and declared.

Sources & references

Regulation (EU) No 305/2011 laying down harmonised conditions for the marketing of construction products (Articles 4 to 9, 11, 15, 36, 37, 68, Annex V), EUR-Lex eur-lex.europa.eu/eli/reg/2011/305/oj
Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products and repealing Regulation (EU) No 305/2011 (Articles 16, 94, 95, 96), EUR-Lex eur-lex.europa.eu/eli/reg/2024/3110/oj
Commission Delegated Regulation (EU) 2016/364 on the classification of the reaction to fire performance of construction products (Annex, Table 4: electric cables), EUR-Lex eur-lex.europa.eu/eli/reg_del/2016/364/oj
Commission Decision 2011/284/EU on the procedure for attesting conformity of power, control and communication cables (AVCP systems per class), EUR-Lex eur-lex.europa.eu/eli/dec/2011/284/oj
Commission communication 2016/C 209/03, OJ C 209, 10 June 2016: first publication of EN 50575:2014 and EN 50575:2014/A1:2016 under Regulation 305/2011, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52016XC0610(04)
Commission communication 2018/C 092/06, OJ C 92, 9 March 2018: list of harmonised standards under Regulation 305/2011, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018XC0309(09)
Commission Delegated Regulation (EU) No 574/2014 amending Annex III to Regulation 305/2011 (model declaration of performance), EUR-Lex eur-lex.europa.eu/eli/reg_del/2014/574/oj
Commission Delegated Regulation (EU) No 157/2014 on making a declaration of performance available on a website, EUR-Lex eur-lex.europa.eu/eli/reg_del/2014/157/oj

Frequently asked questions

Does the CPR apply to every cable placed on the EU market?: No. A cable needs a Declaration of Performance and the CE marking under the CPR when it is a construction product (produced for incorporation in a permanent manner in construction works) covered by a harmonised standard. For cables that standard is EN 50575:2014 with amendment A1:2016, power, control and communication cables for general applications in construction works subject to reaction to fire requirements. Its references were published in OJ C 209 of 10 June 2016, and the coexistence period with national rules ended on 1 July 2017. Cables that are not incorporated permanently in a building, such as cords supplied with an appliance, are not construction products.
Which AVCP system applies to cables under EN 50575?: Commission Decision 2011/284/EU sets it by reaction to fire class: system 1+ for Aca, B1ca, B2ca and Cca, system 3 for Dca and Eca, and system 4 for Fca. Under system 1+ a notified product certification body determines the product type, inspects the plant and the factory production control, keeps them under continuous surveillance and audit-tests samples taken before placing on the market. Under system 3 a notified testing laboratory determines the product type and the manufacturer runs the factory production control alone. Cca is therefore a system 1+ class, not a system 3 class.
What do s1a, d1 and a1 mean in a cable classification?: They are the additional classifications of Delegated Regulation (EU) 2016/364, Table 4. Smoke s1 means TSP1200 of 50 m2 or less and peak SPR of 0.25 m2/s or less in EN 50399; s1a adds a transmittance of at least 80 % in EN 61034-2, s1b at least 60 % and below 80 %. Droplets d0 means no flaming droplets within 1200 s, d1 none persisting longer than 10 s. Acidity is measured with EN 60754-2: a1 is a conductivity below 2.5 µS/mm and pH above 4.3, a2 below 10 µS/mm and pH above 4.3. These additional classes exist only for B1ca, B2ca, Cca and Dca.
Does Regulation (EU) 2024/3110 already change the cable DoP?: Not yet. The new CPR entered into force on 7 January 2025 and applies from 8 January 2026, but Article 95(3) keeps harmonised standards cited under Regulation 305/2011 valid until withdrawn, and Article 95(8) keeps the old DoP rules for products covered by them. EN 50575 is such a standard. The new obligations, including the declaration of performance and conformity, apply to a product family only one year after the Commission adopts an implementing act covering it (Article 95(9)). Manufacturers may opt in earlier once such an act exists.
Is LSZH the same as a CPR Euroclass?: No. LSZH (low smoke zero halogen) is a commercial description and does not appear in Regulation 305/2011 or in Delegated Regulation 2016/364. The legal performance is the reaction to fire class with its smoke, droplet and acidity additional classifications, for example Cca-s1b,d1,a1. A cable can be advertised as LSZH and hold any class.
Does the CPR CE marking on a cable replace LVD compliance?: No. Decision 2011/284/EU states in a footnote that power, control and communication cables rated between 50 and 1000 V AC or 75 and 1500 V DC are also subject to the Low Voltage Directive. A fixed-installation power cable can therefore carry obligations under both texts: the CPR DoP covers its declared reaction to fire performance, the LVD covers electrical safety. Data cables below those voltages fall outside the LVD but remain within the CPR when permanently installed.
Can a distributor sell a cable under its own brand with its own DoP?: Yes, but it then becomes the manufacturer. Article 15 of Regulation 305/2011 makes an importer or distributor that places a product on the market under its own name or trademark subject to all manufacturer obligations. Article 36(1)(b) lets it declare performance using the test results of the original manufacturer, with that manufacturer's authorisation. For system 1+ classes (Aca to Cca), Article 36(2) requires a notified product certification body to verify that documentation.
Who decides the minimum Euroclass for a building?: The Member States. The CPR harmonises how performance is assessed and declared, not the level required. Article 8(4) of Regulation 305/2011 forbids a Member State to impede the use of CE-marked products when the declared performance corresponds to its requirements for that use, and Article 8(6) requires national methods to follow the harmonised standards. The required class for a given building and cable route comes from national building and fire safety rules.