Construction products will need a Digital Product Passport under the Construction Products Regulation (CPR), Regulation (EU) 2024/3110, but not yet. The duty starts 18 months after the Commission’s passport delegated act enters into force, and on 15 October 2026 no such act or draft exists. It also reaches only product families covered by harmonised specifications under the 2024 Regulation.
What decides the start date?
The first gate is in Articles 22(7) and 80(1). The construction passport system must work six months after the Article 75(1) delegated act enters into force, and the manufacturer’s duty applies after 18 months. Manufacturers may use the system voluntarily in between.
The second gate is in Article 95(9). Chapter III duties, the passport among them, apply to a product family one year after the Commission makes a harmonised standard mandatory for it or adopts the equivalent implementing act. Products still under standards or assessment documents from the 2011 Regulation get no passport.
When could a cement passport be due?
Example: the Commission’s indicative DPP timeline places the passport act in Q2 2027. In its CPR working plan, cement is the first family whose new standard is due to become mandatory under the 2024 Regulation, in Q4 2027. Every date in the plan is indicative. Assume the passport act enters into force on 1 October 2027: the duty then applies from 1 April 2029. Assume the act making the cement standard mandatory is adopted on 31 December 2027 and sets no later date: 2024 Regulation duties for cement then apply from 31 December 2028. A cement passport would be due from 1 April 2029, the later of the two.
What will the construction passport carry?
The passport holds, under Article 76(2):
- the declaration of performance and conformity (DoPC)
- general product information, instructions for use and safety information
- the technical documentation and the label
- unique identifiers
- documentation required by other Union law
- data carriers of key parts that have their own passport
Once the duty applies, Article 91(2) requires economic operators to meet the information duties for those documents by providing the passport. The DoPC, general product information, instructions for use and safety information still come on paper, free, if the end user asks at purchase. Products exempt under Article 14 need no passport. The system must stay accessible for 25 years after the last product of a type is placed on the market, and each passport for at least 10 years.
Registry and border
Identifiers and the EU registry follow Articles 12 and 13 of the Ecodesign for Sustainable Products Regulation (ESPR), unless the passport act sets other rules. Unlike toys and detergents, construction products face no automatic registry check at EU customs, though customs can still suspend release under Regulation (EU) 2019/1020 where required documents are missing. A manufacturer outside the EU appoints a single authorised representative, who verifies the passport documentation under Article 23.
Sources: Regulation (EU) 2024/3110 (CPR), CPR Working Plan 2026-2029, COM(2025) 772, European Commission, CE marking and DoPC, European Commission, Digital Product Passport
With a manufacturer’s current DoPC and technical file, GreenSutra’s Digital Product Passport solutions list what the passport will need. The DPP guide tracks the CPR dates as the two acts arrive.