Digital Product Passport for Construction Products: What CPR 2024/3110 Actually Requires
If you manufacture windows, insulation, structural steel, cement, or any other product permanently incorporated into buildings or civil engineering works in the EU, you may have noticed that most Digital Product Passport coverage focuses on textiles, batteries, and the ESPR working plan. Construction tends to get a footnote.
That footnote is now a regulation. And it has its own legal instrument, its own timeline, and its own compliance logic - separate from ESPR.
Here is what you actually need to know.
The law that governs construction DPPs: CPR 2024/3110, not ESPR
The first thing to get right is which regulation applies. Most DPP coverage centres on the Ecodesign for Sustainable Products Regulation (ESPR, Reg (EU) 2024/1781) - the horizontal framework that sets DPP architecture across almost all physical goods. But construction products are largely governed by their own sector-specific law.
Regulation (EU) 2024/3110 - the revised Construction Products Regulation - entered into force on 7 January 2025, repealing and replacing the old CPR (EU) No 305/2011. It lays down harmonised rules for the marketing of construction products and, for the first time, establishes an explicit legal basis for a construction-specific Digital Product Passport system.
The relationship between the two regulations is clearly defined in the text itself: where conflicts arise between CPR 2024/3110 and ESPR (Reg (EU) 2024/1781), the relevant provisions of the CPR shall prevail (Article 12). In plain terms: construction stakeholders should track CPR delegated acts and the CPR working plan - not ESPR delegated acts - for their DPP timeline.
CPR leads for construction products. ESPR is the horizontal DPP framework, but CPR 2024/3110 is the sector-specific law that governs construction product DPPs. The two regulations are designed to be interoperable, but where they conflict, CPR prevails (Article 12). If you manufacture construction products, your compliance calendar runs off CPR delegated acts — not the ESPR working plan.
That said, the two regulations are not in opposition. ESPR sets the central DPP architecture - registries, generic principles, data access rules - while CPR adds construction-specific rules and links them to the Declaration of Performance and Conformity (DoPC), CE marking, and the EU Construction Products Database. Think of ESPR as the shared infrastructure and CPR as the construction-specific operating layer on top of it.
What the revised CPR actually changes
The 2011 CPR was primarily about CE marking and performance declarations. The 2024 revision goes considerably further.
CPR 2024/3110 became generally applicable on 8 January 2026, with obligations phasing in as harmonised technical specifications and standards are revised - there is no single cliff-edge date. Key changes include:
- Declaration of Performance and Conformity (DoPC): The old Declaration of Performance (DoP) is replaced by a combined DoPC that now must include environmental essential characteristics. From the date of application, manufacturers must declare climate-change indicators (Annex II, points a-d) in the DoPC, with additional environmental characteristics phased in over the following four years.
- Mandatory environmental information: The new CPR introduces mandatory disclosure of lifecycle-based environmental performance indicators, phased in between 2026 and 2032, aligned with the EN 15804 standard used for Environmental Product Declarations (EPDs).
- Digital Product Passport: An explicit legal basis for a construction-specific DPP system, governed under Chapter X of the regulation.
- Scope expansion: CPR 2024/3110 now covers used and remanufactured products, not just new ones - relevant for importers and distributors who may find themselves classified as manufacturers under Article 26.
Annex VII of CPR 2024/3110 defines 36 product families in scope, including structural assemblies, insulation, fire protection, windows, doors, coatings, and electrical systems intended for permanent incorporation in construction works.
The DPP obligation: not yet, but the clock is running
Here is where many manufacturers misread the situation - in both directions.
Some assume the construction DPP is already mandatory. It is not. The DPP obligation under CPR 2024/3110 does not switch on automatically when the regulation applies. It starts only after the Commission adopts a delegated act establishing the construction DPP system (Article 75(1)). Once that delegated act enters into force, manufacturers then have 18 months to provide DPPs through the construction digital product passport system.
Others assume that because no deadline is fixed, there is nothing to do yet. That is equally wrong.
In December 2025, the European Commission published the first CPR Working Plan for 2026-2029, providing the first product-family-specific roadmap for when harmonised standards and DPP obligations will unfold. The plan signals that regulatory implementation is now in motion. For the earliest product families - cement and concrete are cited as examples - revised standards are expected by end of 2027, after which the 18-month clock would start. For other families, the timeline stretches into 2028-2029.
The DPP registry itself must be operational by 19 July 2026. A delegated act setting rules for DPP service providers is expected in Q4 2026. The system is being built; the product-family obligations will follow.
What the construction DPP will contain
The construction DPP is not a replacement for existing instruments - it is designed to sit alongside them and make their data digitally accessible.
The Declaration of Performance and Conformity and CE marking remain central for market access. The DPP builds on top of that foundation, adding:
| Data layer | What it includes |
|---|---|
| Product identification | Unique product identifier, manufacturer, trade name, intended use under CPR |
| Performance & safety | Essential characteristics, test results, safety instructions, technical documentation |
| Environmental data | EPD-aligned lifecycle indicators (GWP, resource use, waste), substance information per REACH |
| Circularity information | Deconstruction potential, reuse and recycling guidance, end-of-life routes |
| DoPC | The Declaration of Performance and Conformity, accessible digitally through the DPP system |
A data carrier - QR code, NFC, or RFID - will link the physical product to its passport. The construction DPP system is designed to be interoperable with the wider ESPR DPP infrastructure, including the central EU registry.
The scale of the challenge is not trivial. Construction generates 38.4% of all EU waste - the largest share of any sector (Eurostat, 2024) - while circular material use in the sector stands at just 12.2%. The DPP is explicitly designed to close the information gap that makes tracking product impacts at scale so difficult.
EPDs: your most important preparation asset
Environmental Product Declarations (EPDs) per EN 15804+A2 are already well established in the construction sector. Under CPR 2024/3110, they become even more central: the regulation requires EPD data to be included in the DoPC, making environmental data an integral part of product performance information rather than a voluntary add-on.
EN 15804+A2 became mandatory for all new EPDs in October 2022, expanding core environmental impact indicators to 13 and introducing mandatory end-of-life reporting. Manufacturers who already maintain verified, structured EPD data have a significant head start: that data is the primary source for the environmental and circularity fields the construction DPP will require.
An EPD does not replace CPR conformity - CE marking and the DoPC remain the market-access instruments. But a well-structured, machine-readable EPD is the most reusable data asset you can build right now. It feeds the DoPC today, the DPP tomorrow, building-level LCAs under the revised Energy Performance of Buildings Directive (EPBD), and green procurement tenders that are already asking for verified environmental data.
What construction manufacturers should do now
The 18-month window after the Article 75 delegated act sounds generous. It is not. In complex supply chains - where EPD data must be collected across multiple plants, verified by a Notified Body, and structured into machine-readable formats - 18 months is a critically short period.
Ensure all relevant products have verified EPDs aligned with EN 15804+A2. Check that lifecycle modules C1–C4 (end of life) and Module D (beyond system boundary) are declared — these feed the circularity fields the DPP will require. EPDs expire after five years; plan renewal cycles now.
The DoPC replaces the old DoP from 8 January 2026. Start structuring your declaration data in digital, machine-readable formats rather than PDFs. The DPP system will require human- and machine-readable documents; building that capability now avoids a costly retrofit later.
The construction DPP will require a globally unique product identifier linked to a data carrier (QR code, NFC, or RFID). Begin assigning GTINs or ISO/IEC 15459-compliant identifiers to your product models. GS1 Digital Link is the expected standard for the data carrier.
Information on substances of very high concern (SVHCs) above 0.1% w/w must be provided with the DoPC under Article 15(6) of CPR 2024/3110. This data will also be required in the DPP. Audit your formulations and supplier data now.
The DPP obligation starts 18 months after the Article 75 delegated act enters into force. Monitor the CPR Working Plan 2026–2029 for your product family's harmonised standard revision timeline. When the standard is mandated, the 18-month clock starts. Subscribe to Commission updates and industry body communications (Construction Products Europe is a key source).
The bottom line
Construction's DPP is not a future policy idea. It is embedded in EU law through CPR 2024/3110, which has been in force since January 2025 and generally applicable since January 2026. The obligation to provide a DPP is not yet active - it waits for the Article 75 delegated act - but the infrastructure is being built, the working plan is published, and the first product families are on a clear runway toward mandatory DPPs by the late 2020s.
The manufacturers who treat 2026-2028 as preparation years - cleaning up bills of materials, expanding EPD coverage across their portfolio, structuring DoPC data in machine-readable formats - will be ready to activate full DPPs with minimal additional effort when their product family's deadline arrives. Those who wait for an "official date" in the Official Journal will find 18 months is not enough time to build what they need from scratch.
Your EPD data is not a compliance cost. It is the foundation of your DPP. Start there.
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