Construction DPP: five changes since September, and the dates that now matter
TL;DR. No construction product needs a Digital Product Passport yet, and the act that will set up the construction passport system is still expected in the second quarter of 2027. But the ground around it moved this autumn. The EU registry that every passport will be registered in is live, and on 30 October the Commission published its API. The assessment and verification systems for the new regime became law on 17 September. The Commission's Working Plan now gives indicative dates for the first families: cement first, then thermal insulation, doors and windows, flat glass and reinforcing steel in 2029. And Member States are putting enforcement in place, with penalties applying from 8 January 2027. On the Commission's own timing, the passport duty lands between late 2028 and mid-2029. The data work behind it is the part to start now.
The five changes
Since our last pieces in early September, five things have moved. Each has its own section below.
- The EU registry has an API. The registry every passport will be registered in has been live since July; on 30 October the Commission published its technical package.
- The assessment and verification systems are law. Delegated Regulation (EU) 2026/1310 has been in force since 17 September, with a new system 3+ for environmental sustainability.
- The Working Plan's dates are the ones to plan on. Table 3 dates each family's standard, and only cement's request sits under the new regulation.
- The standards moved. CEN-CENELEC Guide 36 now asks for a digital DoPC in every new harmonised standard, the enquiry on prEN 18357 has closed, and the Commission proposed a new standardisation regulation on 6 October.
- National enforcement is being put in place. Penalty rules are due to the Commission by 8 December 2026 and apply from 8 January 2027; the Netherlands, Germany, France and Denmark already have their acts in force.
The EU registry is live, and it now has an API
Every passport will be registered in one EU registry, construction passports included. Commission Implementing Regulation (EU) 2026/1778 set it up. The registry went live on 20 July 2026 and the regulation applies from 6 August 2026. Its scope covers products under the Ecodesign Regulation (ESPR), batteries, construction products, toys, detergents, and any product whose EU law requires a registered passport.
The registry does not hold product data. It holds the unique identifiers, the customs commodity codes and a registration record, and it points to the passport wherever the manufacturer or its service provider hosts it.
On 30 October 2026 the Commission published the technical package: an API integration guide, OpenAPI specifications, a semantic data guide and two authentication guides. One rule in those guides matters to every manufacturer. The unique product identifier must be a web address that resolves to the passport, compliant with the CEN-CENELEC JTC 24 standards and at most 2,000 characters long. JSON is the mandatory data format.
Only the battery product group has been switched on so far. Construction passports will exist only once their own act is in place, and that act may set its own rules for identifiers and data carriers (CPR Article 79(1)). The direction is still clear: plan an identifier for each product type that can sit inside a web address. GS1 Digital Link is one way to build it, not the only one.
Member States must name a national administrator for the registry by 18 February 2027. We found none named yet in the nine countries we follow.
The construction passport act, and when the duty really lands
The construction passport system will be set up by a Commission delegated act under Article 75(1) of the Construction Products Regulation, Regulation (EU) 2024/3110. The Commission's DPP page still indicates the second quarter of 2027. There is no call for evidence, draft or consultation yet.
The regulation counts from that act's entry into force, not from its adoption. Six months after entry into force the system must be fully operational. Eighteen months after it, manufacturers must make the passport available (Articles 22(7) and 80(1)). In between, they may use the system voluntarily.
Entry into force follows an objection period. Parliament and the Council have two months to object; either can extend that by two months, or both can end it early (Article 89(6)). On an adoption in the second quarter of 2027, the passport duty therefore lands between late 2028 and mid-2029. Plan on the earlier end, and treat any single date you see quoted as an estimate.
Your family's own timing matters too. A family's obligations under the new regulation start one year after the implementing act that makes its harmonised standard mandatory (Article 95(9)). The Commission's CE marking page words the 18 months per product family, while the regulation counts them from the one act that sets up the system. Until that is clarified, watch both clocks: the system act, and your family's standard.
The assessment and verification systems are now law
Commission Delegated Regulation (EU) 2026/1310 of 11 June 2026 was published on 28 August and has been in force since 17 September 2026. For each product family, category and essential characteristic, it fixes which assessment and verification system applies once a family declares under the new regulation.
The new regulation has six systems (Annex IX): the five manufacturers know from the old regime, and a new one. System 3+ is the "notified body's control of environmental sustainability assessment", and the delegated regulation assigns it to environmental sustainability for every family. It also sets system 2+ for the content of dangerous substances and for release into soil and groundwater, and system 3 for emissions into indoor air. Its Annex III adds the systems for each family and category.
In practice, once your family moves to the new regime, a notified body will validate your environmental assessment: the input values, the assumptions, the rules applied and the correct use of the calculation software. If your environmental data could not withstand that review today, that is the gap to close first.
Two further delegated regulations, (EU) 2026/331 and (EU) 2026/557, set the classes of performance for reaction to fire and resistance to fire under the new regime.
Which families come first: the Working Plan's dates
The Commission's CPR Working Plan 2026 to 2029, COM(2025) 772, is still the only document that dates the families. Its section 1.4 lists three standardisation requests already adopted. Two of them, precast concrete products and structural metallic products, are still under the old regulation. The third, cement, building limes and other hydraulic binders, is under the new one. Four more requests are in preparation: reinforcing and prestressing steel, doors and windows, thermal insulation, and flat glass.
The plan's Table 3 gives an indicative date for each family's standard to be made mandatory:
| Product family | Standardisation request | Standard made mandatory (indicative) |
|---|---|---|
| Cement, building limes and other hydraulic binders | Q3 2025, adopted | Q4 2027 |
| Doors, windows, shutters and gates | Q1 2026 | 2029 |
| Flat glass, profiled glass and glass blocks | Q1 2026 | 2029 |
| Reinforcing and prestressing steel | Q2 2026 | 2029 |
| Thermal insulation products | Q3 2026 | 2029 |
| Gypsum products | 2028 | Not dated |
Three cautions. The plan calls itself indicative, and its first progress report is due at the end of 2026. No standard has yet been made mandatory under the new regulation; the Commission names cement as probably the first, in 2027. And the doors and windows request, planned for the first quarter of 2026, was notified as a draft on 21 January and is still a draft, contested by industry.
Remember what the mandatory date starts: one year later, the family's obligations under the new regulation apply, including the new declaration.
Environmental data: EPDs stay, but the DoPC figure comes from Commission software
The new Declaration of Performance and Conformity (DoPC) carries the environmental characteristics of Annex II in three steps fixed in law (Article 15(3)). The four climate indicators, points (a) to (d), apply from 8 January 2026 to any product declared under the new regime. Points (e) to (m) follow from 9 January 2030, and points (n) to (s) from 9 January 2032.
What is often missed: Article 15(2) says the environmental performance is calculated with the latest version of software the Commission makes available free of charge, and the declaration records which version was used (Annex V). EN 15804 appears only in a recital. We found no release of that software yet.
So EPDs to EN 15804+A2 remain the input you need, and they already pay off today: France's INIES database, the Dutch national environmental database, Germany's ÖKOBAUDAT and Italy's green procurement criteria all run on them. But the figure in your DoPC will come from the Commission's tool, and under system 3+ a notified body will check how you used it.
The information on substances of concern under REACH Articles 31 and 33 goes with the DoPC (Article 15(6)) and is part of the passport. Those REACH articles have not changed. A structured EU format for that information does not exist yet.
Standards: six cited, two waiting, and a draft for the digital DoPC
Six European DPP standards became harmonised under the Ecodesign Regulation on 15 July 2026 (Implementing Decision (EU) 2026/1736): EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223. They include the standards for unique identifiers (EN 18219), data carriers (EN 18220) and data storage, archiving and persistence (EN 18221). Two more, EN 18239 on access rights and EN 18246 on data authentication, are published as standards. The decision to cite them has not been adopted, and the Commission now expects it in November 2026.
For construction, the bigger news is the digital DoPC. CEN/TC 442 has a draft standard, prEN 18357, that sets out how to build data templates for a machine-readable DoPC on top of EN ISO 23387. Its CEN enquiry closed on 1 October 2026 (national comment deadlines fell earlier, on 1 and 18 September); AFNOR plans final publication for February 2028, and a draft is not yet normative. In October, CEN-CENELEC Guide 36 (third edition) also asked the authors of new harmonised standards to digitalise the DoPC as data templates grouped after Annex V. New harmonised standards will increasingly arrive with their own DoPC template.
The EPD standards are stable for now. EN 15804 has no active revision, and a revision of ISO 22057, the standard for EPD data templates, was only registered in May 2026, with no draft yet.
On 6 October 2026 the Commission also proposed a new European standardisation regulation (COM(2026) 780) to replace Regulation (EU) No 1025/2012. Every CPR standardisation request runs through that framework, so its progress will affect how fast new harmonised standards arrive.
National rules: enforcement now, and data demands that already exist
The national acts that implement the new regulation add authorities, market surveillance and fines. They do not add content to the declaration. What pulls product data at national level is building life-cycle rules and public procurement, plus a language rule in two countries. Penalty rules must be notified to the Commission by 8 December 2026 and apply from 8 January 2027 (Articles 92 and 96).
| Country | What is in force or coming | What it asks of a manufacturer |
|---|---|---|
| Germany | Construction Products Act amended, in force since 15 January 2026: DIBt as assessment body and notifying authority, fines up to EUR 50,000 | The DoPC and product information in German. Life-cycle data enters ÖKOBAUDAT only through an EPD programme operator |
| France | Decrees of January 2026 on enforcement and notified bodies. RE2020 levels revised for permits from 1 July 2026. An environmental award criterion in every public contract from 21 August 2026 | Any environmental claim needs a verified FDES on INIES, to NF EN 15804+A2 |
| Netherlands | Building decree amended by the decree of 3 September 2026, in force since 24 September 2026; the inspectorate ILT enforces. MPG limit values recalculated and extended from 1 July 2026 | A product counts in an MPG calculation only with a declaration in the national environmental database |
| Denmark | Dedicated order in force since 8 January 2026; fines from 8 January 2027. Building CO2 limits since 1 July 2025 | The DoPC in Danish or English; general product information, instructions and safety information in Danish |
| Italy | A decree adapting national law is due by 9 April 2027 (Law 36/2026, Article 19). Green procurement criteria for buildings apply to tenders from 2 February 2026 | An EPD to UNI EN 15804 is accepted as proof in public works, with minimum recycled content |
| Poland | Draft act on construction products in government committees since September 2026; the 2004 act still applies. Paper building logbooks may be issued until 31 December 2031 (Article 47v of the Building Law, added in December 2025) | The national building mark (znak budowlany, the "B" mark) stays in the draft of 9 September 2026, with fines of up to PLN 150,000 (Articles 65 and 66; now PLN 100,000) for a product that does not deliver its declared performance |
| Spain | Draft royal decree notified to the EU, not yet adopted | Nothing new to declare yet |
| Sweden | Proposal: replace the climate declaration law from 1 April 2027, life-cycle GWP from 2028, limit values from 2030 | Building calculations would take the GWP from the DoPC where it exists |
| Belgium | Royal decree of 22 May 2014 on environmental claims | Any environmental claim on a construction product needs a registered B-EPD |
Other EU rules that pull on the same data
None of these changes what goes into a DoPC, but each draws on the same product data.
- CBAM. The carbon border mechanism has been in its definitive phase since 1 January 2026. Certificates go on sale on 1 February 2027, and the first declaration is due by 30 September 2027. An extension to downstream steel and aluminium goods, proposed from 1 January 2028, is in negotiation, and the Council's version adds construction goods. Importers of cement, steel and aluminium need embedded-emissions data per product.
- Buildings. Under the Energy Performance of Buildings Directive, new buildings over 1,000 m² must disclose their life-cycle GWP from 1 January 2028, and all new buildings from 2030. Those calculations consume product GWP.
- Corporate reporting. The simplified ESRS (Delegated Regulation (EU) 2026/1563) enter into force on 10 November 2026 for financial years from 1 January 2027, with over 60 percent fewer mandatory data points. Large customers will ask their suppliers for less, not more.
- Green claims. The Empowering Consumers Directive has applied since 27 September 2026: generic environmental claims to consumers need substantiation.
- Wood. The Deforestation Regulation, as amended in 2025, applies from 30 December 2026 for medium and large operators, which covers wood-based construction products.
- Circular economy. The Commission is expected to present a Circular Economy Act in the fourth quarter of 2026. It is the file to watch for construction and demolition waste.
Seven statements worth correcting
We read the texts again against EUR-Lex this autumn. These statements circulate widely, in some places in our own earlier material, and the texts say otherwise.
| Often said | What the text says |
|---|---|
| The construction passport has nine content elements | Article 76(2)(a) lists seven items: the DoPC; general product information with instructions and safety information; the technical documentation; the label; the unique identifiers; documents required by other EU law; and the data carriers of key parts |
| The data carrier is part of the passport's content | The passport is connected to a data carrier and reached through it (Article 76(2)(b) and (c)); only the carriers of key parts are content |
| Manufacturers need a passport from late 2028, or from 2029 at the earliest | 18 months after the passport act enters into force (Articles 22(7) and 80(1)); on a Q2 2027 adoption, between late 2028 and mid-2029 |
| The DoPC's environmental values are calculated to EN 15804 | They are calculated with the Commission's software (Article 15(2)); EN 15804 appears only in a recital |
| The passport identifier will be stated in the DoPC | Annex V has no such field; the Commission may amend Annex V to integrate the passport (Article 15(5)) |
| Requirements for DPP service providers come in an implementing act | A delegated act under ESPR Article 11; the Commission gives Q4 2026, Q2 2027 and Q3 2027 in different places |
| The passport chapter is Articles 75 to 79 | Articles 75 to 80; Article 80 is the one that says when the passport becomes mandatory |
We keep our earlier pieces online as first published, so the way the framework has developed stays easy to follow, and Magda has added short dated notes to each where things have moved since: the guide to Digital Product Passports for construction products and its Polish version, which construction products need a DPP first and its Greek version, what goes in a construction DPP, and from DoP to DoPC.
The dates that matter
| Date | What happens | Status |
|---|---|---|
| November 2026 | EN 18239 and EN 18246 expected to be cited as harmonised standards | Indicative |
| 8 December 2026 | Member States notify their CPR penalty rules | Fixed in law |
| 8 January 2027 | CPR penalties apply | Fixed in law |
| 18 February 2027 | Battery passport mandatory; national registry administrators appointed | Fixed in law |
| Q2 2027 | Construction passport act expected | Indicative |
| 30 September 2027 | First CBAM declaration due | Fixed in law |
| Q4 2027 | Cement standard made mandatory, the first family | Indicative |
| 1 January 2028 | Life-cycle GWP disclosure for new buildings over 1,000 m² | Fixed in law |
| Late 2028 to mid-2029 | Manufacturers owe the construction passport | Arithmetic on an indicative date |
| 2029 | Standards for thermal insulation, doors and windows, flat glass and reinforcing steel made mandatory | Indicative |
| 9 January 2030 | The DoPC adds Annex II indicators (e) to (m) | Fixed in law |
| 6 August 2030 | Registry connected to the EU customs Single Window | Fixed in law |
| 9 January 2032 | The DoPC adds Annex II indicators (n) to (s) | Fixed in law |
| 8 January 2040 | The transition from the old regulation ends | Fixed in law |
Read the table the right way round: the fixed dates tell you the framework is running, and the indicative ones are the Commission's plans, which have moved before and will move again.
What to do this quarter
- Date each family. Find your families in the Working Plan's Table 3, note the year its standard is expected to become mandatory, and add one year. If you span several families, plan to the earliest.
- Check one declaration against the new model. Annex V asks for the intended use, the assessment and verification system for each essential characteristic, and the notified bodies involved. One product shows you the size of the gap.
- Make your environmental data reviewable. Keep EPDs to EN 15804+A2 current, and document the input data and assumptions behind them, because under system 3+ a notified body will validate them.
- Choose an identifier per product type that can sit inside a web address, and decide who will host the passport.
- List your markets and what each one asks. That means the DoPC's language (German, Danish or English), the national databases (INIES, the Dutch database, ÖKOBAUDAT) and the claim rules in France and Belgium.
- Diary the next signals: the Member States' penalty rules by 8 December 2026, the Working Plan's first progress report at the end of 2026, and the passport act in 2027.
Questions manufacturers ask
Is the construction Digital Product Passport mandatory yet?
No. The act that sets up the construction passport system has not been adopted, and the Commission indicates the second quarter of 2027.
When will I need one?
The regulation sets the duty 18 months after that act enters into force. On the Commission's indicative timing, that is between late 2028 and mid-2029. Your family's move to the new regulation, one year after its standard is made mandatory, is the other date to watch. The regulation counts the 18 months from the one system act, while a Commission page words them per product family, and that point is not yet clarified.
Can I register a construction product in the EU registry now?
No. Only the battery product group is switched on, and construction passports need their own act first. You can already decide on the identifier: a web address that resolves to the passport.
Do I still need EPDs if the Commission's software calculates the DoPC values?
Yes. EPDs feed national databases and public procurement today. The data behind them is also what goes into the Commission's calculation, and under system 3+ a notified body will validate it.
Does the new standardisation regulation change my timeline?
Not yet. It is a Commission proposal of 6 October 2026, and it changes nothing until it is adopted.
Where this leaves you. The passport itself is still a 2027 act, but the registry, the identifiers, the assessment systems and national enforcement are already in place. That leaves less room to wait than the headline date suggests, because the data work behind a passport is measured in years. For the background, our guide to Digital Product Passports for construction products covers what the passport is and where the obligations come from, and our reading of the CPR Working Plan shows how to find your family's place in the queue. If you want the work planned for your own portfolio, the DPP Readiness Program does exactly the steps above: dating your families, a DoPC gap check, environmental data planning and identifier choices. Contact us to talk it through.
Sources
All read on 31 October 2026. The article states the law as it stood that day.
- Regulation (EU) 2024/3110, the Construction Products Regulation
- Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation
- Delegated Regulation (EU) 2026/1310, assessment and verification systems
- Implementing Regulation (EU) 2026/1778, the DPP registry
- Implementing Decision (EU) 2026/1736, the harmonised DPP standards
- CPR Working Plan 2026 to 2029, COM(2025) 772
- European Commission: Digital Product Passport
- European Commission: DPP registry guides
- European Commission: CPR 2024 revision
- Delegated Regulation (EU) 2026/1563, simplified ESRS
- Delegated Regulation (EU) 2026/331, classes for reaction to fire
- Delegated Regulation (EU) 2026/557, classes for resistance to fire
- COM(2026) 780, proposal for a regulation on European standardisation
- CEN-CENELEC Guide 36, edition 3, October 2026
- CEN/TC 442 on the digital DoPC and prEN 18357; CEN enquiry closure (stage 4060, 1 October 2026) from iTeh's copy of the CEN project record; national deadlines from BSI's draft for public comment (comments by 1 September 2026) and AFNOR Norm'Info (closed 18 September 2026)
- European Commission: Carbon Border Adjustment Mechanism
- Directive (EU) 2024/1275, the Energy Performance of Buildings Directive
- Directive (EU) 2024/825, empowering consumers for the green transition
- Regulation (EU) 2023/1115, the Deforestation Regulation and Regulation (EU) 2025/2650 amending it
- European Commission: Circular Economy Act initiative
- Germany: act adapting the Bauproduktengesetz to Regulation (EU) 2024/3110, BGBl. 2026 I No. 4
- France: Décret n° 2026-7, Décret n° 2026-17, Loi n° 2021-1104 (Climat et résilience), Article 35; the 21 August 2026 start date comes from Article 11 of Décret n° 2022-767 du 2 mai 2022
- Netherlands: Besluit van 3 september 2026 amending the Besluit bouwwerken leefomgeving, Staatsblad 2026, 276; Nationale Milieudatabase on MPG policy
- Denmark: order on marketing and market surveillance of construction products, LTA 2025/1831; building regulations amendment, LTA 2025/271
- Italy: Legge 17 marzo 2026, n. 36; CAM edilizia, decree of 24 November 2025
- Poland: draft act on construction products; act of 4 December 2025 amending the Building Law, Dz.U. 2025 poz. 1847
- Spain: TRIS notification 2025/2993, draft royal decree on construction products
- Sweden: Boverket's proposal on buildings' climate impact
- Belgium: FPS Health on the Royal Decree on environmental messages
Member of the CIRPASS-2 Stakeholder Community, contributing to Expert Working Groups on the Digital Product Passport.