
Digital Product Passport for construction products
The Digital Product Passport for construction products often applies per batch, needs no GTIN and carries environmental figures.
Where Transpareo supports you
As the manufacturer you are responsible for the passport. Transpareo is the DPP platform on which you create, maintain and publish it. Each card leads to the matching section further down. The passport checklist for construction products lists every point in detail.
Your product needs a unique identifier and a QR code that leads to its passport. Transpareo creates both, even without a GTIN, per product type, batch or item.
The passport carries your declaration of performance, the CE documents and the technical values. Transpareo brings the fields for them, and you declare the values as the manufacturer.
Since 2026 the declaration of performance includes climate figures, and more follow by 2032. Transpareo keeps each figure in a field of its own, beside your environmental product declaration.
Importers need the declaration and the environmental figures from their producer. With Transpareo Upstream the producer fills in the fields, and you review every value.
Some information is for everyone, some only for demolition firms or authorities. In Transpareo you set for every field who may see it.
Every publication is signed, and any reader checks it with the Transpareo Time Machine. You export your data at any time in common formats.
A construction passport has to stay reachable for decades. In Transpareo every passport keeps a permanent address, and once registered, Transpareo Vault archives it for ten years.
Today your company makes the entry in the EU registry, once it has proved its identity there. Transpareo checks the passport first and prepares the details the entry needs.
What is coming for construction product manufacturers
The digital product passport for construction products rests on a regulation of its own. Construction products got their passport before most industries did. Transpareo is the DPP platform on which manufacturers create it today.
Where the law stands
The new Construction Products Regulation replaced the regulation of 2011. It entered into force on 7 January 2025 and applies from 8 January 2026.
A chapter of its own sets up a passport system for construction products. It is built on the product passport of the Ecodesign Regulation. And it has to work with digital building models.
What is still moving
The Commission sets up the passport system with an act of its own. The regulation sets no deadline for it.
The construction passport system has no date yet.
Everything else hangs on that act. Six months after it, the system has to run. Eighteen months after it, manufacturers have to make a passport available.
The Commission plans the act for the second quarter of 2027. It calls this plan indicative itself. That is where the often quoted years 2028 and 2029 come from. They are arithmetic on a planned date.
What already applies today
The parts of the regulation with fixed dates are already running.
The declaration of performance and conformity replaces the old declaration of performance and the declaration of conformity. Since 8 January 2026 it has included the first environmental characteristics. More follow in 2030 and 2032.
Questions also arrive from the building side. The EU buildings directive requires a climate figure for new buildings over their whole life cycle. It applies from 2028 to new buildings above 1,000 m² of useful floor area and from 2030 to all. The member states had to transpose the directive by 29 May 2026.
The data of the individual construction products counts for that figure, where it exists. Planners will therefore ask manufacturers for climate data per product. They need it in a form their calculation can take in. A product passport in Transpareo delivers these values in structured form.
Public buyers ask for data
The same data will soon count in tenders too. Public bodies in the EU award contracts worth around EUR 2.6 trillion every year. That is about 15 per cent of the EU’s economic output.
Marc Steiner is a judge at the Swiss Federal Administrative Court. At the DPP conference in Zurich on 8 October 2026 he spoke in a personal capacity. He showed how the product passport, industrial policy and the reform of procurement law fit together. To him they are “of a piece”.
Some of it already applies. The Net-Zero Industry Act requires minimum sustainability requirements. They apply to contracts covering net-zero technologies, including works contracts with such installations. The Energy Efficiency Directive gives the public sector an exemplary role. Its bodies cut their energy consumption by 1.9 per cent a year. Above the EU thresholds they buy only products, buildings and works with high energy efficiency.
Other parts are proposed. On 4 March 2026 the Commission proposed the Industrial Accelerator Act. Publicly bought steel, cement and aluminium for construction would then have to be low-carbon. Cement and aluminium would also have to come from the Union. The proposal would amend the Construction Products Regulation as well. On 9 September 2026 a proposal for new procurement rules followed. It makes the best price-quality ratio the standard. Quality gets at least 30 per cent of the score. Parliament and Council are still negotiating both proposals.
Procurement already runs on data. Since October 2023 public buyers in the EU have published their notices as structured eForms. A buyer who writes tenders as data will want to read the bidders’ evidence as data too.
Switzerland is one example of how this looks. At federal level the most advantageous tender has won since 2021. That is set in the Federal Act on Public Procurement. Since 2025 its contracting authorities set environmental requirements in their technical specifications, where suitable. The Climate Act gives the Confederation and the cantons an exemplary role. The award monitor of the Swiss construction industry shows the result. To mid-2026, qualitative criteria made up 52.8 per cent of the weighting on annual average, and 58.8 per cent at federal level. Swiss Federal Railways (SBB) weight the carbon footprint at 25 per cent in their tenders for rails. By their figures, rails from secondary steel cause about a third of the emissions.
Steiner’s conclusion: the effort the product passport takes is small next to the opportunities. In his view, whoever cannot supply product data in structured form risks tenders and export orders. The climate figure a tender asks for is in your declaration of performance and conformity anyway. With Transpareo you make it available as part of your product passport.
What this page covers
This page is your reference work on the digital product passport for construction products. It shows the timeline, the roles with their duties and the required data. Then come the official sources and a sample spreadsheet to compare with your own data. At the end are the questions construction product manufacturers ask us most often. A term underlined with dots opens the wording of the provision.
From the rules to the passport
In one picture: the rules that reach your product in grey. The data you already hold for them in teal. And the Transpareo product passport with its reading tiers in blue.
The three biggest hurdles in practice
- No trade identifier: cement, gravel, insulation and steel sections rarely carry a GTIN. What is required is a unique product type code and a batch or serial number, and a GTIN is no part of it. Most production systems have never shown those numbers outside the plant. Transpareo issues the identifier even without a GTIN.
- The batch is the product: composition varies between deliveries. A deconstruction audit in twenty years will want to know which delivery went into which wall. A passport per product type is not enough on its own for that. The passport is read long after the sale, by clients, users and deinstallers too. The Commission’s working plan sees it as a basis for digital building logbooks. In Transpareo you keep the passport per batch.
- Two regimes at once: old harmonised standards under the 2011 regulation stay in force until 2040. New technical specifications arrive family by family. For years your portfolio sits in both worlds, and your data model has to cope. In Transpareo you create your own fields for it.
More on this: Construction products without a GTIN: how the DPP works anyway and Carbon footprint in the DPP: which method.
Regulatory timeline for construction products
The key dates of the rules that apply to construction products or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 7 January 2025Revised Construction Products Regulation in force
Regulation (EU) 2024/3110 enters into force twenty days after publication. A first part applies at once, such as the definitions and the standardisation rules. The rest follows a year later.
- 16 December 2025First CPR working plan
The Commission publishes its first working plan under the Construction Products Regulation, for 2026 to 2029. It shows which product families get new technical specifications first. It confirms that the passport comes with an act of its own. It names no date for that act.
- 8 January 2026The new regulation applies
The old Regulation (EU) No 305/2011 is repealed. Some of its provisions stay in force until 8 January 2040. From now on the declaration of performance and conformity covers the first four environmental characteristics.
- 20 July 2026EU DPP register operational
The central registry for product passports goes live, one day after the legal deadline. Its Implementing Regulation (EU) 2026/1778 already names construction products. The registry is in place before the construction passport system. It has offered a test environment since the launch.
- 8 January 2027Penalties apply
The rules on penalties take effect. Each member state sets the amounts itself. Everywhere, market surveillance can stop the sale of a product.
- Q2 2027Passport act expected
The Commission plans the act for construction products for the second quarter of 2027. It calls its own timeline indicative. The regulation sets no date for it.
- After the actSix months, then eighteen
Six months after the act, the construction passport system has to run. After eighteen months, manufacturers have to make the passport available. In between, they may use the system voluntarily.
- 9 January 2030More environmental characteristics declared
More environmental characteristics join the declaration of performance and conformity. The last ones follow on 9 January 2032. Then the declaration covers the full environmental profile, from climate to land use.
- 8 January 2040The old regulation finally goes
The last provisions of Regulation (EU) No 305/2011 expire. Until then two sets of rules sit side by side. That is why a product’s paperwork can look inconsistent without anyone being wrong.
Who is affected?
Duties for construction products: what falls on each economic operator on the way to the market.
Draws up the declaration of performance and conformity and affixes the CE marking. Gives the product a unique code of its type and, where one exists, a batch or serial number. Eighteen months after the passport act, makes the product passport available. Whoever manufactures with 3D printing carries the same duties.
Places on the market only products that comply with the rules. Much of the evidence sits with a producer outside the EU. So the importer secures the declaration, the documentation and the environmental figures by contract, long before the passport duty. With a supplier request in Transpareo, the producer fills in the fields directly.
Checks that declaration, marking and documentation are present, and keeps them reachable. Selling under its own name or brand makes it the manufacturer. Then it owes everything the manufacturer owes. From 21 September 2027 the new Union Customs Code applies. For distance sales to consumers from outside the EU, the seller or the marketplace is then the importer, depending on the arrangements. That importer has to make sure the construction product meets the product rules customs apply.
Placing a remanufactured product on the market always makes you the manufacturer. A used product does so in certain cases. Reclaimed steel, salvaged brick and re-used facade elements therefore need their paperwork too.
What goes in the DPP for construction products?
Data fields for construction products: the key ones the relevant EU regulation requires.
The regulation merges the old declaration of performance and the declaration of conformity into one document. It states composition, intended use and CE marking. It also names the technical specification the product was assessed against. In the product passport the declaration comes first.
The regulation sets a fixed list of environmental characteristics, from climate to land use. They cover the product’s whole life cycle. They are calculated with free software from the Commission. The characteristics phase in from 2026 to 2032. In Transpareo each one becomes a field of its own with a unit.
Compressive strength, thermal conductivity, fire class and durability are typical essential characteristics. They come from the product’s technical specification. These are the values a planner reads. The passport has to carry them unchanged.
This covers material purity, deconstruction guidance and the potential as a secondary raw material. The passport system sets who may read which information. Deinstallers are on that list by name. They are the real audience for this data.
Downloads
The checklist for construction products as a PDF to print and tick off, and the sample spreadsheet of the Transpareo import to compare with your own product data - all without an account.
Preliminary: the checklist for construction products follows an adopted act whose implementation details are still pending. We update it as soon as new regulatory information is published.
Sample row for construction products, filled in and with every column the import expects.
14 columns, sample values included
Transpareo for construction products
Transpareo is the DPP software for construction product manufacturers. It gives every product an identifier, even without a GTIN. You keep passports per product, batch or item. Fields of their own carry the declaration of performance and conformity, the environmental characteristics and the deconstruction information. Each field has its own visibility.
Data comes in through the web interface, by Excel import or through the API. So your production system stays the source. The sample spreadsheet above shows the columns a construction passport carries.
Every publication is a signed version, and earlier versions stay retrievable. Whoever reads the passport checks the signature with the Transpareo Time Machine in their own browser, without asking us. You export products, components and passports at any time as JSON-LD, CSV, Excel spreadsheet or SQL. The spreadsheets import back.
Frequently asked questions about the DPP for construction products
When does the DPP become mandatory for construction products?
The regulation fixes no date. The Commission first has to set up the passport system with an act of its own. No deadline applies to that. Once the act is in force, two clocks start. After six months the system has to run. After eighteen months manufacturers have to make the passport available. The Commission plans the act for the second quarter of 2027. If the plan holds, the duty applies from late 2028 or 2029. In Transpareo you can create your product passports today.
Does this apply to every construction product?
Not yet. The duties apply to products covered by a harmonised technical specification or a European technical assessment. The new regulation replaces the old standards family by family. The Commission’s working plan sets the order. For many products the passport arrives with the specification of their product family. Specifications under the 2011 regulation do not count for this. Cement, building limes and other hydraulic binders come first. Their standards are planned to become mandatory in the fourth quarter of 2027. For chimneys, other than free-standing ones, the plan names 2028. For doors and windows, flat glass, reinforcing and prestressing steel, thermal insulation and structural timber products it names 2029. Precast concrete and structural metallic products were requested under the old regulation. The plan itself calls all of these years indicative.
Does the passport duty apply to importers too?
Importers have duties of their own. They may place only compliant products on the market. In some cases they count as the manufacturer themselves. That happens when they sell under their own name or brand. It also happens when they change the declared use or claim different characteristics. Private-label building materials are common. So this catches more importers than many expect. Settle the data flow in the supply contract, before the first audit comes. With a supplier request in Transpareo, your producer delivers the data straight into your product passport.
We have no GTIN. How does the identifier work?
That is the normal case in this industry. What is required is a unique code of the product type and, where one exists, a batch or serial number. A GTIN is no part of it. If you have a GTIN, Transpareo turns it into a GS1 Digital Link. If you have none, Transpareo issues a unique identifier of its own. Transpareo produces the QR code either way. Some products cannot carry a code themselves, such as aggregates in bulk. Then the code goes onto a label, the packaging or the accompanying documents. A passport may also be connected to more than one code. More on this in how the DPP works without a GTIN.
Our composition varies between batches. Can the passport handle that?
Yes, and it has to. Cement, concrete and aggregates change from delivery to delivery. That is why the regulation asks for a batch or serial number alongside the type code. In Transpareo you publish the passport per product, batch or item. The QR code on a delivery note then leads to the composition of exactly that batch. That is what makes a later deconstruction audit possible.
Is the passport just the declaration of performance in a new coat?
The passport contains the declaration of performance and more. The regulation lists what a construction passport carries. The declaration of performance and conformity comes first. Then come the product and safety information, the technical documentation, the label and the unique identifiers. The declaration is the core. The passport holds it in a structured, machine-readable form, with rules on who may read what.
Do we have to produce an EPD to EN 15804?
The regulation does not require an EPD. It works with a fixed list of environmental characteristics over the life cycle. They are calculated with free software from the Commission. The regulation mentions the standard EN 15804 only once, in its recitals. There it is a source for that software, with the words “or future applicable standards”. If you already hold an EPD, its data covers most of the list. Many manufacturers keep their figures with a programme operator or in a national building materials database. That data is the practical starting point. For some years the same figures will live in three places, the EPD, the declaration and the passport. Where your own data is missing, European background data applies. The Commission deliberately keeps it conservative. Bringing your own data means declaring the figures of your own plant. In Transpareo the EPD sits as a field of its own beside the figures.
Is this the same passport as the one under the Ecodesign Regulation?
The construction passport is a system of its own, deliberately built on the general product passport. It has to be compatible with the passport of the Ecodesign Regulation. Its rules on identifiers, the registry and the web portal apply to construction products too. The construction act may set different rules. A company that already runs product passports for another product group adapts them. In Transpareo you keep the passports of every product group on one platform.
What can we prepare for the EU registry today?
Your company’s identity verification. Only a verified company can register a passport. Who registers construction products is for their act to set. A company in the EU proves its identity with a qualified electronic seal. A qualified electronic attestation of attributes works as well. The verified status lasts three years at most. It ends earlier if the seal or the attestation expires. Then the verification is repeated. The registry has run since 20 July 2026 and offers a test environment. On registration it checks the data structure and the level of the passport, that is model, batch or item. Whether the values are right remains for market surveillance to check. Today your company makes the entry. A service provider cannot do it for you yet. We expect that to change. Transpareo checks every passport before publication and prepares the details the entry needs.
How does this fit with BIM?
The regulation names Building Information Modelling (BIM) explicitly. The passport system must not compromise working with digital building models. The details are for the construction act to set. In practice your product data has to leave the passport in structured form. A planning model has to be able to take it in, and a PDF cannot do that. An obvious route is for the model to store the passport identifier per component. It then fetches the other values through it when a calculation needs them. They will be needed soon. From 2028 the EU buildings directive requires a life-cycle climate figure for large new buildings. The Commission’s working plan sees the passport as support for this, for digital building logbooks and for BIM. Transpareo makes every passport machine-readable at a permanent address.
Do public buyers require a product passport?
Today no procurement law prescribes one. The values a passport carries count more and more in tenders, though. Contracts covering net-zero technologies come with minimum sustainability requirements. In 2026 the Commission put forward two proposals. Publicly bought steel, cement and aluminium would have to meet carbon requirements. Quality would weigh at least 30 per cent in every award. In Switzerland, Swiss Federal Railways weight the carbon footprint of rails at 25 per cent. A published passport in Transpareo shows the public values at a permanent address. A bid can include them as a link or a QR code.
How long does a construction passport have to stay available?
The construction act sets the exact period. The regulation already sets the frame. The passport system has to be accessible for 25 years after the last product of a type. The company makes the passport available for at least ten years. The passport has to stay available even after an insolvency or a closure. For that, the regulation provides for a back-up system run by the providers. The details follow in the act. Buildings outlive their suppliers. So ask every provider what happens to your passports after a cancellation. With Transpareo they stay reachable through a permanent address. Our provider checklist names more questions worth asking.
Official documents
Legal sources for construction products to read for yourself: what each document is and when you need it.
- Regulation (EU) 2024/3110 (revised Construction Products Regulation)The regulation itself. It governs the construction passport system and the declaration of performance and conformity with its environmental characteristics.
- Regulation (EU) No 305/2011 (the previous CPR)Repealed from 8 January 2026. Some of its provisions run until 8 January 2040. Keep it open as long as your product is assessed under an old harmonised standard.
- First CPR Working Plan for 2026-2029The Commission communication on standardisation under the new regulation. It shows when a technical specification for your product family is likely. It names no date for the passport act.
- Regulation (EU) 2024/1781 (ESPR)The general product passport framework. The construction passport system has to be built on it. The EU registry rests on it too.
- Implementing Regulation (EU) 2026/1778 on the DPP registryThe rules for the EU product passport registry, in force since 6 August 2026. Its scope already names construction products. It sets out the identity verification a company goes through before its first registration.
- Implementing Decision (EU) 2026/1736 on the harmonised DPP standardsNames six harmonised standards for the product passport, EN 18216 and EN 18219 to EN 18223. They cover identifiers, data carriers, data exchange, storage, interfaces and how the systems work together. Their role for the construction passport is for its act to decide.
- Directive (EU) 2024/1275 on the energy performance of buildingsThe EU buildings directive, to be transposed by 29 May 2026. It requires a life-cycle climate figure for new buildings in the energy performance certificate, from 2028 above 1,000 m² and from 2030 for all. The calculation uses the data of the construction products where they exist.
- Regulation (EU) 2024/1735 (Net-Zero Industry Act)The regulation requires minimum sustainability requirements in contracts covering net-zero technologies, works contracts with such installations included. Implementing Regulation (EU) 2026/718 sets the first one. It applies from 30 June 2026, to the blades of wind turbines.
- Directive (EU) 2023/1791 on energy efficiencyGives the public sector an exemplary role. The final energy consumption of public bodies combined falls by at least 1.9 per cent a year. Above the EU thresholds contracting authorities buy energy-efficient.
- Proposal for the Industrial Accelerator ActThe Commission’s proposal of 4 March 2026 (COM(2026) 100). Art. 11 would bind public buyers to low-carbon requirements for steel, cement and aluminium. Cement and aluminium would also have to come from the Union. Parliament and Council are still negotiating.
- Proposal for new EU procurement rulesThe Commission’s proposal of 9 September 2026 (COM(2026) 590). A regulation would replace the procurement directives of 2014. The best price-quality ratio becomes the standard, with at least 30 per cent of the weight on quality.
- DPP page of the European CommissionThe official roadmap with the state of the registry and the acts. It also shows the indicative second quarter of 2027 for construction products. A change of date shows up here first.
Further reading on our blog
Construction products without a GTIN get their passport via batch IDs. How that works for cement, bricks and steel beams.
A pragmatic guide to the carbon footprint methods the ESPR accepts. It compares life-cycle assessment, environmental declarations and system boundaries.
The EU register for Digital Product Passports became law on 16 July 2026. What it asks of you, and what we prepare for you.
Six harmonised DPP norms are set in stone. The target has stopped moving, and we already meet it.
Ready for your construction product passports?
Set up your passports for construction products today. By the time the obligation takes effect, you have long been up and running.