Passport checklist for construction products

Does this apply to your product?

Tick what holds for your product. The first statement is the gate that decides whether the economic operator duties reach you at all, and it is the one most often missed. The articles in brackets point to Regulation (EU) 2024/3110.

• The product is covered by a harmonised technical specification, or it is CE-marked on the basis of a European technical assessment: only then do the obligations of this chapter apply to you at all (Art. 20(1)).
• It is a construction product, meaning a formed or formless physical item, 3D-printed products included, or a kit, placed on the market for permanent incorporation into construction works (Art. 3(1)).
• You place it on the EU market as its manufacturer, including where you manufacture it by 3D printing, in which case the same duties attach (Art. 22(1)).
• You place it under your own name or trade mark, modify it, declare a different use, claim characteristics deviating from the manufacturer’s, or place a used or remanufactured product on the market: each makes you the manufacturer in law (Art. 26(1) and (2)).
• It is individually manufactured or custom-made under the conditions of Art. 14, or made for heritage conservation: then no declaration is drawn up, and no passport is required either (Art. 14, Art. 76(4)).

What already applies today

The passport has no date, but the paperwork it will carry mostly does. Everything below comes from Regulation (EU) 2024/3110 and is what the passport will later hold. It starts binding a product family one year after the implementing act that makes its harmonised technical specification mandatory, so check that date for your family first (Art. 95(9)). Tick off what is already in place.

• Determine the product type and have the performance assessed against the mandatory essential characteristics and those you intend to declare (Art. 22(1)).
• Draw up the declaration of performance and conformity on the model of Annex V, which merges the old performance and conformity declarations into one document (Art. 13, Art. 15(1)).
• Declare the environmental performance over the life cycle for the Annex II characteristics, calculated with the latest version of the software the Commission provides free of charge; updates become mandatory one year after publication (Art. 15(2)).
• Cover Annex II points (a) to (d) since 8 January 2026, points (e) to (m) from 9 January 2030 and points (n) to (s) from 9 January 2032 (Art. 15(3)).
• Provide the REACH information of Article 31 or, as the case may be, Article 33 together with the declaration (Art. 15(6)).
• Draw up the technical documentation naming the declared use, the elements proving performance and conformity, the assessment system of Annex IX and the environmental calculation (Art. 22(3)).
• Affix the CE marking, which may only go on a product for which the declaration has been drawn up, and put it on key parts too (Art. 17, Art. 22(2)).
• Give the product a manufacturer-specific unique identification code of the product type and, where available, a batch or serial number, visible and legible to users (Art. 22(5)).
• Label a product “Only for professional use” where expertise is needed to use it, and show that label before the sales contract binds the customer, distance selling included (Art. 22(5)).
• Accompany the product with the general product information, instructions for use and safety information of Annex IV, in the language the member state determines (Art. 22(6)).
• Keep every document and item of information of this chapter at the disposal of national authorities for ten years, and present it within ten days of a request; the duty falls away for what is available through the passport (Art. 20(4)).
• Identify on request who supplied you and whom you supplied, with contact details and tax and company registration numbers (Art. 20(3)).

What the passport will carry

Art. 76(2)(a) already lists the content, which is why the passport is less a new document than a container for documents you produce anyway. Under each item you find its place in the regulation.

• The declaration of performance and conformity, including the REACH information of Art. 15(6) and the documentation provided together with it under Annex V Art. 76(2)(a)(i)
• The general product information, instructions for use and safety information of Annex IV Art. 76(2)(a)(ii)
• The technical documentation, including the sections required where a simplified procedure was used Art. 76(2)(a)(iii)
• The label, where environmental sustainability labelling has been required for your product family Art. 76(2)(a)(iv)
• The unique identifiers issued under the identifier rules the system adopts Art. 76(2)(a)(v)
• The documentation required under other Union law applicable to the product Art. 76(2)(a)(vi)
• The data carriers of key parts for which a passport of their own is available Art. 76(2)(a)(vii)
• Nothing at all, where the product is exempt from drawing up a declaration under Art. 14 Art. 76(4)

What the delegated act still has to settle

This is the part no supplier can promise you today, and the part worth reading before you sign a contract that assumes any of it. Art. 75(2) lists what the act has to determine; every point below is an open question until it is adopted.

• How the system is built on the passport of the Ecodesign Regulation without compromising interoperability with building information modelling Art. 75(2)(a)
• Which functionalities the system needs in order to implement and manage the passports of Art. 76 Art. 75(2)(b)
• Which actors, economic operators, clients, deinstallers, users and authorities among them, may access which information, weighed against intellectual property, sensitive commercial information and the safety of construction works Art. 75(2)(c)
• Which actors may introduce or update information, and which information they may touch Art. 75(2)(d)
• The detailed arrangements for updating the passport of an existing product Art. 75(2)(e)
• The procedures keeping passports available after insolvency, liquidation or cessation of activity, including a back-up system run by service providers Art. 75(2)(f)
• The requirements for passport service providers, and a certification scheme to verify them if one is needed Art. 75(2)(g)
• Whether the identifier, data carrier, digital credential and registry rules of the Ecodesign Regulation apply as they stand or in a more detailed or alternative form Art. 75(2)(h), Art. 79
• The retention frame: the system accessible for twenty-five years after the last product of the type was placed on the market, and the operator making the passport available for at least ten Art. 75(2)(i)
• How the information needed for reuse and remanufacturing stays available Art. 75(2)(j)

How the passport will have to be built

Articles 77 and 78 already fix the properties of the passport as a system, independently of the delegated act. They are the questions to put to any provider now, because a system that cannot do these things will not become compliant later.

• Connected through one or more data carriers to a persistent unique identification code of the product type Art. 77(1)(a)
• Reached through the data carrier that accompanies the CE marking Art. 77(1)(b), Art. 18(2)(g)
• Corresponding to the product type and its unique identification code, and accessible free of charge to economic operators, clients, users and authorities Art. 76(2)(d) and (e)
• Based on open standards, machine-readable, structured, searchable and transferable without vendor lock-in, with a narrow technical exemption for the attached declaration and technical documentation Art. 77(1)(d)
• Graded by levels of access, with trade secrets and intellectual property protected Art. 76(2)(f), Art. 78(f) and (g)
• Fully interoperable with other passports in technical, semantic and organisational terms Art. 78(a)
• Available after insolvency, liquidation or cessation of activity in the union, through the back-up system the act will require Art. 78(e)
• Stored and processed by operators or service providers that may not sell or reuse the data beyond the service Art. 78(d)
• Authentic, reliable and tamper-evident, designed and operated so that fraud is avoided Art. 78(h) and (i)
• Holding no personal data of the end user without explicit consent Art. 77(1)(e)

Deadlines

The dates that matter for a construction product, taken from the application, transitional and passport articles of the regulation. Everything from the delegated act onwards is relative rather than fixed, and is marked as such.

1. 7 January 2025
   The revised regulation enters into force

   Regulation (EU) 2024/3110 of 27 November 2024 enters into force on the twentieth day after its publication in the Official Journal of 18 December 2024. A first block applies at once, including the definitions, the standardisation rules and Annexes I, II, III, IV, VII, IX and X (Art. 96).

2. 8 January 2026
   The new regulation applies

   Regulation (EU) No 305/2011 is repealed from this day, except a listed set of provisions that survive until 8 January 2040 (Art. 94). From here the declaration of performance and conformity has to cover the environmental essential characteristics of Annex II points (a) to (d) (Art. 15(3)(a)).

3. 20 July 2026
   The EU passport registry is operating

   The central registry the Ecodesign Regulation set up is in operation, with Implementing Regulation (EU) 2026/1778 governing it. Its scope already names construction products covered by Art. 76 of this regulation, so the registry layer exists before the construction system does.

4. 8 December 2026
   Member states notify their penalties

   By this day the member states notify the Commission of the rules on penalties and the measures implementing them. The penalties have to be effective, proportionate and dissuasive; the amounts are national (Art. 92).

5. 8 January 2027
   Penalties apply

   Article 92 takes effect (Art. 96). What is uniform across the union is not the amount but the consequence, because market surveillance can stop a product being made available.

6. Indicatively second quarter of 2027
   The passport delegated act is expected

   The Commission's own product passport timeline places the delegated act for construction products in this quarter and marks the timeline as indicative. The regulation itself fixes no date - Art. 75(1) only says that the Commission shall adopt it.

7. Six months after the act
   The system has to be operational

   Six months after the delegated act enters into force, the construction passport system has to be fully operational and fulfilling its objectives, including the functionalities of Art. 76 (Art. 80(1)). Manufacturers may use it voluntarily before that.

8. Eighteen months after the act
   The manufacturer duty applies

   Eighteen months after the same act enters into force, manufacturers make the passport available through the construction passport system, connected to the data carrier of Art. 18(2)(g) (Art. 22(7), Art. 80(1)). This is the only clock that turns the passport into an obligation.

9. 9 January 2030
   More environmental characteristics are declared

   Points (e) to (m) of Annex II join the declaration of performance and conformity, and points (n) to (s) follow on 9 January 2032 (Art. 15(3)). By then the declaration covers the full environmental profile, from climate change effects to land use related impacts.

10. 8 January 2040
    The old regulation finally goes

    The provisions of Regulation (EU) No 305/2011 that survived 2026 are repealed (Art. 94). Until then two regimes sit side by side, which is why a product's paperwork can look inconsistent for years without anyone being wrong.

Sources

The documents this checklist is drawn from, and what each one is good for.

How to prepare

Six steps in the order they pay off. None of them depends on the delegated act, which is the point of doing them now.

1. Work the declaration, not the passport: the declaration of performance and conformity is the passport’s first item and it is already due. Getting it right, on the Annex V model and with the Annex II characteristics, is most of the preparation.
2. Set up the environmental calculation: Annex II points (a) to (d) are due since January 2026, and the Commission’s software updates become mandatory a year after publication. Diarise the update, because a declaration calculated on a superseded version stops being current.
3. Expose the product type code and the batch number: Art. 22(5) wants a manufacturer-specific code of the product type plus a batch or serial number. Most production systems have never had to publish those outside the plant, and that is the real integration work.
4. Decide the level per product family: cement, concrete and aggregates vary between deliveries, so a passport pinned to a product type is not enough on its own. Settle now which families you will publish per batch.
5. Pilot with a handful of product types: Register for free, start from the construction products import template and build a few real types with their declarations and environmental figures attached. Fields the act has not settled stay empty without blocking anything.
6. Ask providers the Art. 75(2) questions: access levels, update rights, back-up after insolvency and the twenty-five-year horizon are the four the act will decide. Our provider checklist turns them into questions you can put in writing.