Digital Product Passports for Construction Products: What Companies Need to Know

Executive Summary

The construction digital product passport is created by Regulation (EU) 2024/3110, the new Construction Products Regulation, adopted on 27 November 2024 and published at OJ L, 2024/3110 on 18 December 2024. Chapter X of that Regulation, Articles 75 to 80, establishes a construction digital product passport system and sets out what a passport must contain, how it must behave and who may write to it.

The single most important fact about it is the one most likely to be misreported. There is no fixed calendar date on which construction product passports become mandatory. Article 75(1) requires the Commission to adopt a delegated act setting up the passport system. Article 80(1) then works in relative time: six months after that delegated act enters into force the system must be fully operational, and eighteen months after it enters into force the manufacturer obligation in Article 22(7) applies. Until the Article 75(1) delegated act exists and its date of entry into force is known, the date on which any given manufacturer must publish a passport cannot be calculated. Anyone quoting you a firm construction DPP deadline today is either quoting the general application date of the Regulation, which is a different thing, or inventing one.

That does not mean there is nothing to do. The Regulation itself applies from 8 January 2026, with a group of provisions already applying from 7 January 2025 and penalties from 8 January 2027. It repeals Regulation (EU) No 305/2011 from 8 January 2026, with a long transition. And crucially, the passport is not new content: Article 76(2)(a) builds it out of the declaration of performance and conformity under Article 15, the general product information and safety information under Article 22(6), the technical documentation under Article 22(3), the label under Article 22(9) and the unique identifiers under Article 79(1). Almost everything the passport will carry is something a construction product manufacturer is, or is becoming, obliged to produce anyway. The passport is the digital delivery of an existing documentary world, extended with environmental performance.

This is why construction is a genuinely different sector from batteries. Batteries got a passport requirement with a hard date and a fixed annex of content. Construction products got a passport that is deferred in time but continuous with an established conformity and documentation regime that most manufacturers already operate. The battery question is “how do I build this before February 2027”. The construction question is “how good is my declaration, technical documentation and environmental data, because that is what will be published”.

This guide is written for regulatory and technical compliance staff, product managers, environmental and LCA specialists, data and IT teams, and for the very large number of small construction product manufacturers who have none of those as separate roles. It separates four things throughout: law, meaning Regulation (EU) 2024/3110 and measures adopted under it; harmonised technical specifications and standards, which are a different kind of instrument; implementation practice, meaning choices your organisation makes; and tieback educational models, which are teaching frameworks with no legal status.

The guide creates no new framework. It applies the models the library already teaches. Nothing here is legal advice, and the adoption status of measures under the new CPR changes; verify the current position on EUR-Lex before making any decision with legal consequences.

Table of Contents

• What Is a Construction Product Digital Product Passport?
• Which Construction Products Are Affected?
• When Do Construction Product Passport Requirements Apply?
• Who Is Legally Responsible?
• What Information Goes Into a Construction Product Passport?
• Where Does the Data Come From?
• Declarations, Technical Documentation and Evidence
• Standards and Interoperability
• Identifiers, Data Carriers and Access
• Supplier and Value Chain Data
• Enterprise Architecture
• Data Quality and Validation
• Evidence and Assurance
• Keeping the Passport Current
• Enforcement
• Practical Implementation Roadmap
• Worked Example
• Common Mistakes
• Preparation Checklist
• Frequently Asked Questions
• Key Takeaways
• Related Articles
• Related Glossary Terms
• References
• About This Article

What Is a Construction Product Digital Product Passport?

The word “passport” makes people think of a new document. It is more accurate to think of it as a governed publication surface over documents that already exist. To use it correctly you have to keep six things apart, because in construction they are routinely collapsed into one another.

Three features of the construction passport deserve attention immediately, because they differ from the general Digital Product Passport picture people arrive with.

First, it is product-type oriented rather than item oriented. Article 76(2)(d) requires the passport to correspond to the product type and its unique identification code under Article 22(5). Batch and serial identification exists under Article 22(5) where available, but the passport is anchored to the type. A manufacturer of cement or insulation board is not being asked to create a distinct record per pallet.

Second, it is long-lived. Article 75(2)(i) requires the system to be accessible for a period of 25 years after the last product corresponding to its product type has been placed on the market, with the economic operator making the passport available for at least 10 years. Buildings outlast product lines, and the passport is designed around that.

Third, it is explicitly built to interoperate in two directions. Article 75(2)(a) requires the construction passport system to be compatible with, interoperable with and based upon the Digital Product Passport established by Regulation (EU) 2024/1781, the ESPR, without compromising interoperability with Building Information Modelling (BIM). That BIM clause has no analogue in any other passport regime and tells you what construction passports are ultimately for: feeding the digital models in which buildings are designed, built, maintained, refurbished and eventually deconstructed.

Which Construction Products Are Affected?

Scope in construction is answered in two stages, and conflating them is the most common analytical error in the sector.

Stage one: is the product within the Regulation at all? Regulation (EU) 2024/3110 lays down harmonised rules for the marketing of construction products. Article 12 addresses the relationship with other Union law, and Articles 14, 59, 60 and 61 provide exemptions and simplified routes, including for micro-enterprises and for custom-made non-series products. Article 76(4) states directly that products for which the Article 14 exemption from drawing up a declaration of performance and conformity is applied are also exempt from the obligation to provide a digital product passport. The passport duty travels with the declaration duty.

Stage two: is the product covered by a harmonised technical specification? This is where construction differs most sharply from batteries. Article 13(1) triggers the declaration obligation where a product is covered by a harmonised technical specification adopted in accordance with Articles 5 or 6. Under Article 5 the Commission requests European standardisation organisations to draft harmonised standards laying down essential characteristics and assessment methods for one or more product families or categories; Article 6 provides for other harmonised technical specifications. Where no such specification covers a product, the European Assessment Document and European Technical Assessment route applies instead.

The practical consequence is that construction products do not all arrive at the same requirements on the same day. Coverage is built product family by product family, through specifications adopted over time. A product family whose harmonised technical specification is adopted early will face detailed, specific essential characteristics sooner than one whose specification comes later. Two products sitting next to each other on a builders’ merchant shelf can be in materially different regulatory positions.

There is one further scoping point specific to sustainability. The Regulation and the ESPR are designed to coexist rather than compete, with the Commission indicating that priority for setting sustainability requirements will generally be given to the ESPR, with the exception of cement, where the CPR route is used. If you make a product that could plausibly fall under either instrument, establish which is intended to govern it before designing anything.

When Do Construction Product Passport Requirements Apply?

This section requires more legal discipline than any other, so it is set out in strict layers. Each layer is a different kind of date and they are not interchangeable.

Article 22(7) is worth reading in its own words, because it is the operative duty:

“By 18 months after the entry into force of the delegated act referred to in Article 75(1) the manufacturer shall make available a digital product passport referred to in Article 76, through the construction digital product passport system referred to in Article 75, connected to a data carrier referred to in Article 18(2), point (g).”

So the honest position, stated plainly: no universal product-level construction DPP date can currently be given from primary sources. It is contingent on the Article 75(1) delegated act and, for the content that will actually be declared, on the harmonised technical specifications adopted for your product family. What can be stated is the arithmetic. Once the Article 75(1) act enters into force, the clock is six months to an operational system and eighteen months to your obligation, and Article 80(1) expressly permits voluntary use in the interim.

Who Is Legally Responsible?

The library already teaches responsibility in the Legal Responsibility Model, which arranges roles in three bands: potential legal accountability, role-dependent responsibility, and contributing or supporting roles. This section applies that model to the CPR rather than restating it.

Under Regulation (EU) 2024/3110 the roles are defined with unusual precision:

• Article 20 sets obligations of all economic operators.
• Article 22 sets obligations of manufacturers, and it is Article 22(7) that carries the passport duty, Article 22(3) the technical documentation duty, Article 22(5) the unique identification code duty, Article 22(6) the general product information and safety information duty and Article 22(9) the labelling provision.
• Article 23 covers authorised representatives.
• Article 24 covers importers and Article 25 distributors.
• Article 26 is the deemed-manufacturer provision: cases in which the obligations of manufacturers apply to importers and distributors. Anyone who places a product on the market under their own name or trade mark, or modifies a product already placed on the market in a way affecting its declared performance or compliance, should read it before assuming they are a distributor.
• Article 27 covers fulfilment service providers and Article 28 online marketplaces.
• Article 29 covers online and distance sales, and requires the offer to indicate, where required, the CE marking, the Article 18(2) information, the Article 22(9) label and a data carrier connected to a digital product passport in accordance with Article 22(7).

The statutory duty in Article 22(7) sits with the manufacturer. Article 76(1) adds the substantive standard: the information in the passport shall be accurate, complete and up to date. Article 75(2)(d) then separates a different question, which is who may write to the record: the delegated act is to determine which actors, including manufacturers, authorised representatives, importers, distributors and digital product passport service providers, may introduce or update information. Write access is not accountability. A service provider permitted to update a passport does not thereby acquire the Article 22(7) duty.

Four kinds of responsibility must therefore be kept apart:

What Information Goes Into a Construction Product Passport?

Article 76(2)(a) lists the contents. Grouping them by category is more useful than reciting them, and each item below is marked with how firmly it is fixed today.

Required by current law, in the sense that Article 76(2) already names it:

Dependent on product or family. What the declaration actually says is set by the harmonised technical specification or European assessment document applicable to your product. Article 15(1) requires performance to be expressed in relation to essential characteristics “in accordance with the relevant harmonised technical specifications or European assessment document”, and Article 15(3) requires the declaration to cover at least performance over the life cycle for certain listed characteristics. Two manufacturers with equally complete passports may declare entirely different characteristics because their families differ.

Dependent on a future measure or standard. The structure, format, access levels, identifier lifecycle rules and service-provider requirements are all to be settled by the Article 75(1) delegated act, which may under Article 75(2)(h) lay down more detailed or alternative rules to those in the ESPR for identifiers, data carriers, digital credentials and the registry. Article 77(2) allows other Union legislation to require or permit additional information in the passport, in accordance with that same delegated act. None of this can be designed to precisely today.

Implementation practice. How you version records internally, how you store evidence behind a declared value, what internal identifiers you use, how you stage a review before publication and how you connect the passport to your own or your customers’ BIM environments are your choices. They are not legal requirements and should never be presented internally as though they were.

Where Does the Data Come From?

Here the library’s Passport Data Origin Model does the work. It teaches that passport information is assembled rather than stored in one place, that every element has an origin, an authoritative source and evidence, and that publishing something does not make you its authority. The table below applies that existing model to representative construction product content. It is an application, not a new model.

Read each row across: this information, originating here, authoritative here, supported by this evidence.

Two things this table is designed to make unavoidable. First, no single system owns this. Identity and commercial attributes sit in ERP and PIM, engineering definition in PLM or a document system, performance in laboratory reports, constancy in factory production control, environmental performance in an LCA tool, and assessment outcomes with external bodies. Second, the authoritative source is frequently not you. For a laboratory-measured value the laboratory is authoritative; for a European Technical Assessment the Technical Assessment Body is. You remain responsible for what you declare and publish, which is a different thing from being the author of the underlying fact.

Declarations, Technical Documentation and Evidence

Construction is unusual among Digital Product Passport sectors because it arrives with a mature, codified documentation and conformity environment already in place. Understanding how the passport sits on top of that environment, rather than displacing it, is the core intellectual task of this guide.

Work from the bottom up.

Assessment methods come from the specification. Under Article 5 the Commission requests European standardisation organisations to draft harmonised standards laying down essential characteristics and their assessment methods for product families or categories; Article 6 provides for other harmonised technical specifications. Where no harmonised technical specification covers a product, a European Assessment Document may be developed and a European Technical Assessment issued by a Technical Assessment Body. Which route applies to you determines what “performance” even means for your product.

Testing and calculation produce values. Initial type testing, type calculation, and life cycle assessment produce the numbers. Articles 59 to 61 provide simplified procedures, including replacement of type-testing and type-calculation, use of simplified procedures by micro-enterprises, and custom-made non-series products. Where those simplified routes are used, Article 22(3)(e) requires the technical documentation to record it, and Article 76(2)(a)(iii) requires the resulting specific sections to be in the passport.

Constancy of performance is verified through the assessment and verification system. Article 10 and Annex IX set out the assessment and verification systems, abbreviated AVS in the new Regulation. Annex IX opens by requiring the manufacturer to determine the product type correctly and apply the corresponding product category on the basis of the applicable harmonised technical specification or European assessment document, and where a notified body is involved, requires the notified body to verify under Article 55(1) that this was done correctly. Under the most stringent system, System 1+, the manufacturer carries out factory production control and further testing of samples to a prescribed test plan while the notified body exercises full control including audit sample testing. Lower systems involve the notified body progressively less, down to systems where the manufacturer’s own factory production control carries the weight.

The technical documentation is the basis of everything declared. Article 22(3) requires the manufacturer to draw up technical documentation “as the basis for the declaration of performance and conformity”, indicating the declared use falling within the applicable intended use, all relevant elements necessary to demonstrate performance and conformity, information on the procedures in place, information on the applicable system or systems set out in Annex IX, information on any simplified procedures applied under Articles 59 to 61, and the calculation of environmental sustainability performance.

The declaration expresses the result. Article 13 triggers the obligation, Article 14 provides exemptions, Article 15 sets the content using the Annex V model, and Article 16 governs supply. Article 15(1) requires performance to be expressed in relation to essential characteristics in accordance with the applicable specification or assessment document, and requires the declaration to state where Article 7 product requirements have been demonstrated. Article 15(2) requires the declaration to include environmental sustainability performance over the life cycle in respect of the predetermined environmental essential characteristics in Annex II for those characteristics that are declared, calculated with the latest version of software made available free of charge on the Commission’s website. That software provision is unusual and operationally significant: software updates become mandatory one year after publication and may be applied voluntarily from publication, which means your declared environmental figures have a maintenance obligation attached to them independent of any change to your product.

The passport publishes it. Article 76(2)(a)(i) puts the declaration in the passport; Article 76(2)(a)(iii) puts the technical documentation in it; Article 77(1)(h) requires the declaration in the passport to follow the guidelines issued under Article 16(3); and Article 77(1)(d) requires passport information to be based on open standards in an interoperable, machine-readable, structured, searchable and transferable format without vendor lock-in, while expressly exempting documents provided together with the declaration and the technical documentation from that formatting obligation where justified for technical reasons.

That last exemption is the clearest textual signal that the passport does not dissolve the documentary world beneath it. Structured data and attached documents coexist by design.

The library’s evidence lifecycle and conformity assessment material explain how to run this generally. Applied to construction, the practical instruction is short: every declared value should be traceable to a specific test report, calculation run or assessment with an identifiable author, date, method and scope, and that traceability should exist before publication rather than being reconstructed under audit.

Standards and Interoperability

The library’s Standards Landscape Model distinguishes binding EU law, product-specific legal requirements, harmonised standards where applicable, other standards and technical specifications, and implementation choices. That distinction is not repeated here; what matters is that construction bends it in one specific way.

Under Regulation (EU) No 305/2011 the standardisation route ran principally through harmonised standards developed by European standardisation organisations and cited in the Official Journal. The new Regulation retains that route in Article 5, where the Commission may request one or more European standardisation organisations under Article 10 of Regulation (EU) No 1025/2012 to draft harmonised standards laying down essential characteristics and their assessment methods. But it adds Article 6, covering other harmonised technical specifications, giving the Commission a route to adopt harmonised technical specifications itself. The umbrella term in the new Regulation is therefore “harmonised technical specification”, of which a harmonised standard is one species.

Placed in the landscape model, for construction products:

• Binding EU law: Regulation (EU) 2024/3110 itself, and delegated and implementing acts adopted under it, including the Article 75(1) passport act.
• Product-specific legal requirement: the essential characteristics and product requirements that apply to your product family through harmonised technical specifications under Articles 5 and 6 and product requirements under Article 7. Article 7 is titled in terms of product requirements and harmonised standards conferring a presumption of conformity, so the presumption of conformity mechanism operates here as elsewhere in Union product law.
• Harmonised standard where applicable: a standard drafted under an Article 5 standardisation request, once it is in force for your family. Article 95(3) preserves standards referenced under the old Regulation until withdrawn or repealed.
• Other standard or technical specification: European Assessment Documents, and any voluntary standards you choose to use for internal quality, data exchange or environmental methodology.
• Implementation choice: your data model, your integration approach, your internal identifiers and your BIM strategy.

Two specific interoperability requirements are law rather than choice. Article 75(2)(a) requires the construction passport system to be compatible with, interoperable with and based upon the ESPR Digital Product Passport, without compromising interoperability with BIM. Article 77(1)(d) requires passport information to be based on open standards without vendor lock-in. Article 78 sets the essential requirements governing technical design and operation, including access, storage and trade-secret protection, and restricts resale of data by passport service providers.

Identifiers, Data Carriers and Access

Keep the chain intact, in this order, because every confused conversation about construction passports collapses two adjacent links.

Product → identifier → data carrier → access and resolution → digital resource.

• Product. The physical product, belonging to a product type. Construction passports are anchored to the type under Article 76(2)(d).
• Identifier. Two things sit here and should not be merged. Article 22(5) requires a manufacturer-specific unique identification code of the product type, easily visible and legible for users, together with a batch or serial number where available, on the product, or on a label, packaging or accompanying document where the product’s nature makes that impossible. Separately, Article 76(2)(a)(v) and Article 79(1) deal with the unique identifiers in the passport sense, where Article 12 of the ESPR applies unless the Article 75(1) delegated act says otherwise.
• Data carrier. Article 76(2)(b) requires the passport to be connected to one or more data carriers, Article 76(2)(c) requires accessibility through the carrier displayed in accordance with Article 18(2)(g), and Article 77(1)(b) and (c) require it to be affixed accordingly and to comply with Article 79(1). The Regulation does not prescribe a specific carrier technology.
• Access and resolution. Article 76(2)(e) requires the passport to be accessible free of charge to all economic operators, clients, users and authorities through the data carrier, and Article 76(2)(f) requires different levels of access to the system. Article 75(2)(c) makes the delegated act determine which actors, including economic operators, clients, deinstallers, users and competent national authorities, may access what, taking account of intellectual property, sensitive commercial information and the safety of construction works. Article 79(2) and (3) apply Articles 13 and 14 of the ESPR to the registry and web portal unless the delegated act provides otherwise.
• Digital resource. The passport itself, machine-readable and structured under Article 77(1)(d), with attached documents permitted where technically justified.

Two provisions matter more than they look. Article 77(1)(e) prohibits storing personal data relating to the end-user in the passport without explicit consent under Article 6 of Regulation (EU) 2016/679. And Article 77(3) requires a manufacturer placing a product on the market to provide actors selling online or at distance with a digital copy of the data carrier and product identifier, free of charge and within five working days of a request, so that customers who cannot physically access the product can still reach the passport.

Supplier and Value Chain Data

The Supplier Readiness Model already explains how to assess, segment, engage and escalate with suppliers. This section applies it to construction rather than restating it.

Construction supply chains have a particular shape. They are frequently short in tiers but deep in material heterogeneity: an insulation manufacturer may buy from a handful of direct suppliers, but the environmental performance of the finished board depends on binder chemistry, mineral sourcing, energy mix at the supplier’s plant and transport, none of which the direct supplier necessarily holds in usable form. Several dependencies recur:

• Materials. Composition, density, chemistry and any hazardous substance information, with the documentation required under other Union law that Article 76(2)(a)(vi) will pull into the passport.
• Components and key parts. Article 76(2)(a)(vii) requires data carriers of key parts for which a passport is available, so component suppliers’ passport readiness becomes your readiness.
• Environmental information. Upstream life cycle inventory data feeding the Article 15(2) calculation. This is the hardest category, because suppliers are being asked for something they have often never produced, and because it must be usable in the Commission’s prescribed calculation.
• Test evidence. Where a supplier’s material carries its own test results relied on in your declaration, you need the report itself, not a summary.
• Manufacturing information. Process and energy data from suppliers’ own production, where it enters your calculation.

The distinction that decides whether a supplier programme works is between a supplier declaration and validated, accepted evidence. A declaration is an assertion by a party with an interest in the answer. It becomes evidence when it is supported by something checkable: a test report with a named method and date, a certificate, an audit, a chain-of-custody record, or a calculation whose inputs you can inspect. Accepting declarations as though they were evidence is how organisations end up publishing figures they cannot defend.

Enterprise Architecture

The library already teaches architecture in Building an Enterprise Digital Product Passport Architecture, and the layered reference architecture there applies unchanged. Rather than restate it, this section names the three pressures construction puts on it, and then splits the path by organisation size.

Pressure one: document weight. Construction passports carry technical documentation and declaration attachments, expressly exempted from the structured-format requirement where technically justified. This is a document management problem as much as a data problem, and organisations that model only structured attributes will discover the gap late.

Pressure two: very long retention. Article 75(2)(i) contemplates accessibility for 25 years after the last product of a type is placed on the market, with the operator making the passport available for at least 10 years, and Article 75(2)(f) requires the delegated act to establish procedures for availability after insolvency, liquidation or cessation of activity, including back-up by service providers. Ordinary product data retention assumptions do not survive this.

Pressure three: the BIM boundary. Article 75(2)(a) requires interoperability with Building Information Modelling not to be compromised. Your passport data will be consumed by design and asset systems you do not control, over decades.

SME path

Most construction product manufacturers in the EU are small. The Regulation itself recognises this: Article 60 provides for use of simplified procedures by micro-enterprises and Article 61 for custom-made non-series products. Nothing in Articles 75 to 80 requires an enterprise software programme. A proportionate SME path looks like this:

• Manual entry where appropriate. For a small catalogue of product types, maintaining declaration content by hand, with a review step, is legitimate and auditable.
• Controlled spreadsheets and files. One controlled workbook per product type, with a single named owner, an explicit version and a change log, beats an uncontrolled database.
• Document and evidence upload. A simple, consistently named folder structure holding test reports, calculations, factory production control records and certificates, each linked to the declared value it supports.
• Lightweight integration. Export from your accounting or ERP system for identity and commercial attributes; do not attempt to integrate the environmental calculation until the data behind it is stable.

Enterprise path

For manufacturers with large catalogues across multiple sites and countries:

• ERP, PIM and PLM each hold a defined slice; the ERP versus PIM versus PLM distinction should be settled before integration, not during.
• Master and reference data. Product type coding, essential characteristic vocabularies, unit handling and specification references need a single governed definition, or every site will declare differently.
• Document and evidence repositories with retention aligned to the passport horizon rather than to ordinary business retention.
• APIs and integration into whatever the Article 75(1) delegated act ultimately requires, built behind an internal interface so the external contract can change without a rewrite.
• Governance, in the sense the programme governance model describes: decision rights over what is declared, and who may authorise a change.
• Scalable publication, so that a specification change affecting four hundred product types is a controlled batch operation rather than four hundred manual edits.

Data Quality and Validation

The Data Validation Control Model sets out the control types; construction supplies unusually sharp examples of each.

The construction-specific trap is unit and class drift across languages and markets. The same product declared in five Member States, translated by different parties under Article 16(4), acquires inconsistencies that no single reviewer sees. Validate the source values once and control translation as a derived artefact.

Evidence and Assurance

The Evidence Lifecycle and the Assurance Model apply here in full. The point worth pressing for construction is this: publication is not proof of substantive correctness.

Construction professionals sometimes assume the opposite, because the sector’s conformity machinery is genuinely strong. A notified body has been involved; a certificate exists; therefore the number must be right. But notified body involvement is scoped by the applicable assessment and verification system in Annex IX, and in the lower systems the notified body does far less than people imagine. Under Article 15(1) the manufacturer declares; under Article 76(1) the manufacturer must keep the passport accurate, complete and up to date. A correctly formatted, fully populated, system-validated passport can still contain a wrong value, and the format tells nobody it is wrong.

Practical assurance for a construction passport programme therefore tests three distinct things:

1. Is the requirement analysis right? Have we correctly identified the applicable harmonised technical specification or assessment document, the essential characteristics, the assessment and verification system and the product requirements?
2. Is the evidence sufficient and current? Does every declared value have live, in-scope evidence, and has anything expired, been superseded or been invalidated by a process change?
3. Does the published result faithfully represent the evidence? Not “did publication succeed”, but “does what a client sees match what we can prove”.

Keeping the Passport Current

Article 76(1) is a continuing obligation: the information shall be accurate, complete and up to date. The Operating Model explains how to run that as an operation. The construction-specific triggers are:

• Product change. A reformulation, a changed binder, a new raw material source or a design revision that affects a declared characteristic.
• Manufacturing change. A new production line, a new site, a changed process or a changed energy supply, which can move environmental performance without changing the product at all.
• Evidence expiry or supersession. A test report superseded by retesting, a certificate lapsing, an audit cycle completing, a European Technical Assessment reaching the end of its usable life.
• Corrected declarations. Where an error is found, the correction must propagate to the declaration, the technical documentation, the label, the instructions and the passport together.
• Standards change. A revised or withdrawn harmonised technical specification, a new version of an assessment method, or transition out of the Article 95 arrangements as old standards and European Assessment Documents reach their limits in 2031, 2036 and 2040.
• Calculation software change. Article 15(2) makes updates to the Commission’s environmental calculation software mandatory one year after publication. Your figures can require recalculation even when nothing about your product has changed. This trigger has no equivalent in other passport regimes and is easily forgotten.
• Regulatory change. New delegated or implementing acts, including any amendment under Article 80(2) to functionalities or to Articles 77(1) and 78 for ESPR compatibility.
• Product withdrawal. Ceasing to place a product type on the market does not end the record. Article 75(2)(i) contemplates accessibility for 25 years after the last product of the type is placed on the market, with at least 10 years of availability by the operator.

Enforcement

The Enforcement Lifecycle explains how supervision moves from an applicable requirement through market surveillance to corrective or restrictive action, and it is not repeated here. Three construction-specific observations:

First, the passport is a surveillance instrument by design. Article 76(3)(b) states that the requirements are to facilitate the verification of product compliance by competent national authorities, and Article 75(2)(c) puts those authorities among the actors whose access the delegated act must determine. A passport makes your declared position permanently and cheaply inspectable, which changes the practical probability of a discrepancy being noticed.

Second, information non-compliance and substantive non-compliance are different findings. A missing or inaccessible passport is a defect in the record. A product that does not achieve its declared performance is a defect in the product. They attract different responses, and conflating them leads organisations to treat a publication failure as a crisis and a substantive discrepancy as an administrative fix.

Third, penalties have their own date. Article 92 applies from 8 January 2027 under Article 96, later than the Regulation’s general application date, and penalties themselves are set by Member States.

Practical Implementation Roadmap

The Implementation Roadmap already provides the stage model. What follows translates it into construction product preparation. It creates no second roadmap.

Worked Example

Common Mistakes

Preparation Checklist

Scope and applicability

• Inventory every product type you place on the EU market, with its unique identification code.
• For each, record whether a harmonised technical specification under Article 5 or 6 covers it, or whether the European Assessment Document and European Technical Assessment route applies.
• Record whether Article 14 exemption, Article 60 micro-enterprise simplification or Article 61 custom-made treatment applies, and note that Article 76(4) removes the passport duty where the Article 14 exemption is used.
• Confirm which instrument governs sustainability requirements for your product where both the CPR and the ESPR could plausibly apply.

Requirements

• Derive the essential characteristics you must declare for each product type.
• Identify applicable Article 7 product requirements.
• Identify the predetermined environmental essential characteristics from Annex II that you declare.
• Record the applicable assessment and verification system from Annex IX and the notified body tasks it entails.

Data and evidence

• Map every required element to origin, authoritative source and evidence.
• Age-check every test report and calculation against the current product and process.
• Bring factory production control records at every plant onto a comparable basis.
• Establish whether you can produce the Article 15(2) environmental calculation at all, and if not, what is missing.

Suppliers

• Segment suppliers by what you need: composition, environmental data, test evidence, key-part passports.
• Distinguish declarations already held from evidence already held, and quantify the gap.
• Put data requirements into contracts and qualification criteria rather than into email requests.

Documentation

• Confirm the Article 22(3) technical documentation exists, is current and records the assessment and verification system and any simplified procedures used.
• Confirm the declaration, label under Article 22(9) and instructions under Article 22(6) are mutually consistent in every language you publish.

Systems and operation

• Choose the SME or enterprise path deliberately rather than by default.
• Set retention for passport-relevant records against the Article 75(2)(i) horizon.
• Put the mandatory calculation software update cycle into the compliance calendar.
• Name an owner for each change trigger.

Governance

• Establish who may authorise a change to a declared value.
• Establish who signs off a passport before publication.
• Establish how a discovered error is corrected across the declaration, documentation, label, instructions and passport together.

Frequently Asked Questions

When do I have to publish a construction product passport? No calendar date can currently be given from the Regulation. Article 22(7) requires it eighteen months after the entry into force of the delegated act referred to in Article 75(1), and Article 80(1) requires the system to be fully operational six months after that same act. Until the act exists and its date of entry into force is known, the obligation date cannot be calculated.

Isn’t 8 January 2026 the deadline? That is the general date of application of Regulation (EU) 2024/3110 under Article 96, and the date from which Regulation (EU) No 305/2011 is repealed under Article 94. It is not the passport date.

Can I publish a passport voluntarily before then? Article 80(1) states that the system may be used by manufacturers voluntarily in the interim period between the system becoming operational and the obligation applying.

Does the passport replace the declaration of performance and conformity? No. Article 76(2)(a)(i) puts the declaration into the passport. The declaration continues to be drawn up under Articles 13 to 15 using the Annex V model, and Article 77(1)(h) requires the version in the passport to follow the guidelines issued under Article 16(3).

Does it replace my technical documentation? No. Article 22(3) still requires it, and Article 76(2)(a)(iii) publishes it.

Do I need a QR code? The Regulation requires connection to one or more data carriers affixed in accordance with Article 18(2)(g) and complying with Article 79(1). It does not name QR codes or any other specific technology.

Do I need a GTIN or GS1 Digital Link? Not under Regulation (EU) 2024/3110 as it stands. Article 79(1) applies Article 12 of the ESPR for unique identifiers and data carriers unless the Article 75(1) delegated act lays down more detailed or alternative rules. Treat any specific syntax as an implementation choice today.

Is the passport per item or per product type? It corresponds to the product type and its unique identification code under Article 76(2)(d). Article 22(5) separately requires a batch or serial number on the product where available.

Who can see what? Article 76(2)(e) requires free access through the data carrier for economic operators, clients, users and authorities, and Article 76(2)(f) requires different levels of access. Article 75(2)(c) leaves the detailed allocation to the delegated act, taking account of intellectual property, sensitive commercial information and the safety of construction works.

How long must the passport remain available? Article 75(2)(i) requires the system to be accessible for 25 years after the last product of the type is placed on the market, and requires the economic operator to make the passport available for at least 10 years.

What happens if my company ceases trading? Article 75(2)(f) requires the delegated act to establish procedures ensuring availability after insolvency, liquidation or cessation of activity, including a back-up system by passport service providers.

Are my existing harmonised standards still usable? Article 95(3) provides that harmonised standards referenced under Article 17(5) of Regulation (EU) No 305/2011 and in force on 8 January 2026 remain valid under that Regulation until withdrawn by the Commission or otherwise repealed.

What about my European Technical Assessment? Article 95(4) provides that European Assessment Documents referenced by 8 January 2026 remain valid until 9 January 2031, and that European Technical Assessments issued under them cannot found placing on the market after 9 January 2036.

Is my notified body or Technical Assessment Body still valid? Article 95(2) deems bodies designated under Regulation (EU) No 305/2011 to be designated under the new Regulation, but requires them to be assessed and designated anew at the latest by 8 January 2030.

Does the CPR passport conflict with the ESPR passport? It is designed not to. Article 75(2)(a) requires the construction system to be compatible with, interoperable with and based upon the ESPR passport, without compromising BIM interoperability.

Does the ESPR or the CPR set my sustainability requirements? The instruments are designed to coexist, with priority for sustainability requirements generally given to the ESPR, with the exception of cement. Establish which governs your product before designing anything.

Are penalties in force? Article 92 applies from 8 January 2027 under Article 96. Penalties themselves are a matter for Member States.

We sell online. Anything extra? Article 29(2) requires the offer to indicate, where required, the CE marking, the Article 18(2) information, the Article 22(9) label and a data carrier connected to a passport under Article 22(7). Article 77(3) requires the manufacturer to supply distance sellers with a digital copy of the data carrier and product identifier free of charge within five working days of request.

Can personal data go in the passport? Article 77(1)(e) prohibits storing personal data relating to the end-user without explicit consent under Article 6 of Regulation (EU) 2016/679.

What should we do first, today? Get the product type inventory, the specification coverage per type and the age and scope of your test evidence under control. None of that depends on the delegated act, and all of it is required whatever the delegated act says.

Key Takeaways

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• Battery Passport
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Related Glossary Terms

• Digital Product Passport
• Declaration of Performance and Conformity
• Harmonised Technical Specification
• Harmonised Standard
• Technical Documentation
• Notified Body
• Conformity Assessment
• Presumption of Conformity
• Economic Operator
• Authorised Representative
• Product Identifier
• Data Carrier
• Delegated Act
• Entry Into Force
• Market Surveillance Authority
• Sustainability Data
• Authoritative Source
• Data Quality
• Product Lifecycle
• ESPR

References

• Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2024 laying down harmonised rules for the marketing of construction products and repealing Regulation (EU) No 305/2011, OJ L, 2024/3110, 18.12.2024: https://eur-lex.europa.eu/eli/reg/2024/3110/oj
• Regulation (EU) No 305/2011 laying down harmonised conditions for the marketing of construction products, OJ L 88, 4.4.2011: https://eur-lex.europa.eu/eli/reg/2011/305/oj
• Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR): https://eur-lex.europa.eu/eli/reg/2024/1781/oj
• Regulation (EU) No 1025/2012 on European standardisation: https://eur-lex.europa.eu/eli/reg/2012/1025/oj
• Regulation (EU) 2019/1020 on market surveillance and compliance of products: https://eur-lex.europa.eu/eli/reg/2019/1020/oj
• Regulation (EU) 2016/679, the General Data Protection Regulation: https://eur-lex.europa.eu/eli/reg/2016/679/oj
• European Commission, construction products policy and the Construction Products Regulation: https://single-market-economy.ec.europa.eu/sectors/construction/construction-products-regulation-cpr_en
• European Commission, Digital Product Passport: https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/digital-product-passport-dpp_en
• EUR-Lex, register of delegated and implementing acts, for the current adoption status of measures under Regulation (EU) 2024/3110: https://eur-lex.europa.eu/homepage.html

About This Article

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