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, published in November 2024 and becoming applicable in stages from 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.ihre-firma.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. The product passport must contain at minimum:
- manufacturer identification (with a EUDAMED-like registration)
- product type and variant
- Declaration of Performance (DoP) under existing CPR rules
- Environmental Product Declaration (EPD) following EN 15804
- usage, installation and maintenance instructions
- where needed: a safety data sheet
- dismantling and recycling instructions - new compared with the old CPR
The EPD is not optional. The new CPR moves it from a voluntary recommendation into the mandatory register. For construction-product manufacturers this means: one EPD study per relevant product family, updated every 5 years.
Realistic roadmap for manufacturers
The CPR application dates are staggered:
- 2026: technical secondary acts - specification of the CPP data fields
- 2027/2028: obligation for large product groups (cement, steel, insulation)
- 2029+: full application to all construction products
On the production side this means:
- 2026 Q2: check which of your products belong to the first CPP wave (probably high-volume building materials)
- 2026 Q4: begin EPD creation if not yet available
- 2027 Q1: consolidate data collection for the CPP - ideally in a platform that can map both the CPP and the ESPR DPP
- 2027 Q4: pilot implementation for the first product family, in parallel with DoP creation
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.