Digital Product Passports for construction products: deadlines and what manufacturers must do

What the DPP is under the revised CPR

The Digital Product Passport is a structured, machine-readable digital record for each construction product, accessed through a data carrier - a QR code, barcode or data matrix - on the product, its packaging or its documentation. Under Regulation (EU) 2024/3110, Articles 75–77 establish a dedicated construction digital product passport system: Article 75 mandates the Commission to set up the system itself through delegated acts, and Articles 76–77 define what each passport must contain and how it must behave (availability, backup, interoperability), as summarised by Istituto Giordano's analysis of the DPP provisions.

Two design decisions matter for planning. First, the construction DPP is a standalone framework under the CPR - separate from, but designed to be interoperable with, the general DPP framework of the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781). Construction products get their passport through the CPR, not the ESPR working plan. Second, the DPP is not a bolt-on document: it packages the information that already anchors CE marking - above all the new Declaration of Performance and Conformity (DoPC), which replaces the old Declaration of Performance and adds conformity and environmental content to it.

Who is affected and when

Everyone in the supply chain of construction products placed on the EU market is in scope - manufacturers first, but the new CPR also imposes obligations on importers, distributors and online marketplaces. The critical point about timing: the new CPR does not switch product families over on a single date. Each family migrates when its new harmonised technical specification is adopted via an implementing act, with a minimum one-year coexistence period before compliance under the new rules becomes mandatory. Until then, products stay under the old regime - which is why parts of the old Regulation 305/2011 continue to apply, on a transitional basis, until 8 January 2040.

Timeline of verified dates

A caution about dates you may have seen elsewhere: 2030 and 2032 are not "DPP becomes mandatory" dates. They are the enacted phase-in steps for how many environmental indicators the DoPC must declare. No EU act currently in force fixes a single date on which every construction product must carry a passport; the trigger is always your product family's delegated act and harmonised technical specification.

What a construction product passport must contain

Per Article 76 of the revised CPR, as summarised by Istituto Giordano and Designing Buildings, each DPP must include:

• The Declaration of Performance and Conformity (DoPC) - the successor to the DoP, covering declared performance and regulatory conformity in one document, with REACH information (Articles 31/33 of Regulation 1907/2006) provided together with it;
• General product information, including the unique product identifier;
• Instructions for use and safety information;
• Technical documentation supporting the declared performance;
• Documentation required under other EU law applicable to the product;
• A data carrier (QR code, barcode or data matrix) physically linking the product to its digital record.

The environmental dimension is the heaviest lift. Once a family falls under a new harmonised technical specification, the DoPC must declare climate-change indicators (global warming potential across the life cycle, calculated under EN 15804 rules - the same methodology behind Environmental Product Declarations), with the indicator set expanding in 2030 and again in 2032. If you do not have EPD-grade life-cycle data for your products today, this - not the QR code - is your long pole.

What manufacturers should do now

1. Map your portfolio to Annex VII product families and locate each family in the CPR Working Plan 2026–2029. Precast concrete, structural metallic products and cement/limes/binders already have standardisation requests; if you are in those families, your clock is running fastest.
2. Audit your current declarations. Inventory every DoP, test report and technical file, and gap-check them against DoPC content - performance plus conformity plus environmental characteristics plus REACH information.
3. Start generating EN 15804 life-cycle data (EPDs) now. Climate-change indicators become declarable as soon as your family migrates, and the indicator set only grows through 2030 and 2032. EPD programmes routinely take 6–12 months per product line.
4. Fix your product data infrastructure. A DPP is machine-readable, product-instance-linked data - spreadsheets and PDFs will not survive contact. Assess PIM/ERP readiness, unique identifier strategy, and data-carrier (QR/data matrix) placement on products and packaging.
5. Assign ownership and budget. DPP readiness cuts across regulatory affairs, product engineering, sustainability and IT; make one person accountable and fund a multi-year programme, not a project.
6. Brief your supply chain. Your DoPC and environmental declarations depend on upstream data (cement, steel, aluminium inputs - some of which face their own ESPR ecodesign track). Put data-delivery clauses into supplier contracts.
7. Track the delegated acts and pilots. Follow the Commission's DPP hub and the CIRPASS-2 construction pilot - the pilot architectures being tested through April 2027 are the best available preview of what the operational system will demand.

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