DPP for Construction Products
How the new Construction Products Regulation (EU) 2024/3110 introduces mandatory Digital Product Passports for concrete, steel, insulation, and other covered products — with a 10-year post-lifetime data retention requirement.
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 — placing the sector within the broader EU trajectory toward product-level digital transparency, even though construction products are outside the scope of ESPR.
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 covers the DPP system infrastructure: the technical requirements for the digital registry, data carriers, and the architecture for accessing DPP data. The Commission must establish the digital infrastructure before DPPs can become mandatory — this is estimated to be operational in 2026 or 2027.
Article 76 defines the DPP content requirements. Every DPP for a construction product must include:
- Unique product identifier — a GS1 Global Trade Item Number (GTIN) is the recommended standard
- Declaration of Performance (DoP) or Declaration of Conformity (DoC) — the existing legal compliance documentation for the product under EU harmonised technical standards
- Technical specifications: structural strength, fire resistance classification, thermal performance, and other essential characteristics relevant to the product category
- Environmental sustainability data: recycling rates, durability, lifecycle assessment data, and circular economy indicators
- Carbon footprint and Environmental Product Declaration (EPD) data: carbon footprint per functional unit, aligned with EN 15804 methodology for construction products
- Recyclability and end-of-life information: how the product should be sorted, dismantled, and recycled at end of life
- Safety data and installation instructions
- CE marking references
The 10-Year Data Retention Requirement
One of the most operationally significant provisions of the CPR DPP framework is the data retention obligation. Under the regulation, the DPP must be maintained for the lifetime of the product plus 10 additional years.
For construction products, product lifetimes are measured in decades. A structural steel component or concrete element installed in a building may remain in service for 50 to 100 years. The DPP for that product must therefore remain accessible and data-complete for potentially 110 years or more.
The regulation specifically addresses the scenario of manufacturer insolvency: the DPP must remain accessible even if the manufacturer ceases to exist. This requires data hosting arrangements that do not depend on the continued operation of any single commercial entity — a technical requirement that existing IT infrastructure rarely meets out of the box.
Priority Products
DPPs will not be mandatory simultaneously for all construction products. The regulation establishes a phased approach, with priority products subject to mandatory DPP requirements first:
- Concrete
- Steel (structural steel and reinforcing steel)
- Insulation materials
- Further product categories will be added via delegated acts
The Commission must establish the digital infrastructure — the DPP registry, APIs, and data-sharing systems — before the mandatory DPP requirements can take effect. Once the infrastructure is operational, manufacturers of priority products will have 18 months to comply.
The current estimate is infrastructure operational by 2026 or 2027, making the first mandatory compliance deadlines for priority products fall approximately in late 2027 to mid-2028.
The 2032 Full Coverage Target
The regulation sets 2032 as the target year for full DPP coverage across all construction products within scope. By that date, the Commission aims to have:
- All essential characteristics of all covered construction product categories covered by DPP requirements
- All DPP data standardised and machine-readable
- Full integration with the broader EU product data ecosystem, including ESPR DPP infrastructure
Interplay with ESPR
Construction products are not covered by ESPR (Regulation (EU) 2024/1781). The two frameworks run in parallel, not in hierarchy.
However, they share the same conceptual architecture — unique identifiers, QR codes or RFID carriers, decentralised data hosting, registry-based identifier management, and layered access rights for different actors. The Commission has signalled an intent for these two ecosystems to be technically interoperable, though as of March 2026 the specific integration mechanisms remain to be defined in implementing acts.
For manufacturers producing products that fall under both frameworks — for example, steel used both as a construction product and in manufactured goods covered by ESPR — the practical requirement to maintain two separate DPP systems is an open compliance 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 — not PDF, but structured data accessible via API
- Persistent — not tied to the manufacturer's CRM or ERP system lifecycle
- Linked to individual product identifiers — not just product models, but potentially individual batches or items
For manufacturers of concrete, steel, and insulation: begin assessing your Declaration of Performance 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) 2024/1781 (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