The construction industry lives in a world of its own when it comes to product identification. A Ford Fiesta has a VIN, a pack of ibuprofen has a pharmaceutical number, a bottle of olive oil has a GTIN. A bag of Portland cement? A batch number that the worker writes on the bag with a waterproof pen.
When the DPP arrives across the board, the construction sector faces a specific question: how do you identify products uniquely and durably that traditionally were not identified individually?
Why GTINs do not work in the construction industry
The GTIN (Global Trade Item Number) is a trade identifier. It names an item as it circulates in trade. With construction products this fails in several places:
- bulk goods such as cement, sand and gravel are delivered by the tonne on lorries. No individual “item”.
- made-to-measure products such as steel beams are produced to customer specification. Each beam tends to be unique.
- batch-based products such as mortar or concrete have different properties per batch (daily production).
- system components such as windows or doors are configurable - every order is different.
A single GTIN per product does not exist, because the concept of “product” is more diffuse in the construction industry.
The way out: batch- and serial-number-based identification
The EU has recognised this. In the new Construction Products Regulation (EU) 2024/3110, in force since 7 January 2025 and applicable since 8 January 2026, there is a dedicated “Construction Products Passport” (CPP). Its identification is based on:
- product type (base identifier - for example the DoP number from the Declaration of Performance)
- batch number or production date (variable)
- optionally a serial number for individual pieces
This aligns with GS1 logic. GS1 offers Application Identifiers:
-
01- GTIN (where present) -
10- batch number (BATCH/LOT) -
11- production date -
21- serial number -
8004- GIAI (Global Individual Asset Identifier) where no GTIN is maintained
A GS1 Digital Link such as:
https://id.example.com/01/04012345678901/10/2026-W14-A
identifies a product type 04012345678901 from batch 2026-W14-A. For the construction industry, the combination that works.
CPR vs. ESPR: two legal acts, one passport?
Here it gets complicated. The CPR revision has its own passport framework. The ESPR has a framework. Both refer to each other, but the technical specifications are not identical.
A manufacturer of concrete roof tiles is subject to both: the CPR for the construction-product properties, the ESPR for environmental aspects such as recyclability.
In practice this means: two data layers, both findable under the same product ID. The common data model behind them is still under discussion. The EU working group (CEN/CENELEC JTC 24) is working on proposing a shared structure by the end of 2026.
Realistically: manufacturers that start now should choose a data structure that supports extensibility. A rigid ESPR-only format will have to be readjusted. A CPP-compliant format covers more.
What exactly is in the CPP
The CPR defines an extensible structure. Art. 76(2) lists what a construction passport carries:
- manufacturer identification and the unique identifiers
- product type and variant
- declaration of performance and conformity under Art. 15
- environmental essential characteristics of Annex II, declared over the life cycle
- usage, installation and maintenance instructions
- where needed: a safety data sheet
- dismantling and recycling instructions - new compared with the old CPR
An EPD to EN 15804 is not part of that duty. The operative text works with the Annex II characteristics, calculated with software the Commission provides free of charge (Art. 15(2)); EN 15804 appears only in the recitals, as the source of characterisation factors for that software. If you already hold an EPD, its underlying data covers most of Annex II.
Realistic roadmap for manufacturers
No date is fixed in the regulation. Art. 75(1) obliges the Commission to set the passport system up by delegated act but names no deadline for doing so. Once that act enters into force, Art. 80(1) starts two clocks:
- six months to a fully operational passport system
- eighteen months to the manufacturer duty of Art. 22(7)
The Commission’s own timeline places the act indicatively in the second quarter of 2027, which is where the commonly quoted late 2028 and 2029 figures come from.
That is arithmetic on an indicative date, not law.
On the production side this means, in this order:
- check which of your products a harmonised technical specification covers, because the obligations of Art. 20 hang on that
- assemble the Annex II environmental characteristics, which have been moving into the declaration of performance and conformity since 8 January 2026 anyway
- consolidate the data collection, ideally in a platform that can map both the construction passport and the ESPR passport
- pilot a first product family, in parallel with the declaration
In practice: what if your product fits no standard?
There are construction products that fit into no box. Custom-made steel staircases, bespoke special-glass elements, concrete with a special aggregate for special structures. Here two pragmatic routes are possible:
- Project passport: the entire delivery for a construction project is treated as one passport. Not every individual beam gets its own QR code. Works if the installer documents the overall project.
- Laser-marked batch ID: every physical product carries a permanent ID (lasered, etched). The passport resolver maps the ID to the batch data.
Which route is right depends on the reuse scenario. For recycling operations in the year 2065, option 2 counts for more - the infrastructure for “project passports” will hardly survive.
Everything the regulation asks of construction product manufacturers, with the timeline, the roles, the required data, the official documents, is in our reference on the Digital Product Passport for construction products.
Questions on this article
Do we need a GTIN at all?
No. Art. 22(5) of Regulation (EU) 2024/3110 asks for a manufacturer-specific unique identification code of the product type plus a batch or serial number where one exists, and the passport builds on the unique identifiers of Art. 79. Neither names a GTIN. Where you have one, Transpareo turns it into a GS1 Digital Link that other systems resolve too; where you do not, the passport carries a unique Transpareo identifier and the QR code leads to it just the same.
When does the construction passport actually become mandatory?
No date is fixed in the regulation. Art. 75(1) obliges the Commission to set the passport system up by delegated act but names no deadline for doing so. Once that act enters into force, Art. 80(1) starts two clocks - six months to a fully operational system, eighteen months to the manufacturer duty of Art. 22(7). The Commission’s own timeline places the act indicatively in the second quarter of 2027, which puts the duty around late 2028 or 2029 if the plan holds. Anyone naming a firm month today is guessing.
Does it apply to every construction product?
Not yet. Art. 20 gates the economic operator obligations to products covered by a harmonised technical specification or CE-marked on the basis of a European technical assessment, and the new regulation replaces the old family of harmonised standards family by family. For many products the honest answer today is that the passport arrives when the specification for your product family does.
Our composition varies from batch to batch. What does the QR code point at?
Whatever level you publish at. That variation is exactly why Art. 22(5) asks for a batch or serial number alongside the product type code. In Transpareo you publish per product type, per batch or per individual item, so a code on a delivery note leads to the composition of that delivery rather than to a generic average, which is what makes a deconstruction audit decades later worth anything.
Do we have to produce an EPD to EN 15804?
Not as a duty written into the regulation. The operative text works with the predetermined environmental essential characteristics of Annex II, declared over the life cycle and calculated with software the Commission provides free of charge (Art. 15(2)). EN 15804 appears only in the recitals, as the source of characterisation factors for that software, and even there with the qualifier “or future applicable standards”. If you already hold an EPD, its underlying data carries most of Annex II; if you do not, the Commission’s calculation route is the one the regulation actually points at.
Is the construction passport the same as the ESPR passport?
Not the same, but deliberately not separate either. Art. 75(2)(a) requires the construction system to be compatible with, interoperable with and based upon the passport established by Regulation (EU) 2024/1781, and Art. 79 applies the ESPR rules on unique identifiers, the registry and the web portal, with the first two yielding if the construction act sets more detailed or different rules. A manufacturer of concrete roof tiles falls under both acts and should treat that as one data structure with two views, not as two projects.
What about a bespoke item that fits no product family?
Two routes work, and they differ in what survives. A project passport treats the whole delivery for one building as a single passport, which holds up as long as the installer documents the project. A permanent mark on each piece, lasered or etched, maps that piece to its batch data for as long as the piece exists. For a recycler in 2065 the second is worth far more, because the project documentation will be long gone.
Do construction passports go into the EU register too?
Art. 79 applies the ESPR rules on the registry to construction passports, so the entry is the same act it is elsewhere and it is made by the economic operator itself. The register has been operational since 20 July 2026 under Implementing Regulation (EU) 2026/1778, and the specification of its interface is still evolving. What a provider can do is prepare what the entry asks for, the product identifier, the operator identifier, the passport address and the fingerprint. What no provider can do is make the entry for you.
