The Digital Product Passport Is Coming to Construction: What to Prepare in 2026

Introduction: From Paper Certificates to Digital Product Data

The construction industry has operated on paper-based product documentation for decades. Declarations of Performance arrive as PDFs. Safety data sheets are emailed as attachments. EPDs are downloaded from programme operator websites. Product data is scattered across manufacturer websites, certification databases, and specification libraries — rarely in interoperable formats.

The Digital Product Passport (DPP) aims to change this fundamentally. Under CPR 2024/3110, every construction product covered by a harmonised technical specification will eventually carry a DPP: a structured digital dataset linked to a unique product identifier, accessible through a standardised data carrier (such as a QR code or RFID tag), and registered in a centralised EU database.

This article explains what the DPP is, how it relates to the broader EU digital product passport framework, what it will contain, and — critically — what still needs to happen before it becomes a practical reality for construction-product manufacturers.

The EU Digital Product Passport Landscape

ESPR: The Overarching Framework

The DPP concept originates from the Ecodesign for Sustainable Products Regulation (ESPR), adopted in 2024, which establishes a horizontal framework for digital product passports across multiple product categories. The ESPR creates the legal basis for requiring DPPs for products placed on the EU market, with the goal of supporting circular economy, sustainability, and market surveillance objectives.

Under the ESPR, the Commission will adopt delegated acts specifying DPP requirements for specific product groups. The first wave of ESPR-mandated DPPs is expected to cover textiles, batteries (already under the Battery Regulation), and electronics — with construction products addressed through the sector-specific CPR rather than through ESPR delegated acts.

CPR 2024/3110: The Construction-Specific Implementation

CPR 2024/3110 creates its own DPP framework tailored to construction products. While aligned with the ESPR’s overarching principles — unique identifiers, machine-readable data, centralised registry — the construction DPP is governed by the CPR and its implementing acts, not by ESPR delegated acts.

This dual-track approach means that construction-product manufacturers need to track the CPR-specific DPP developments, not the ESPR timeline. While there may be interoperability between the two systems, the legal requirements for construction products will be defined by CPR implementing acts.

What Will the Construction DPP Contain?

Core Data Elements

Based on the CPR 2024/3110 text, the construction DPP is expected to carry the following categories of information:

• Product identification — unique product identifier, manufacturer details, product type, intended use.
• Performance data — the essential characteristics declared in the Declaration of Performance (mechanical, fire, acoustic, thermal, etc.).
• Environmental sustainability data — GWP sub-indicators (total, fossil, biogenic, luluc), and potentially additional environmental indicators as defined in the applicable hTS.
• Material composition — information on substances of concern, recycled content, and material composition relevant to end-of-life treatment and circular economy.
• Compliance and traceability — AVS system applied, notified body details, production facility information, batch or serial identification.
• Digital access — data carrier type (QR code, RFID, NFC), link to the centralised DPP registry, machine-readable data format.

Unique Product Identifier

Each construction product (or batch/type, depending on the implementing acts) will receive a unique identifier linked to the DPP registry. The format — whether based on GS1 standards, UUID, or a bespoke EU scheme — has not yet been defined in implementing acts. The identifier will enable any actor in the value chain to access the product’s DPP data through a standardised interface.

Data Carrier and Access

The DPP data will be accessible through a physical data carrier attached to or accompanying the product. The most likely options are:

The Commission’s implementing acts will specify which data carriers are acceptable and what minimum information must be directly encoded versus linked to the registry.

The Implementation Roadmap: What Must Happen First

Step 1: Harmonised Technical Specifications

The DPP obligation is activated product-by-product through new harmonised technical specifications (hTS). Each hTS will define what data must be included in the DPP for that product family. Without an hTS, there is no obligation — and as of March 2026, no new hTS under CPR 2024/3110 has been published.

The Commission’s First CPR Working Plan (2026–2029) identifies priority product families (cement, concrete, steel, insulation) for standardisation requests to CEN, but the standardisation process typically takes 2–3 years from mandate to publication.

Step 2: European Commission Implementing Acts

Even after hTS are published, the DPP requires a suite of implementing acts from the Commission that define:

• The DPP registry infrastructure — the centralised database where DPP data is stored and accessed.
• The data format — the technical schema for structuring DPP data in a machine-readable format.
• The unique identifier system — the standard for assigning and managing product identifiers.
• The data carrier requirements — which physical carriers are acceptable and how they link to the registry.
• Accreditation rules for DPP service providers — who can host, manage, and validate DPP data on behalf of manufacturers.

Step 3: Coexistence and Transition

After both the hTS and implementing acts are in place, there will be a coexistence period during which products may comply with either the old harmonised standard (without DPP) or the new hTS (with DPP). The DPP becomes mandatory only when the old standard is withdrawn from the Official Journal and the coexistence period ends.

Implications for Different Actors

Manufacturers

Manufacturers will bear the primary responsibility for creating and maintaining DPPs. This means investing in digital data management systems, collecting the required product data, and interfacing with the DPP registry. The scale of this effort will depend on the manufacturer’s product range, production volumes, and existing digital infrastructure.

For large manufacturers with existing product information management (PIM) systems and EPD programmes, the transition may be relatively straightforward. For SMEs with limited digital infrastructure, the DPP could represent a significant operational challenge.

Specifiers, Architects, and Engineers

For building professionals, the DPP promises to simplify access to verified product data. Instead of hunting through multiple databases and PDF documents, a specifier could scan a QR code and access all performance and environmental data in a structured, comparable format. This would streamline material selection, facilitate whole-building LCA, and support compliance with building-level carbon regulations.

Market Surveillance Authorities

Market surveillance authorities will gain a powerful tool for verifying product compliance. Instead of requesting paper documentation from manufacturers, authorities could access DPP data directly from the centralised registry — enabling more efficient and targeted market surveillance, including cross-border checks.

What Manufacturers Should Do Now

The DPP is not an immediate compliance requirement, but it is a strategic reality that will reshape how construction products are documented and traded in the EU market. Practical steps for Q2 2026:

• Map your product data landscape — identify what data you already hold (DoPs, EPDs, safety data sheets, test reports) and where it is stored. The DPP will require consolidating this data into a single digital structure.
• Invest in EPDs — an EN 15804+A2-compliant EPD is the most efficient way to prepare the environmental data component of the DPP. Commission or update EPDs for your core products.
• Assess your digital readiness — evaluate your IT systems’ ability to manage structured product data, generate machine-readable outputs, and interface with external registries.
• Engage with industry initiatives — participate in sector-specific DPP pilot projects and standardisation activities to gain early practical experience.
• Monitor implementing acts — track EC publications for DPP implementing acts to understand exactly what will be required and when.

The Bottom Line

The Digital Product Passport will transform how construction products are identified, documented, and traced across the EU market. It represents a generational shift from paper-based product data to structured, machine-readable, centrally registered digital information. But this transformation is still in its early stages.

The legal framework is in CPR 2024/3110. The practical implementation depends on harmonised technical specifications and Commission implementing acts that have not yet been published. Manufacturers have a preparation window — measured in years, not months — to get their data in order, build EPD programmes, and position themselves for a digital-first product documentation landscape.

Information current as of publication date. DPP obligations take effect after the publication of new harmonised technical specifications and European Commission implementing acts in the Official Journal of the EU.