The Construction Products Regulation and Digital Product Passports: What the Industry Needs to Know

The Construction Products Regulation (EU) 2024/3110 — the recast of the original CPR 305/2011 — is one of the most significant pieces of EU internal market legislation for the construction sector in over a decade. Among its many innovations, it introduces a full Digital Product Passport (DPP) framework for construction products, set out in Chapter X (Articles 75–80). In this article, we walk through the legislative timeline, the DPP provisions, the critical role of harmonised standards, and what the Commission's Working Plan tells us about when different product families will actually be affected.

Legislative Timeline

The path from proposal to applicable regulation took nearly four years:

Where the DPP Lives in the CPR — Chapter X

The DPP provisions are concentrated in Chapter X of the regulation, spanning Articles 75 to 80. Unlike the ESPR, which delegates DPP details almost entirely to product-specific delegated acts, the CPR recast builds a substantial DPP framework directly into the regulation text:

• Article 75 — Establishes the DPP system. The Commission is empowered to adopt a delegated act setting out the technical design of the DPP system for construction products. In practice, it is expected that this delegated act will likely be adopted after the CEN/CENELEC JTC24 working groups have published the DPP technical standard — provided the construction sector deems it a suitable standard for its DPP requirements.
• Article 76 — Defines the minimum content that a DPP must contain: the declaration of performance and conformity (DoPC), safety information, relevant technical documentation, labels, and unique product identifiers.
• Articles 77–78 — Set out interoperability requirements, access rights, data security, and protections for trade secrets and confidential business information.
• Article 79 — Establishes the DPP registry: manufacturers must upload unique product identifiers and related data to this EU-level digital registry (shared with ESPR), expected operational in 2026. Article 80 — Provides for a publicly accessible web portal for searching and comparing DPP data, and sets out the operational timeline.

This is a notable design choice: the CPR builds on, and is designed to be interoperable with, the ESPR's horizontal DPP architecture — but it does so through a sector-specific regulation that reflects the particularities of construction products.

When Do DPP Obligations Actually Apply?

This is the central question for the industry — and the answer is more nuanced than a single date. DPP obligations for any product family depend on two conditions being met simultaneously:

1. The product family must be covered by a new harmonised technical specification (HTS) under CPR 2024/3110 — replacing its current standard under CPR 305/2011.
2. The Article 75 delegated act — which sets out the technical design of the DPP for construction products — must be in force. Per Article 75(8), DPP obligations apply 18 months after entry into force of this delegated act. Within that 18-month window, the technical infrastructure (built on the ESPR's horizontal DPP architecture — the EU registry, unique identifier scheme, and web portal) must become operational.

Until both conditions are satisfied, DPP use remains voluntary for that product family. The practical start date is always the later of the two: even if a product family's new harmonised standard is cited in the Official Journal, DPP obligations won't apply until the Article 75 delegated act has been in force long enough for the 18-month lead-in to elapse — and vice versa.

The Path from Preparatory Work to DPP

This is the process that will determine the real-world timeline for construction product DPPs. The CPR's Annex VII defines product families — broad groupings such as precast concrete, doors and windows, thermal insulation, and structural metallic products. Harmonised standards under the old CPR 305/2011 remain valid until they are formally withdrawn and replaced by new harmonised technical specifications (HTS) under CPR 2024/3110. Products migrate to the new regulatory regime family by family, as new standards are developed, adopted, and referenced in the Official Journal — and a DPP becomes mandatory for a given product only once its family has completed this transition and the Article 75 delegated act is in force.

The Commission's Working Plan (COM(2025) 772) tracks six milestones per product family, typically spanning 4.5–5.5 years from start to finish:

The Commission's Table 3 reveals a continuous spectrum of progress across all 37 families. A critical legal nuance: DPP obligations under Chapter X are linked to the Declaration of Performance and Conformity (DoPC), which only applies to products covered by new harmonised technical specifications under CPR 2024/3110. Products still CE-marked under old harmonised standards cited under CPR 305/2011 — such as precast concrete (PCR, currently under EN 13369 etc.) and structural metallic products (SMP, currently under EN 1090-1) — continue using the old Declaration of Performance (DoP) and are not yet subject to DPP obligations. DPP for these families will only apply once new HTS under CPR 2024/3110 replaces their current standards. Based on the Working Plan milestones and typical standardisation timelines, our scenario estimate is ~2030–2031 for these earliest families — but this depends on standardisation requests being adopted on schedule and on CEN/CENELEC meeting delivery deadlines. For families with genuine new standard development under the new CPR (cement, doors and windows, thermal insulation), the scenario estimate is ~2029–2030. Later families without acquis work extend to ~2032–2034. These year-specific estimates are scenario assumptions, not regulatory commitments. Two conditions must converge: (1) the product family's new HTS must be in force, and (2) the Article 75 delegated act must have been adopted and the 18-month lead-in must have elapsed. The delegated act has not yet been adopted; based on the legislative programme, we estimate it will complete its lead-in by approximately 2028–2029, well before most product families' new HTS is ready. If that assumption holds, the harmonised standard is the binding constraint for the vast majority of families.

Two Routes to CE Marking — and Two Paths to DPP

A common misconception is that DPP obligations will activate for an entire product family at once. In practice, the rollout will be uneven within a product family because standardisation requests set deadlines at the level of individual deliverables and standards, not a single family-wide switch date. To understand why, it helps to know the two routes through which construction products reach CE marking today:

Route 1: Harmonised standards (hENs)

The majority of construction products are covered by harmonised European standards (hENs) — product specifications developed by CEN Technical Committees under a Commission mandate and cited in the Official Journal. Products covered by an hEN must be CE marked. Under the new CPR 2024/3110, each existing hEN will eventually be replaced by a new Harmonised Technical Specification (HTS). DPP obligations apply to a product once its specific HTS is in force — but different hENs within the same product family will be revised and adopted at different times. For example, in the Roof Coverings family (ROC), EN 490 (concrete tiles) could receive its new HTS before EN 1304 (clay tiles), meaning DPP for concrete roof tiles would activate before clay roof tiles — even though both belong to the same family.

Route 2: European Assessment Documents (EADs) and European Technical Assessments (ETAs)

When no harmonised standard exists for a product — typically innovative, niche, or novel products — manufacturers can obtain a European Technical Assessment (ETA) via an European Assessment Document (EAD) developed by EOTA. This is the CE marking route for products like green roof kits, FRP reinforcement bars, structural building kits, and many other innovations. Some product families rely entirely on EADs — Building Kits (KAS) has an estimated ~32 EADs and zero harmonised standards. Others use both routes: Roof Coverings (ROC) has approximately 21 hENs alongside ~32 EADs, and Products related to Concrete (CMG) has approximately 16 hENs plus ~19 EADs covering circular economy innovations like steel fibres recovered from end-of-life tyres and municipal waste incinerator bottom ash. (Note: per-family hEN and EAD counts are approximate, based on the nlfnorm.cz harmonised standards database and EOTA's EAD database, mapped to CPR Annex VII product families. Exact counts may vary as the Commission's official lists are updated.)

Under CPR 2024/3110, the EAD/ETA route has its own transition timeline:

• Old EADs (adopted under CPR 305/2011) remain valid for issuing ETAs until 9 January 2031 (five years from the Regulation's entry into force, per Article 95).
• ETAs issued under old EADs remain valid for CE marking until 9 January 2036 (ten years from entry into force).
• New EADs under CPR 2024/3110 must include environmental sustainability requirements (per Article 42): GWP declaration immediately upon adoption, core life cycle assessment indicators by 2029, and full LCA by 2031. (Note: the separate manufacturer declaration obligations under Article 15 follow a slightly later schedule — GWP from 8 January 2026, core indicators from 9 January 2030, all indicators from 9 January 2032.)
• New EADs have a 10-year validity period. ETAs issued under new EADs have no expiry.

DPP obligations for EAD/ETA products follow a similar logic: products placed on the market under new ETAs (issued against EADs adopted under CPR 2024/3110) will use the Declaration of Performance and Conformity (DoPC) and therefore fall under Chapter X DPP obligations. Products still operating under old ETAs (valid until 9 January 2036) are not subject to DPP — analogous to how products under old hENs use the old DoP and remain outside the DPP system.

The innovator's paradox

This two-route structure creates a counterintuitive outcome that the industry has not yet widely recognised: innovative products using the EAD/ETA route could face DPP obligations before mainstream products in the same family that are covered by harmonised standards — provided the Article 75 delegated act is in force and the manufacturer is using a new ETA issued under a CPR 2024/3110 EAD. Here is why.

In the new CPR architecture, the DoPC is a core element of what the DPP must contain, and the Declaration of Performance and Conformity (DoPC) is the key mechanism linking both routes to DPP obligations. Any product that issues a DoPC under CPR 2024/3110 falls within the scope of Chapter X. Both routes lead to a DoPC: a product covered by a new HTS issues one, and a product with a new ETA (against a CPR 2024/3110 EAD) issues one. Limited exemptions exist under Article 14 (e.g., individually manufactured products), but for mass-market construction products the DoPC — and therefore DPP — is the standard path.

The paradox arises from timing. EOTA can adopt a new EAD in roughly 12–18 months — the process involves a single Technical Assessment Body drafting the document and EOTA's technical board validating it. By contrast, developing a new HTS through CEN/CENELEC typically takes 36 months of TC work alone, preceded by 12+ months of preparatory milestones and followed by a coexistence period. This means a manufacturer of, say, an innovative green roof kit could obtain a new ETA under a CPR 2024/3110 EAD and be required to issue a DoPC — triggering DPP obligations — years before the mainstream clay or concrete roof tiles in the same family (ROC) have their harmonised standard replaced.

This is not a theoretical edge case. It affects every product family that has both hENs and EADs — which is the majority of the 37 families. Whether a product reaches CE marking through the hEN route or the EAD route, the transition timing to a DoPC — and therefore to DPP obligations — differs by route. The practical effect is that there is no way to indefinitely defer DPP: once a manufacturer's product falls under a new HTS or a new ETA under CPR 2024/3110, the DoPC requirement and the associated DPP obligation follow, subject to the Article 75 delegated act being in force and the 18-month lead-in having elapsed.

What the family-level estimates really mean

The DPP date estimates shown on each product family card below represent the envelope — the approximate date by which the last major products within that family are expected to be subject to DPP. In practice, individual products within a family will transition at different times depending on when their specific hEN is replaced by a new HTS, or when their EAD is adopted under the new CPR. Early products within a "~2032–2033" family could realistically see DPP obligations by 2030–2031 if their particular standard is prioritised in the standardisation request.

The Commission's Working Plan (2026–2029)

In late 2025, the Commission published its Working Plan (COM(2025) 772) for the rollout of harmonised technical specifications under the recast CPR. Its Table 3 provides granular milestone dates for all 37 product families — from product scope definition through to the delegated act making each standard mandatory.

The 37 product families below are ordered by their estimated DPP obligation date — earliest first — based on the readiness of existing standards and the work of CEN/CENELEC technical committees. The DPP obligation estimates are derived from Table 3 milestone dates plus the coexistence period and the Article 75 delegated act timeline. The numbers (e.g. #1, #20) refer to the product family numbers assigned in the CPR's Annex VII — they are regulatory reference numbers, not a priority ranking:

Disclaimer: The CPR regulatory landscape is dynamic and at times opaque, making it difficult to be completely up to date or accurate. The information on this page is provided for informational purposes only and should not be considered legal advice. For critical decision-making, we recommend validating this information with legal experts, sector organisations, or the European Commission. If you see anything that should be improved or updated, please let us know through the form below.

Precast Concrete Products Annex VII #1 · PCR CEN/TC 229

Structural Metallic Products Annex VII #20 · SMP CEN/TC 135

Cement & Building Limes Annex VII #15 · CEM CEN/TC 51

Chimneys & Flues Annex VII #6 · CHI CEN/TC 166

Road Construction Annex VII #23 · RCP CEN/TC 227

Floorings Annex VII #19 · FLO CEN/TC 134

Building Kits & Prefab Annex VII #34 · KAS EOTA (EADs)

Attached Ladders Annex VII #36 · LAD

Reinforcing Steel Annex VII #16 · RPS CEN/TC 459/SC 4

Doors, Windows & Gates Annex VII #2 · DWS CEN/TC 33

Thermal Insulation Annex VII #4 · TIP CEN/TC 88

Flat Glass Products Annex VII #30 · GLA CEN/TC 129

Structural Timber Annex VII #13 · STP CEN/TC 124

Fixed Fire-Fighting Annex VII #10 · FFF CEN/TC 191

Wall & Ceiling Finishes Annex VII #21 · WCF CEN/TC 128

Gypsum Products Annex VII #7 · GYP CEN/TC 241

Structural Bearings Annex VII #5 · SBE CEN/TC 167

Space Heating Annex VII #27 · SHA CEN/TC 130

Roof Coverings Annex VII #22 · ROC CEN/TC 128

Circulation Fixtures Annex VII #12 · CIF CEN/TC 226

Concrete & Mortar Annex VII #26 · CMG CEN/TC 104

Aggregates Annex VII #24 · AGG CEN/TC 154

Curtain Walling Annex VII #9 · CWP CEN/TC 33 WG 6

Construction Adhesives Annex VII #25 · ADH CEN/TC 193

Sealants for Joints Annex VII #32 · SEA CEN/TC 349

Fire Protection Annex VII #35 · FPP CEN/TC 127

Masonry Products Annex VII #17 · MAS CEN/TC 125

Waste Water Engineering Annex VII #18 · WWD CEN/TC 165

Fixings Annex VII #33 · FIX EOTA (ETAs)

Membranes Annex VII #3 · MEM CEN/TC 254

Geotextiles Annex VII #8 · GEO CEN/TC 189

Sanitary Appliances Annex VII #11 · SAP CEN/TC 163

Pipes & Tanks Annex VII #28 · PTA CEN/TC 155

Cables & Wires Annex VII #31 · CAB CLC/TC 20

Wood Based Panels Annex VII #14 · WBP CEN/TC 112

Drinking Water Products Annex VII #29 · DWP

Decorative Paints New family · DPW CEN/TC 139

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Per-standard DPP timeline

What the DPP Must Contain

Article 76 specifies the minimum information that must be accessible through a construction product's DPP:

Interoperability and Open Standards

Articles 77 and 78 contain unusually explicit requirements for the DPP's technical architecture. The regulation mandates:

• Open standards — data must be structured in open, machine-readable formats.
• No vendor lock-in — the DPP system must not tie manufacturers or other economic operators to proprietary platforms.
• Interoperability — the system must work across different software environments and be compatible with existing digital tools used in the construction sector, including Building Information Modelling (BIM) systems.
• Data security and trade secrets — access controls must protect confidential business information while ensuring that regulators and market surveillance authorities can access the data they need.

The emphasis on BIM compatibility is distinctive to the CPR and reflects the construction sector's existing digital infrastructure. It signals that the Commission sees the DPP not as a standalone compliance tool, but as a layer that integrates with how the industry already manages product data.

What Should the Industry Do Now?

Despite the uncertainty around exact dates, the direction is clear. Manufacturers and other economic operators in the construction sector should:

• Map your products to the working plan. Identify which Annex VII product families your products fall under and check where those families sit in the Commission's rollout timeline. Our CPR DPP Tracker can help →
• Start collecting and structuring product data. The DPP will require declarations of performance, safety information, technical documentation, and unique identifiers. Much of this data already exists but is often fragmented across different systems and formats.
• Engage with CEN/CENELEC. If your product family's standardisation request has been adopted or is in preparation, the standards development process is already underway. Industry input — particularly from SMEs — is critical to ensuring the resulting specifications are both ambitious and workable.
• Build DPP-ready data infrastructure. The regulation's emphasis on open standards, machine-readable formats, and BIM compatibility means that proprietary, siloed product data systems will not meet the requirements. Start investing in interoperable digital product data now.

The CPR recast represents a generational shift in how construction products are documented, tracked, and verified across the EU market. The DPP is not an add-on — it is a core part of the new regulatory architecture. Getting ahead of it is not just good compliance; it is a competitive advantage.