Industry · Construction products & building materials
The product passport for construction products: the industry with its own legal basis.
Construction products do not run via the ESPR but via the new Construction Products Regulation (EU) 2024/3110 – it is already in force and introduces a dedicated construction-products DPP, expected step by step ~2029–2030. Declaration of performance and proof of conformity go digital, environmental data from EPDs becomes a mandatory component. If you still maintain PDF DoPs today, you have a clear roadmap ahead of you.
- (EU) 2024/3110New Construction Products Regulation in force – its own DPP legal basis
- ~2029–2030Construction products DPP expected, step by step per product family
- DoP → digitalDeclaration of performance & conformity become machine-readable
- EN 15804EPDs as the data basis for environmental information in the passport
01 — Situation
Not ESPR but CPR: the special route for construction products.
While textiles, furniture or electronics get their product passport via the ESPR and delegated acts, the construction sector has its own route: the new Construction Products Regulation (EU) 2024/3110 is in force and anchors the Digital Product Passport directly in construction products law. The obligation is expected step by step ~2029–2030, depending on when the harmonised technical specifications of the individual product families are revised.
An important intermediate step comes considerably earlier: the European Commission’s official DPP timeline already lists DPP requirements for construction products for Q2 2027 – the legal and system foundations of the construction passport thus emerge long before the obligation per product family. Anyone planning to digitise declarations of performance and EPD data only in 2029 will be late.
The core of the transition: what manufacturers provide today as a declaration of performance (DoP) and CE conformity documentation in PDF form will in future be carried digitally, machine-readably and product-specifically in the passport – complemented by environmental, use-phase and circularity information. Environmental product declarations (EPDs) under EN 15804 thereby move from voluntary marketing collateral to the central data basis.
On top of that comes a second front: anyone processing steel or aluminium will receive the ESPR product passports for iron & steel (act expected Q4 2026) and aluminium (expected 2027) as input-material data in their own supply chain. All dates in the DPP timeline.
02 — Requirements
What data the construction products DPP is likely to require.
The details will be set by the harmonised technical specifications per product family – but structure and direction already follow from the new CPR:
Digital declaration of performance (DoP)
The declared performances – load-bearing capacity, fire behaviour, thermal conductivity and more – machine-readable instead of a PDF in the download folder.
Conformity & CE marking
Proofs of conformity, notified bodies and certificates digitally referenced on the product – verifiable for market surveillance and building authorities.
Environmental data & EPDs
Environmental indicators under EN 15804 (GWP and further impact categories) – EPD data moves from the brochure annex into the structured passport.
Substances of concern
Substances of concern in building materials and construction chemicals – compatible with REACH/SCIP obligations, in future with clear product linkage.
Use-phase & circularity information
Installation, maintenance and deconstruction guidance, reusability and recycled content – the basis for circular construction and building resource passports.
Unique identifier + data carrier
Product identifier with a QR data carrier on the product, packaging or accompanying document – granularity per product family (type/batch).
How many of your declarations of performance exist as structured data – not as PDFs?
At most manufacturers: hardly any. That is exactly where construction products readiness begins – in a short call we will show you what the path from PDF DoP to digital passport looks like.
03 — Approach
Construction products readiness in five steps.
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1
Applicability check
Check the range against the new CPR and the ESPR input-material groups (steel, aluminium): which product families are hit by what – and in which order?
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2
Data audit DoP & EPD
Take stock of declarations of performance, test certificates, certificates and EPDs: what exists in structured form, what only as PDF – and where is environmental data missing entirely?
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3
Input-material & supplier data
Structure data requests to raw-material and input-product suppliers – from cement through steel to construction chemicals, prioritised by volume and tender pressure.
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4
Data model & systems
DPP data model per product family, identifier logic (type/batch level), connection to ERP/PIM and the existing DoP processes.
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5
Pilot product passport
A real construction product with a QR identifier, digital DoP and EPD data as a machine-readable passport – the blueprint for rollout by ~2029/2030.
04 — FAQ
Frequently asked questions from construction product manufacturers.
When does the Digital Product Passport become mandatory for construction products?
The new Construction Products Regulation (EU) 2024/3110 is in force – that is fixed. The construction products DPP itself is expected step by step ~2029–2030, depending on when the harmonised technical specifications of the respective product family are revised. These dates are indicative and can differ per product family. Important: the European Commission’s official DPP timeline already lists DPP requirements for construction products for Q2 2027 – the foundations emerge well before the obligation itself.
Does the ESPR or the Construction Products Regulation apply to us?
For construction products within the scope of the CPR, the construction products DPP under (EU) 2024/3110 applies. There are still touchpoints with the ESPR: steel and aluminium get their own ESPR product passports (expected Q4 2026/2027) – as input materials of your products. In the applicability check we clarify which sets of rules concretely hit your range.
Will our EPDs become mandatory?
The new CPR anchors environmental information far more firmly in construction products law; EPD data under EN 15804 is the established data basis for it. Those already maintaining EPDs have a head start – the decisive step is making the results available in structured, product-specific form instead of as a PDF document.
We are a merchant or importer – does this affect us?
Yes. Importers assume manufacturer obligations when they place products from third countries on the EU market, and trade must in future ensure that passport data remains available. Anyone running private labels is effectively in the manufacturer role.
What should we do now, concretely?
Three things: (1) transfer DoP, test-certificate and certificate data from PDFs into structured article data, (2) check EPD coverage across the range and prioritise gaps, (3) organise supplier data for input materials (steel, aluminium, construction chemicals). Then you are ready to go as soon as your product family is up.
Contact
From PDF DoP to digital passport – the transition needs lead time.
Tell us briefly which product families you manufacture or trade – you will get an honest assessment of when you are affected and what makes sense now.
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