Digital Product Passport for construction products

No date is fixed in the regulation. Art. 75(1) obliges the Commission to set up the construction passport system 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.

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. The new regulation replaces the old harmonised standards family by family, which is exactly what the CPR working plan sequences. So the honest answer for many products today is that the passport will arrive when your product family’s specification does.

Importers have their own obligations under Art. 24 and must place only compliant products on the market. They become fully responsible as manufacturers the moment they sell under their own name or trademark, change the declared use, or claim characteristics that differ from the manufacturer’s (Art. 26(1)). Private-label building materials are common enough that this catches more importers than expect it. Settle the data flow in the supply contract, not after the first audit.

That is the normal case in this industry and it is not a problem. Art. 22(5) already requires a manufacturer-specific unique identification code of the product type plus a batch or serial number where one exists, and the passport builds on unique identifiers issued under Art. 79. Transpareo turns a GTIN into a GS1 Digital Link where you have one, and issues a unique Transpareo identifier where you do not, producing the QR code either way. More on this in how the DPP works without a GTIN.

Yes, and it has to. Cement, concrete and aggregates differ from delivery to delivery, which is why Art. 22(5) asks for a batch or serial number alongside the product type code. In Transpareo you can publish at product level, at batch level or at item level, so one QR code on a delivery note leads to the composition of that batch rather than to a generic average. That is also what makes a later deconstruction audit possible.

No, it contains it. Art. 76(2) lists what a construction passport carries, and the declaration of performance and conformity referred to in Art. 15 is the first item, alongside the general product information and safety information of Art. 22(6), the technical documentation of Art. 22(3), the label and the unique identifiers. The declaration is the core; the passport is the structured, machine-readable container plus the access rules around it.

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 once in the recitals, as the source of characterisation factors for that software, and even there it is qualified with “or future applicable standards”. If you already hold an EPD, its underlying data will carry most of Annex II; if you do not, the Commission’s calculation route is the one the regulation actually points at.

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 to more detailed or alternative rules if the construction act sets any. So a company that already runs product passports for another product group is adapting, not starting again.

The regulation names it explicitly. Art. 75(2)(a) requires the construction passport system to be built on the ESPR passport “without compromising interoperability with Building Information Modelling”. What that means in detail will be set in the delegated act. Practically, it means your product data has to leave the passport in a structured form that a planning model can consume, which is a good reason not to store it as PDFs.

For an established period after the last product of its type was placed on the market (Art. 76(2)(h)), with the length to be set in the delegated act. The important part is already fixed - the passport has to remain available for that period even after insolvency, liquidation or the operator ceasing activity in the Union (Art. 78). Buildings outlive suppliers, so ask every provider what happens to your passports after a cancellation. With Transpareo they stay reachable through a permanent address, and our provider checklist names the other questions worth asking.