Digital Product Passport Under CPR 2024/3110: What Construction Manufacturers Need to Know

What CPR 2024 Already Requires: Article 6 and Mandatory Environmental Disclosure

Article 6 of Regulation (EU) 2024/3110 requires manufacturers to declare the Global Warming Potential (GWP) of their construction product as part of the Declaration of Performance (DoP), once the new harmonised technical specifications for a given product family enter into force. This is a direct environmental performance requirement — not a future aspiration — and it marks the first time that climate impact data becomes a legally mandated element of CE marking for construction products.

The reference framework for calculating and reporting GWP under CPR 2024 is EN 15804+A2:2019, the European core Product Category Rules (PCR) for construction products. An Environmental Product Declaration (EPD) verified according to EN 15804+A2 satisfies the Article 6 GWP disclosure requirement in full — making EPDs the most efficient compliance route for manufacturers subject to the new CPR.

Phased Implementation: Which Indicators, and When

CPR 2024 does not activate all environmental indicators simultaneously. The mandatory disclosure scope expands in phases, aligned with the revision cycle of harmonised standards (hEN) under the new CPR framework:

Manufacturers who hold a current EPD verified under EN 15804+A2 already capture the complete LCA indicator set — including GWP, AP, EP-freshwater, POCP, PERT, PENRT, and water use — placing them ahead of each phase threshold without additional analytical work.

System 3+: The New Verification Category Introduced by CPR 2024

One of the most significant and least-discussed structural changes in CPR 2024/3110 is the introduction of Assessment and Verification of Constancy of Performance (AVCP) System 3+. This is a new conformity assessment category that did not exist under the original CPR (305/2011) and is specifically designed for environmental performance declarations.

How System 3+ Differs from Existing AVCP Systems

System 3+ is, in effect, the formalisation of what EPD programme operators such as EPD Polska already do: independent, accredited third-party verification of the Life Cycle Assessment study and the resulting environmental declaration. Under the new CPR framework, this verification activity is given a defined legal status within the conformity assessment architecture — making the EPD verification process not merely a market differentiation tool but a legally recognised conformity procedure.

What System 3+ Means in Practice

For manufacturers, System 3+ has three immediate implications:

• Independent LCA verification is mandatory for GWP disclosure under Article 6 — self-declared environmental data (System 4) will not satisfy the requirement once the relevant hEN is in force.
• The verifier must be accredited — EPD programme operators operating under PCA (Polish Accreditation Centre) or equivalent national accreditation bodies satisfy this requirement. EPD Polska operates under PCA accreditation, qualifying as a System 3+ body for construction products within its scope.
• Existing EPDs already meet System 3+ criteria — EPDs verified by EPD Polska under EN 15804+A2 and ISO 14025 were produced through exactly the independent third-party verification process that System 3+ formalises. No retroactive re-verification is required.

What Is a Digital Product Passport?

A Digital Product Passport is a structured digital record linked to a specific product or product type through a unique identifier. The concept originates from the broader European sustainability policy agenda, which aims to make product-level environmental and regulatory information accessible throughout the supply chain — from manufacturer to distributor to installer to building owner to end-of-life waste processor. In its simplest form, a DPP is a standardised data carrier (such as a QR code or RFID tag on the product) that links to a digital dataset containing information about the product’s composition, performance, environmental characteristics, and regulatory compliance.

For construction products, the Digital Product Passport concept appears in two distinct regulatory streams. The first is the Ecodesign for Sustainable Products Regulation (ESPR), adopted as Regulation (EU) 2024/1781, which establishes a general framework for DPPs across a wide range of product categories. The second is the revised Construction Products Regulation, CPR 2024/3110, which includes construction-sector-specific provisions for digital information accompanying construction products placed on the EU internal market. Understanding the distinction between these two regulatory instruments — and the conditions that must be met before either imposes binding obligations on manufacturers — is essential for making sound business decisions.

DPP Provisions in CPR 2024/3110

The revised Construction Products Regulation (CPR 2024/3110), published in the Official Journal of the European Union in late 2024, replaces the original Construction Products Regulation (305/2011) and introduces a modernised framework for the marketing of construction products. Among its many provisions, the regulation establishes the legal basis for requiring digital product information, including what is commonly referred to as the Digital Product Passport for construction products.

Under the revised CPR, the information accompanying a construction product when it is placed on the market — traditionally provided through the Declaration of Performance (DoP) and CE marking — may in the future be delivered in digital form. The regulation envisions that a DPP for construction products could contain:

The environmental data component of the DPP is where Environmental Product Declarations become directly relevant. An EPD, prepared according to EN 15804+A2, provides exactly the kind of standardised, verified environmental information that a construction product DPP would need to include. The GWP-total indicator, resource use indicators, waste output indicators, and other environmental metrics from an EPD would form the core of the DPP’s environmental section.

Critical Clarification: DPP Is NOT Yet Mandatory

This is the single most important point for manufacturers to understand, and it is frequently misrepresented in industry commentary: the Digital Product Passport for construction products is not yet mandatory as of March 2026. The provisions in CPR 2024/3110 establishing the DPP framework are enabling provisions — they create the legal authority for future DPP requirements but do not, by themselves, impose immediate obligations on manufacturers.

Two critical preconditions must be met before DPP obligations apply to any specific construction product category:

Precondition 1: New Harmonised Technical Specifications

The DPP requirements in the CPR are linked to the product-specific harmonised technical specifications (hTS) — the successor instruments to what were previously harmonised European standards (hENs). These new hTS will define, among other things, what environmental and sustainability information must accompany each product category. Until a new hTS is published in the Official Journal of the EU for a given product category, the DPP provisions of the CPR do not become operational for that category.

As of March 2026, no new harmonised technical specifications have been published under CPR 2024/3110. The process of developing, reviewing, and publishing new hTS is complex and involves the European Commission, the European standardisation organisations (CEN and CENELEC), and extensive stakeholder consultation. Realistic timelines suggest that the first new hTS may not appear in the Official Journal for several years, and even after publication, coexistence periods will allow manufacturers time to transition from existing standards.

Precondition 2: Implementing Acts from the European Commission

In addition to new hTS, the practical implementation of the DPP requires implementing acts from the European Commission that define the technical format of the passport, the data registry infrastructure, the rules for unique product identifiers, and the conditions for DPP service providers. These implementing acts have not been adopted as of March 2026. Without them, the operational details of the DPP — how data is formatted, where it is stored, how it is accessed, who is authorised to issue passports — remain undefined.

The combination of these two preconditions means that manufacturers face no immediate DPP obligations under the CPR.

ESPR DPP vs CPR DPP: Understanding the Distinction

Confusion often arises from the overlap between the Ecodesign for Sustainable Products Regulation (ESPR) and the CPR, both of which contain DPP provisions. The ESPR (Regulation 2024/1781) establishes a horizontal DPP framework applicable to a wide range of product groups. The European Commission will adopt delegated acts specifying DPP requirements for each product group covered by the ESPR.

Construction products are a special case. The CPR is the sector-specific regulation for construction products, and its provisions are intended to take precedence for products within its scope. However, certain construction-related products may fall within the scope of both regulations — for example, heating systems, lighting, or building automation components. Manufacturers of such products need to monitor both regulatory tracks to understand which DPP requirements will apply to their specific product categories.

For core construction materials — cement, concrete, steel, insulation, aggregates, windows, doors, and similar products regulated primarily under the CPR — the CPR’s DPP provisions are the relevant framework. And as explained above, those provisions are not yet operational.

What Will DPP Contain When It Arrives?

Although the timeline is uncertain, the content requirements for construction product DPPs can be anticipated based on the CPR text and related policy documents. The DPP is expected to include the Declaration of Performance (or Declaration of Conformity under the new terminology), providing the essential characteristics and performance levels of the product. It will contain environmental performance data, likely including GWP and potentially other life-cycle indicators as defined by EN 15804+A2. Information on hazardous substances — aligned with REACH and the Substances of Concern In Products (SCIP) database — will be part of the passport. Recycled content, durability data, and end-of-life instructions are also anticipated.

The unique product identifier will link the physical product (via a data carrier such as a QR code) to the digital record stored in a registry. The European Commission’s DG GROW is responsible for developing the implementing acts that will define the technical architecture of this system.

The Role of EPDs in the Future DPP Ecosystem

When DPP requirements eventually become operational, manufacturers with existing EPDs will be in a strong position. The environmental data section of the DPP will require exactly the kind of information that an EPD already provides.

Manufacturers who have already invested in EPDs will have the LCA data, the verification infrastructure, and the data management processes needed to populate the environmental section of a DPP with minimal additional effort. Manufacturers who have not invested in EPDs will face a steeper challenge when DPP requirements arrive: they will need to simultaneously develop LCA capabilities, collect production data, undergo verification, and set up digital data management systems — all under deadline pressure.

This asymmetry is the core argument for obtaining an EPD now, even though neither GWP disclosure nor DPP is yet mandatory.

Timeline Expectations: When Might DPP Become Mandatory?

Predicting precise regulatory timelines is inherently uncertain, but several indicators provide a reasonable range. The development of new harmonised technical specifications under CPR 2024/3110 is likely to take several years. Standardisation processes at CEN typically require three to five years from mandate to publication, and the CPR introduces a new instrument (hTS) that may involve additional procedural steps. Implementing acts for the DPP technical infrastructure also require development, consultation, and adoption.

A reasonable expectation is that the first DPP obligations for construction products might become effective in the late 2020s at the earliest, with broader rollout across product categories extending into the 2030s. However, this timeline is subject to political priorities, standardisation capacity, and the pace of implementing act development. Manufacturers should monitor developments through official channels — the European Commission’s construction products page, CEN work programmes, and national standards bodies — rather than relying on industry speculation.

Practical Steps for Manufacturers Today

1. Obtain an EPD through a credible programme operator. EPD Polska provides the process that builds exactly the capabilities — data collection, LCA modelling, third-party verification, digital data management — that DPP compliance will require. It also delivers immediate commercial benefits through GPP eligibility, green building project access, and supply chain transparency.
2. Prepare product data management systems for structured digital data. The DPP will require that product information is available in machine-readable formats, linked to unique identifiers. Companies that already manage product data digitally — through product information management (PIM) systems or BIM object libraries — will find the transition easier than those relying on paper-based or PDF-only documentation.
3. Stay informed about regulatory developments without overreacting. Subscribe to updates from EUR-Lex, national standards bodies, and trusted industry associations. Distinguish between the regulatory framework (which exists) and the activation mechanisms (which have not yet been triggered).

Avoiding Premature Compliance Spending

A word of caution is warranted. The DPP concept has generated significant activity among technology vendors offering DPP platforms, data management solutions, and consulting services. Some of these offerings are premature — selling solutions for requirements that do not yet exist in their final form. Manufacturers should be wary of investing heavily in DPP-specific technology platforms before the implementing acts define the required data format, registry architecture, and technical standards. The risk of early adoption is investing in a platform that does not align with the eventual regulatory requirements.

Frequently Asked Questions