Construction Products Regulation (EU 2024/3110): the CPR and the Digital Product Passport
The new Construction Products Regulation (EU) 2024/3110 introduces a digital product passport for construction products plus a Commission-run registry. What the passport must carry, how it links to the declaration of performance and conformity, and the transition timeline away from the 2011 CPR.
Construction Products Regulation (EU 2024/3110): the CPR and the Digital Product Passport
Construction accounts for roughly half of all raw material extraction in the EU and about a third of the waste it generates. It is hard to name a sector where data on composition, origin and reusability would be worth more — and hard to name one where that data is more scattered. Declarations of performance sit as PDFs on manufacturer servers, environmental product declarations (EPDs) in programme-operator databases, factory production control certificates with notified bodies, and technical datasheets in sales catalogues. The new Construction Products Regulation pulls all of it into one place.
Regulation (EU) 2024/3110 was adopted on 27 November 2024, published in the Official Journal on 18 December 2024 and entered into force on 7 January 2025. It applies from 8 January 2026, the date on which Regulation (EU) No 305/2011 is repealed. Among its innovations is a digital product passport for construction products, together with a registry operated by the European Commission. After the ESPR and the Toy Safety Regulation, this is the third piece of EU product law to mandate a digital product passport outright — and the first to do so for products sold in bulk, on pallets and by tanker.
Key takeaways
- Regulation (EU) 2024/3110 (the new CPR) replaces Regulation (EU) No 305/2011. It entered into force on 7 January 2025 and applies from 8 January 2026.
- The CPR introduces a digital product passport for construction products and a Commission-run passport registry, built on the same logic as the ESPR passport: a unique product identifier, a data carrier, open standards and machine-readable data.
- The declaration of performance and conformity — the document in which the new CPR merges the old declaration of performance with the CE declaration of conformity — is to be made available through the passport.
- The passport also carries environmental sustainability data. The Commission is to phase the indicators in, starting with total global warming potential (GWP), based on the established methodology for environmental product declarations for construction products.
- The data carrier does not have to sit on the product itself: for cement, aggregates or ready-mix concrete it may be placed on the packaging or in the documents accompanying the delivery.
- The changeover is not a single event. Existing harmonised standards stay in use until new harmonised technical specifications replace them, so the passport obligation arrives product family by product family — realistically from the end of this decade, with the old regime phasing out into the 2030s.
- myDPP is not a notified body, does not perform testing or factory production control, does not issue declarations of performance and does not produce EPDs. myDPP stores, versions and serves verified product data and the data carrier that opens it.
What the new CPR changes
Regulation (EU) No 305/2011 had a single ambition: to harmonise how manufacturers declare the performance of construction products, so that a product cleared in Portugal could be built into a wall in Poland without further paperwork. It failed on mechanics, not on intent. The system rested on harmonised standards, and the process for adopting and citing them in the Official Journal seized up for more than a decade. Hundreds of standards were written but never cited; manufacturers of newer solutions took the slow, expensive European Technical Assessment route; national rules crept back into the gaps the single market was meant to close.
The new CPR answers this in three ways. First, it gives the Commission tools to act when standardisation fails to deliver, in the form of implementing acts laying down common specifications. Second, it widens the scope: alongside products intended for permanent incorporation in works, it now reaches datasets for additive manufacturing, key parts, and reuse and remanufacturing activities. Third, it moves the system onto digital data — and that is where the digital product passport comes in.
The compliance document itself also changes. The old declaration of performance and the CE declaration of conformity are merged into a single declaration of performance and conformity. That is not cosmetic: one document means one set of data fields, one version, and one place where it can live — the passport.
Timeline
| Date | Milestone |
|---|---|
| 27 November 2024 | Regulation (EU) 2024/3110 adopted |
| 18 December 2024 | Published in the Official Journal of the EU |
| 7 January 2025 | Entry into force |
| 8 January 2026 | Application begins; Regulation (EU) No 305/2011 repealed |
| 2026–2028 | Delegated and implementing acts: passport and registry architecture, environmental requirements, first new harmonised technical specifications |
| from ~2028 | The DPP obligation lands with the relevant technical specification — product family by product family |
| 2030s | Phase-out of harmonised standards from the 305/2011 regime |
Two things are worth taking from that table. First, 8 January 2026 is not the day a manufacturer must have a passport ready. Second, it is also not a date after which the topic can be parked for five years, because sequencing depends on the harmonised technical specifications for individual product families — and those are being drafted now. Makers of cement, insulation, reinforcing steel and windows and doors will be in the first waves.
The digital product passport for construction products
The construction passport works on the same principle as the ESPR passport: a structured, machine-readable set of data linked to the product through a persistent unique identifier and opened by a data carrier. The content, however, is tailored to the sector.
Identification and compliance data
- the unique product identifier and the economic operator identifier (and the manufacturing facility identifier where applicable);
- the declaration of performance and conformity;
- declared performance for essential characteristics under the applicable harmonised technical specification;
- a reference to the technical documentation, including the notified body’s details where one was involved in assessment and verification of constancy of performance;
- the CE marking and the intended use.
Safety and use
- instructions for use and installation, and safety information, in the languages of the markets where the product is made available;
- the safety data sheet where REACH or CLP requires one;
- information on substances of very high concern — the point where the passport meets the SCIP database notification duty.
Sustainability and end of life
- declared environmental characteristics;
- recycled content and the origin of raw materials, to the extent the specification requires;
- information on dismantling, reuse, remanufacturing and recycling — for a product that will be pulled out of a building forty years from now.
The manufacturer keeps the declaration and the technical documentation for at least ten years after the product is placed on the market, and the regulation allows for a longer period for product families with long service lives. Identifiers and data carriers are recorded in a Commission-operated passport registry, which is to be interoperable with the ESPR passport infrastructure. That matters for manufacturers working across several regimes: this is not two parallel passport worlds, but one identification layer with sector-specific datasets.
Environmental data: from EPD to passport field
For many manufacturers the biggest practical change is not the passport itself but what it has to carry. The new CPR makes declaring environmental performance a mandatory part of the system — until now EPDs were voluntary and were mostly produced when a building certification scheme (BREEAM, LEED, DGNB) or a public procurement rule asked for one.
The Commission is to phase the indicator set in. Total global warming potential (GWP-total) comes first, with the remaining indicators from the environmental product declaration methodology following — acidification, eutrophication, resource use, water use. For a manufacturer that means three jobs at once: getting emissions data from raw material suppliers, calculating its own production stage, and keeping the result under version control, because recipes and energy mixes change. This is where calculating a product carbon footprint stops being a marketing project and becomes a compliance artefact with a full evidence trail.
A data carrier for products you cannot label
A construction product rarely looks like a consumer product. It often has no unit packaging, it is sold by weight, by tanker or by pallet, and its “unit” is frequently a production batch rather than an item. The CPR accommodates this: the data carrier may sit on the product, on its packaging, or in the documents accompanying the delivery.
That solves the legal problem but not the data problem. Three decisions come back in every construction project:
- Level of identification. Does the passport describe a product type, a batch, or an individual element? For ready-mix concrete the natural unit is a batch and a specific delivery; for a window, a serial-numbered item; for plasterboard, a type with a batch number printed on the edge.
- Durability of the link. A code on a pallet does not survive a building site. If the passport is meant to serve demolition decades later, the link has to persist in the documentation of the works — which is why construction data will end up in BIM models and digital building logbooks.
- Identifier continuity. Changing a recipe, a plant or a clinker supplier changes the environmental data. You need a rule for when this creates a new passport version and when it creates a new identifier.
The technical layer is shared with other DPP regimes: GS1 Digital Link lets one code serve both a scan on site and a system-to-system query.
CPR and ESPR — who governs construction products
The two acts could easily collide, since both introduce a passport and both address design and life cycle. The split is deliberate: the CPR is the sectoral regime for construction products, and the ESPR can step in for aspects the CPR does not address. In practice a building materials manufacturer looks first at the harmonised technical specifications for its product family rather than at ESPR delegated acts — but it cannot assume the ESPR is irrelevant, particularly for dual-use products such as radiators, heat pumps or luminaires, where the ecodesign and construction regimes meet on a single product.
The new CPR also brings in rules on unsold construction products, shifting the balance towards reuse and donation rather than destruction — the same direction the ESPR took for textiles and footwear.
What a construction products manufacturer should do now
1. Map the portfolio to product families and their dates
The obligation does not arrive on one date. The first step is a list of products mapped to families and to the harmonised technical specifications that cover them, with the status of work on the new specifications. That list, not 8 January 2026, sets the sequence of the project.
2. Consolidate compliance data into one governed source
Declarations, EPDs, FPC certificates, datasheets and safety data sheets usually live in four different systems plus a fifth place — a network drive. A passport needs a single source with versioning and history, because the data has to be provable years later. Our article on DPP and PIM explains why this is usually the most expensive stage of an implementation.
3. Settle identification
Decide the level of identification for each product family, assign identifiers, and set versioning rules. Without this the rest of the project stalls, because there is nothing to attach the data to.
4. Build the capability to calculate environmental data
Environmental data differs from the rest: it is calculated rather than declared, and it depends on suppliers. You need a repeatable process for collecting primary data from raw material and energy suppliers, and a method for updating results when a recipe changes.
5. Bring logistics and sales in early
If the data carrier is going onto a pallet or into a delivery note, the project touches labelling, the warehouse system and shipping documents — teams that compliance projects usually invite far too late. Our DPP implementation checklist walks through the order of work.
Frequently asked questions (FAQ)
When does the digital product passport become mandatory for construction products?
There is no single date. The regulation applies from 8 January 2026, but the passport obligation for a given product arrives with the harmonised technical specification covering its family and with the acts defining the passport architecture. Realistically, expect the first product families from the end of this decade.
Does the passport replace the declaration of performance?
It does not replace it; it becomes the channel through which it is made available. The new CPR merges the old declaration of performance with the CE declaration of conformity into a single declaration of performance and conformity, and that document is to be accessible through the passport. The duty to draw it up, and the manufacturer’s liability for it, remain.
Does the QR code have to be on the product itself?
No. For construction products the data carrier may be on the product, on the packaging, or in the accompanying documents — which is the only workable option for cement, aggregates or ready-mix concrete.
Do I need an EPD for every product?
Declaring environmental performance is becoming part of the system rather than an option. The scope of indicators and the deadline depend on the harmonised technical specification for the product family; total global warming potential is the first indicator in line.
Are existing declarations and standards still valid?
Yes, during the transition. Harmonised technical specifications adopted under Regulation 305/2011 stay in use until they are replaced. Products placed on the market under the old rules do not become illegal overnight — the changeover runs family by family.
How does the construction passport differ from the ESPR passport?
Not in infrastructure: identifier, data carrier, registry and open standards are shared. It differs in content. The construction passport is built around declared performance and conformity, the ESPR passport around ecodesign indicators. A manufacturer operating under both needs one data layer, not two.
Read next
- DPP in 15 minutes — what a digital product passport is
- ESPR regulation — ecodesign requirements explained
- CE marking and the digital product passport
- Product carbon footprint (PCF) and the DPP
- EU Toy Safety Regulation — the DPP replaces the declaration of conformity
- DPP and PIM — why product data is the foundation
- How to implement a DPP — practical checklist
- Declaration of performance and conformity under the CPR — required fields and template