The Digital Product Passport is now enforceable infrastructure
The EU Construction Products Regulation 2024/3110 marks a decisive shift in how product compliance is structured in the European Union. The Digital Product Passport (DPP) is no longer a future-facing policy idea. It is embedded in EU law through horizontal and sector-specific legislation, including CPR 2024, and is positioned as a standardized compliance interface across regulated product categories.
The core purpose of the DPP is clear: to make structured product information accessible across the value chain, strengthen regulatory compliance, improve sustainability reporting, and reinforce market surveillance. For construction products, 2026 represents the beginning of a structured implementation phase.
Understanding this regulation now is not about theory. It is about preparing for operational change.
What is Regulation (EU) 2024/3110?
Regulation (EU) 2024/3110, adopted on 27 November 2024, lays down harmonised rules for the marketing of construction products and repeals Regulation (EU) No 305/2011. Commonly referred to as CPR 2024, it modernises and recasts the EU framework governing construction products placed on the EU market.
While it replaces the previous regime, it preserves transitional continuity where necessary. The European Commission has described CPR 2024 as a major step toward digitalising the construction ecosystem.
A central element of that digitalisation is the construction Digital Product Passport, designed to carry regulated information such as:
- Declarations of performance
- Declarations of conformity
- Safety information
- Instructions for use
The legal message is twofold:
- The Digital Product Passport now exists as a matter of EU law and is moving toward becoming a standard compliance interface across regulated sectors.
- The detailed obligations will be staged through Commission delegated and implementing acts, which define datasets, access rules, technical standards, and mandatory timelines.
The regulation establishes the structure. The Commission will determine the operational details.
The EU DPP architecture under the ESPR
The horizontal legal backbone of the Digital Product Passport is Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR).
The ESPR introduces the DPP as a core mechanism to support sustainable products through standardized, shareable information. However, it operates as framework legislation. It defines the governance structure and legal architecture but leaves product-specific obligations to be specified progressively through subsequent Commission measures.
This “framework first, specificity next” model is deliberate.
Under the ESPR, DPP requirements become operational only when the Commission adopts delegated and implementing acts for a specific product group. These acts determine:
- What information must be included in the passport
- Which economic operators are responsible for providing it
- How access rights are structured
- What interoperability and technical standards apply
In practical terms, compliance is not triggered simply because the ESPR exists. It is triggered when the Commission activates product-group-specific rules that make the passport enforceable for that category.
When does CPR 2024 apply and why 2026 matters
CPR 2024 entered into force on 7 January 2025 and became generally applicable on 8 January 2026.
Its application is staged. Certain structural provisions apply earlier, while enforcement-related elements, including penalties under Article 96, apply later. This sequencing confirms that from January 2026, construction products are among the early sectors being reorganised around digital information flows.
The 2026 milestone is therefore not symbolic. It marks:
- The start of general applicability of the new CPR framework
- The beginning of implementation cycles driven by delegated and implementing acts
- The convergence of technical specifications and market surveillance expectations
In December 2025, the Commission published the First CPR Working Plan for 2026–2029. The document explicitly identifies the Digital Product Passport as a central pillar of the new CPR system and outlines the progressive development of harmonised technical specifications and compliance infrastructure.
For manufacturers and supply chain actors, this signals that regulatory implementation is now in motion.
The construction Digital Product Passport under CPR 2024
CPR 2024 does not treat the DPP as optional supplementary information. It establishes a dedicated legal basis for a construction-specific DPP system.
Under Chapter X of CPR 2024, the Commission is empowered to adopt delegated acts to create and govern the “construction digital product passport system.” This includes defining:
- Governance rules
- Access rights design
- Operational conditions
These delegated acts are the regulatory bridge between legislative intent and enforceable compliance.
The CPR’s logic is clear: the construction DPP will consolidate and transmit regulated product information in a structured, interoperable format across the value chain. It is designed to support sustainability assessments and performance evaluation at both product and building level.
The Commission’s communications align this with the broader ESPR objective of standardized product data serving sustainability and compliance goals.
In short:
- CPR 2024 embeds the DPP in construction product law.
- Delegated acts will define its operational dataset and mandatory status.
- The moment of obligation will depend on product-group-specific activation.
A broader shift toward passport-based compliance in the EU
Construction products are not an isolated case.
The EU is moving toward a passport-based compliance model across multiple regulated sectors. A clear precedent is the Batteries Regulation (EU) 2023/1542, which requires certain batteries placed on the EU market to carry an electronic “battery passport” from 18 February 2027.
This demonstrates that the EU’s approach is consistent:
- Establish the legal architecture.
- Define sector-specific requirements.
- Stage applicability with clear enforcement dates.
The Digital Product Passport is becoming compliance infrastructure, not optional transparency tooling.
What economic operators should do now
For manufacturers, authorised representatives, importers, distributors, and other supply chain actors, the question is no longer whether the DPP will apply.
The real questions are:
- When will the Commission adopt product-group rules relevant to your portfolio?
- What dataset will be required?
- How will access rights be structured?
- What interoperability standards will apply?
Companies active in the construction products value chain should treat 2026 as the start of sustained implementation.
Preparation should include:
- Mapping required product data
- Identifying declarations of performance and conformity datasets
- Designing governance and access control structures
- Ensuring systems can deliver structured, machine-readable information
- Aligning internal digital architecture to passport-ready formats
One common mistake is waiting for the final delegated act before preparing. By the time technical specifications are finalised, companies without structured data architecture will face compressed implementation timelines.
Early preparation reduces compliance risk.
From policy discussion to enforceable digital infrastructure
The EU has moved from conceptual debate to enforceable regulatory infrastructure.
The Digital Product Passport is established in law through the ESPR and reinforced through sectoral legislation such as the EU Construction Products Regulation 2024/3110. CPR 2024 integrates the construction DPP directly into product compliance architecture.
What remains is staged operationalisation through delegated and implementing acts.
For the construction sector, 2026 marks the beginning of a structured implementation phase. Companies that treat the DPP as a future administrative burden may struggle. Those that treat it as a core element of digital compliance architecture will be positioned to adapt as product-group requirements crystallise.
The transition is not hypothetical. It is regulatory, staged, and underway.
