DPP for Construction Products

How the new Construction Products Regulation (EU) 2024/3110 introduces mandatory Digital Product Passports for construction products, what they must contain, and when the obligation applies.

A New Regulation for Construction Products

Regulation (EU) 2024/3110 — the new Construction Products Regulation — entered into force on 7 January 2025. It replaces Regulation (EU) 305/2011 (CPR 2011), which had governed construction product market access since 2011.

The new CPR is a significant expansion of what was primarily a technical harmonisation framework. It introduces Digital Product Passports as a mandatory requirement for construction products. This places the sector within the broader EU trajectory toward product-level digital transparency, with the CPR rather than ESPR as the main legal act for construction products (recital 32).

DPP Requirements: Articles 75 and 76

The DPP obligations for construction products are set out in Articles 75 and 76 of Regulation (EU) 2024/3110.

Article 75 requires the Commission to set up a construction DPP system by delegated act. That act will set who can access and update DPP information, how DPPs stay available after an insolvency, the requirements for DPP service providers and, where needed, more detailed rules on identifiers, data carriers and the registry (Art. 75(1) and (2)). It had not been adopted as of 9 October 2026. The Commission indicates Q2 2027 for it, an indicative date (European Commission). The system must be fully operational 6 months after the act enters into force (Art. 80(1)).

Article 76 sets out what the DPP must contain. Under Article 76(2)(a), it must include:

• The declaration of performance and conformity (Art. 15), with the documentation provided together with it (Annex V)
• The general product information, instructions for use and safety information (Art. 22(6))
• The technical documentation (Art. 22(3))
• The environmental sustainability label, where one is required (Art. 22(9))
• Unique identifiers (Art. 79(1))
• Documentation required under other EU law that applies to the product
• Data carriers of key parts for which a DPP is available

The DPP must correspond to the product type and its unique identification code (Art. 76(2)(d)) (Regulation (EU) 2024/3110).

The 10-Year Data Retention Requirement

One of the most operationally significant provisions of the CPR DPP framework is the data retention obligation. The construction DPP system must be accessible for 25 years after the last product of a product type has been placed on the market, and the economic operator must make the DPP available for at least 10 years (Art. 75(2)(i)).

The regulation specifically addresses the scenario of manufacturer insolvency: the DPP must remain available after an insolvency, a liquidation or a cessation of activity in the Union of the economic operator that created it, including through a back-up system run by DPP service providers (Art. 75(2)(f) and Art. 78(e)). This requires data hosting arrangements that do not depend on the continued operation of any single commercial entity.

When the DPP Becomes Mandatory

The manufacturer's obligation to make a DPP available applies 18 months after the delegated act under Article 75(1) enters into force (Art. 22(7) and Art. 80(1)). Manufacturers may use the system voluntarily before then (Art. 80(1)). Products for which a manufacturer applies the Article 14 exemption from drawing up a declaration of performance and conformity are also exempt from the DPP (Art. 76(4)).

That delegated act had not been adopted as of 9 October 2026, so the date from which the DPP becomes mandatory is not yet set. The Commission's indicative date for the act is Q2 2027 (European Commission).

Environmental Data Phased In to 2032

The 2032 date in the CPR concerns the environmental data in the declaration of performance and conformity, which the DPP must include. The declaration covers the product's environmental performance over its life cycle for the declared environmental characteristics listed in Annex II (Art. 15(2)), and must cover at least:

• Climate change effects (Annex II, points (a) to (d)) from 8 January 2026
• Points (e) to (m), such as ozone depletion, acidification, eutrophication and water use, from 9 January 2030
• Points (n) to (s), such as particulate matter, eco-toxicity and land use related impacts, from 9 January 2032

These dates are set in Article 15(3) (Regulation (EU) 2024/3110).

Interplay with ESPR

The CPR, not ESPR (Regulation (EU) 2024/1781), is the main legal act for construction products, including their sustainability aspects. ESPR can apply to them only in exceptional cases, in a complementary manner, where CPR requirements are insufficient and cannot be amended or complemented in reasonable time (CPR recital 32). The same recital gives ESPR priority for sustainability requirements in two cases: energy-related products in the ecodesign working plans that are also construction products, such as heaters, boilers and heat pumps, and intermediate products such as steel, with the exception of cement. ESPR provides for one such case: if the CPR lacks adequate requirements on the environmental and carbon footprint of cement, the Commission must set ecodesign requirements for cement under ESPR, not earlier than 31 December 2028 and not later than 1 January 2030 (ESPR Art. 18(6)).

The two DPP systems share the same architecture. The CPR requires the construction DPP system to be compatible with, interoperable with and based upon the ESPR DPP (Art. 75(2)(a)), and applies the ESPR rules on unique identifiers, data carriers, the DPP registry and the web portal unless the CPR delegated act sets more detailed or alternative rules (Art. 79). The specific mechanisms will be set in the delegated act under Article 75(1).

For products that fall under both frameworks, such as steel, the CPR still applies alongside ESPR where needed, mainly for safety aspects (CPR recital 32). How their two sets of DPP requirements will fit together is an open question that delegated and implementing acts will need to resolve.

What This Means for the Construction Sector

The construction industry has historically operated with product documentation held in paper form — Declaration of Performance documents, CE marking files, test reports. The CPR DPP requirement means this documentation must become:

• Digital and machine-readable: based on open standards and, as appropriate, machine-readable, structured and searchable. Documents accompanying the declaration and the technical documentation may be exempt where justified for technical reasons (Art. 77(1)(d))
• Persistent — not tied to the manufacturer's CRM or ERP system lifecycle
• Linked to product identifiers: each DPP corresponds to the product type and its unique identification code (Art. 76(2)(d) and Art. 77(1)(a))

For construction product manufacturers: begin assessing your declaration of performance and conformity documentation and EPD data now. The infrastructure and compliance windows are approaching faster than the sector's typical procurement and IT investment cycles.

Sources

• Regulation (EU) 2024/3110 (Construction Products Regulation), Articles 75–76 — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/3110/oj
• Regulation (EU) 2024/3110, Articles 15, 22(7), 77 to 80 and recital 32, EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng
• European Commission, Digital Product Passport page (indicative timeline): https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en
• Regulation (EU) 2024/1781 (ESPR) — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
• European Commission — ESPR DPP Registry framework (Green Forum): https://green-forum.ec.europa.eu/implementing-ecodesign-sustainable-products-regulation_en