Which construction products need a Digital Product Passport first: reading the CPR Working Plan 2026-2029

The plan exists because the regulation gives you no date

The most common question we hear from manufacturers is when the Digital Product Passport becomes mandatory for them. The honest answer is that Regulation (EU) 2024/3110 does not say. It does not switch product families over on a single date. Each family migrates to the new regime when its revised harmonised technical specification is adopted and made mandatory by an implementing act - and until that happens for your family, nothing changes for you.

That design is why the Working Plan matters more than any other document the Commission has published on this. The regulation required the Commission to publish a first working plan, and it did so on 16 December 2025 as COM(2025) 772, covering 2026 to 2029. The plan sets out an indicative, product-family-specific roadmap: which families get standardisation requests, when the standardisation organisations are expected to deliver, and when the resulting specifications may be made mandatory. It also covers the horizontal delegated acts, including the one that will introduce the construction DPP itself.

Two words in that paragraph carry weight. Indicative - the plan is a roadmap, not a statute, and it says so. And product-family-specific - which is what turns a general anxiety about EU regulation into a question you can actually answer about your own portfolio.

Who is at the front of the queue

The first standardisation requests under the new regime cover three families:

• Precast concrete products
• Structural metallic products and ancillaries
• Cement, building limes and other hydraulic binders

Windows, doors and thermal insulation follow. Beyond them the plan sets out a phased roadmap covering all construction product families, with activities scheduled across 2026-2029 and the plan itself to be reviewed and updated by the end of 2028 at the latest.

It is worth seeing how thin that scheduling becomes further down the list. For product family 33, Fixings - which includes post-installed fasteners - the Working Plan schedules the key preparatory CPR Acquis milestones for 2028. The subsequent standardisation request, and the delivery of the harmonised standards themselves, have not yet been assigned dates at all. A family can therefore have a dated preparatory milestone and still no date for the standard that will eventually bind it, which is the clearest illustration in the whole document of the regulatory and standardisation lead time that can precede full implementation of the new CPR framework and its Digital Product Passport requirements.

One thing to be precise about, because it is where most commentary overreaches: the order of standardisation requests is not a list of DPP deadlines. No enacted act yet names a first-mandatory family. What the queue tells you is which families the Commission has started work on first, and since the passport arrives with the new harmonised technical specification, that order is the best available predictor of the order in which obligations land. It is a strong signal. It is not a date.

How a standardisation request becomes your deadline

The chain between a line in the Working Plan and a legal obligation on your product runs through four stages, and understanding it is what lets you read the plan for yourself rather than waiting for someone to tell you what it means.

1. The standardisation request is drafted. A dedicated subgroup produces the document that specifies what the harmonised standard must cover. This is the legal basis for everything that follows, and it is the stage the Working Plan schedules by family.
2. The standardisation organisation does the work. CEN or CENELEC develops the revised harmonised technical specification against that request.
3. The specification is cited. An implementing act publishes the reference in the Official Journal. From this point the standard exists as a usable route to CE marking under the new rules.
4. The coexistence period runs, then ends. For a minimum of one year, a manufacturer may choose between the old route and the new one. When the coexistence period ends, the new specification is the only means of drawing up a declaration for products it covers - and compliance under the new regime, DPP included, is mandatory.

Each stage takes months, and several of them take more than a year. That is why "my family is not in the first wave" is a weaker reassurance than it feels: the total elapsed time from request to mandatory application is measured in years for everyone, and the work you have to do inside that window does not shrink because your window starts later.

The dates that are actually fixed

Read that table the right way round. The enacted dates tell you the framework is real and running. The indicative ones tell you that nobody - including the Commission - can yet give you a date for your product. Planning against the indicative dates as if they were deadlines is a mistake in both directions: it invites panic in 2027 and complacency in 2026.

If you are in the first wave

Precast concrete, structural metallic products, cement and binders: you have the clearest signal any manufacturer in this sector currently has, and it is worth treating as a head start rather than a threat. The families in the first standardisation requests will also be the families whose data expectations get defined first - which means the manufacturers engaged at that stage help shape what "compliant data" ends up meaning for everyone else in their family.

The practical implication is that the work to start now is not the passport. It is the data the passport will carry: declarations in a form that survives being read by a machine, environmental life-cycle data at EPD grade, and product information held somewhere better than a folder of PDFs. None of that is quick, and none of it is wasted if the timing moves.

If you are not

The temptation is to file this under "later". Three reasons not to.

1. The data work is the long pole, and it is the same length for everyone. Environmental Product Declarations routinely take six to twelve months per product line. A PIM or ERP that can hold product-instance-level data is a multi-year programme in most manufacturers. Those durations do not care which wave you are in.
2. A later slot means less warning, not more time. The first-wave families are being watched by the whole sector; when their specifications land, the trade press will explain them in detail. A family whose preparatory milestones sit in 2028, with no date yet for its standardisation request, gets the same obligations later and with far less collective preparation around it.
3. Your customers may arrive before the regulator does. Designers, contractors and public buyers are already asking for structured product data on projects where no passport is yet required. That demand is not waiting for a delegated act.

What to do this quarter

1. Find your families in Annex VII. The Working Plan is organised around them, and its numbering is the vocabulary every subsequent document will use. Knowing that you are family 33 rather than "a fastener manufacturer" is what makes the plan readable.
2. Locate each family in the plan and write down the year. Not the deadline - the year its standardisation request is scheduled. That is the number your internal planning should hang on.
3. Check whether you span waves. Many manufacturers make products across several Annex VII families, and it is common to be first-wave in one and late in another. Plan to the earliest, because the data infrastructure is shared.
4. Gap-check one declaration against the DoPC. Take a single existing Declaration of Performance and compare it against what the new Declaration of Performance and Conformity requires. One product is enough to tell you the size of the problem across the portfolio.
5. Diary the annual report. The Commission reports progress on the plan annually from the end of 2026, and the plan itself is renewed at least every three years. Your family's year can move. Check it rather than assuming it.

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