Digital Product Passport for construction products

Construction products are the main exception to the ESPR rule. Their Digital Product Passport comes not from ESPR but from the recast Construction Products Regulation — CPR, Regulation (EU) 2024/3110 — which entered into force in January 2025. The two regimes are designed to interlock, but for construction products the CPR is the one that governs.

Bottom line: if you place construction products on the EU market, watch the CPR, not ESPR. The CPR introduces its own Digital Product Passport, tied to the Declaration of Performance and CE marking, phasing in through implementing acts.

Which law applies

ESPR explicitly steps back where the CPR covers a product. Construction products — cement, structural steel, insulation, windows and the rest — take their passport obligations from the recast CPR (EU 2024/3110). The CPR passport builds on the existing Declaration of Performance (DoP) and CE marking that construction products already require, rather than starting from scratch.

What the construction DPP carries

Expect the DoP and CE data, essential-characteristics and performance values, material composition and content of hazardous substances, and environmental data including the product's carbon footprint and an environmental product declaration (EPD) where available, plus reuse, recycling and safe-disposal information.

Who is responsible

The manufacturer placing the construction product on the EU market draws up the passport, as they already draw up the Declaration of Performance. For products made outside the EU, the importer or authorised representative carries the duty. As with ESPR, the obligation cannot be delegated away — a platform can produce and file the passport, but the economic operator remains accountable.

Timeline

The recast CPR entered into force in January 2025. Its Digital Product Passport, technical requirements and product-specific rules phase in over the following years through delegated and implementing acts and harmonised standards — a longer, staged transition than the ESPR groups. The direction is fixed even though individual product dates are still being set.

How to prepare

The groundwork is the data you already generate for the DoP and CE marking, plus environmental data (EPDs, carbon footprint) and substance information. Structuring that now — and choosing a passport system that can carry it to the registry and host it long-term — is the low-risk path. PassPer builds the passport from your existing DoP, test reports and EPDs, and handles the carrier, filing and hosting.

Frequently asked questions

Do construction products need a Digital Product Passport?

Yes, but under the recast Construction Products Regulation (EU 2024/3110), not ESPR. The CPR introduces its own passport, tied to the Declaration of Performance and CE marking.

Is the construction DPP part of ESPR?

No. ESPR steps back where the CPR applies. Construction products take their passport obligations from the CPR, which is designed to interlock with the wider DPP system.

When does the construction products DPP apply?

The recast CPR entered into force in January 2025; its passport and product-specific rules phase in over the following years through implementing acts and harmonised standards.

Who draws up the construction DPP?

The manufacturer placing the product on the EU market — or, for imported products, the importer or authorised representative — as with the existing Declaration of Performance.

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