The revised EU Construction Products Regulation has applied since 8 January 2026, and the EU Digital Product Passport Registry became operational in July 2026.

Neither development means that every construction product already needs a Digital Product Passport.

The new Regulation creates the legal framework for Construction Digital Product Passports, but the obligation will be introduced progressively. A passport will only become mandatory once the European Commission has established the construction-specific DPP system and the relevant product is regulated under the new CPR framework.

For manufacturers and importers, the immediate task is therefore to identify when their particular product family moves into the new system.

What does the new Construction Products Regulation change?

Regulation (EU) 2024/3110 replaces the previous Construction Products Regulation and expands the information that may be required for products placed on the EU market.

The framework continues to use harmonised technical specifications to create a common method for assessing and declaring product performance. It also introduces stronger requirements relating to environmental sustainability, product information, traceability and circularity.

A central element is the future Declaration of Performance and Conformity. This combines information on a product’s declared performance with confirmation that it meets the applicable product requirements.

The Construction Digital Product Passport will eventually provide digital access to this information and other documents connected with the product.

Is a Construction DPP already mandatory?

Not as a general rule.

The European Commission must first establish the Construction Digital Product Passport system through a delegated act. That act will define the detailed technical and operational rules, including how the construction system interacts with the wider EU DPP architecture.

The Commission’s first CPR Working Plan confirms that construction products regulated by new harmonised technical specifications or new European Assessment Documents will receive a DPP once the system is operational and has been made mandatory.

This means the obligation depends on two developments:

1. the adoption of the delegated act establishing the Construction DPP system; and
2. the transition of the relevant product family into the new CPR framework.

The fact that the Regulation already applies does not remove these additional steps.

What does the live EU DPP Registry change?

The EU Digital Product Passport Registry became operational on 20 July 2026.

It provides the central infrastructure through which unique product identifiers and selected passport metadata can be registered. The detailed product information itself remains decentralised and is managed by the responsible economic operator or a DPP service provider.

The Registry has been designed to support several product groups, including construction products. Its technical ability to receive construction DPP registrations does not create an independent legal obligation to register them.

The first specific DPP deadline currently concerns certain large batteries from 18 February 2027. Construction products will follow their own implementation process under the CPR.

A live registry should therefore be understood as available infrastructure, not as evidence that every sector-specific obligation has started.

Will every construction product become subject to the new system at the same time?

No.

The Commission is updating the technical framework product family by product family. The first CPR Working Plan covers the period from 2026 to 2029 and sets out indicative priorities for developing new harmonised technical specifications.

The work includes product families such as cement, structural metallic products, reinforcement steel, doors and windows, thermal insulation, glass products and precast concrete.

Each product family has its own technical work, standardisation requests and expected delivery schedule. The dates in the Working Plan are indicative and do not represent one common DPP deadline for the entire construction sector.

A manufacturer of insulation products may therefore move into the new framework at a different time from a manufacturer of windows, cement or structural components.

What happens to existing harmonised standards?

The new CPR does not replace all existing standards and CE-marking processes at once.

Many products continue to be assessed and CE-marked under harmonised standards or European Assessment Documents connected with the previous Regulation. These remain relevant during the transition until new technical specifications become mandatory for the respective product family.

When a new mandatory specification under the revised CPR takes effect, it will become the basis for the applicable performance and conformity requirements. The corresponding references under the previous framework will then be withdrawn through the formal transition process.

This staged approach matters because the applicable documentation depends on the technical route currently governing the product.

A product that is still placed on the market under the previous CPR framework does not automatically require the complete documentation or DPP planned under the new system.

What will the Construction Digital Product Passport contain?

The passport is intended to bring together the main regulatory and technical information connected with a construction product.

Depending on the applicable product rules, this may include the Declaration of Performance and Conformity, general product information, instructions for use, safety information, technical documentation and applicable labels.

Information on essential characteristics and materials is also expected to support the safe use, maintenance, repair, reuse, recycling and final disposal of the product.

The exact content will not necessarily be identical for every construction product. It will depend on the relevant harmonised technical specification, European Assessment Document and any product requirements adopted for the product family.

The passport may also need to remain compatible with Building Information Modelling and other digital systems used across the construction sector.

Does the DPP replace CE marking?

No.

The CE marking and the Digital Product Passport perform different functions.

CE marking shows that the manufacturer has assessed the product under the applicable harmonised framework and accepts responsibility for its declared performance and conformity.

The DPP provides digital access to the information and documentation required for the product. It can support verification and traceability, but it does not replace the underlying assessment or the manufacturer’s legal responsibility.

Once a Construction DPP is required, the data carrier associated with it may provide access to the CE marking and the Declaration of Performance and Conformity. The legal requirements behind those documents will continue to apply.

Who will be responsible for creating the passport?

The manufacturer will generally be responsible for creating and maintaining the DPP for a product covered by the requirement.

Importers and distributors will need to verify that the relevant manufacturer obligations have been met before making the product available on the EU market. They may also acquire additional responsibilities where they sell a product under their own name or trademark or modify it in a way that affects compliance.

The legal responsibility should therefore be assessed separately from the technical hosting of the passport.

A manufacturer may use an external DPP service provider to store or manage product data, but outsourcing the technical process does not transfer the manufacturer’s regulatory responsibility.

Are innovative products treated differently?

Construction products not covered by a harmonised standard may use the European Technical Assessment route.

European Assessment Documents developed under the previous CPR can continue to support European Technical Assessments during the defined transition period. Products relying on those documents do not automatically move into the new DPP system in 2026.

New European Assessment Documents developed under the revised CPR will form part of the future framework. Products regulated through these new documents will also require a DPP once the system is operational and the requirement has been made mandatory.

Manufacturers using the voluntary assessment route should therefore check which generation of European Assessment Document applies to their product.

What should construction-product companies follow now?

Manufacturers and importers do not need to create passports for every product merely because the Registry is available.

They should instead follow four developments:

• the delegated act establishing the Construction DPP system;
• the CPR Working Plan and the progress of the relevant product family;
• new harmonised technical specifications or European Assessment Documents;
• the date on which the new requirements become mandatory for the product.

Companies can also review whether their current product data is sufficiently structured to support future digital use.

This does not require predicting the final passport format. It means ensuring that declarations, technical documentation, product identifiers, material information and safety instructions can be connected reliably to the correct product.

The current position

The legal framework for Construction Digital Product Passports is in place, and the technical EU Registry is operational.

The general obligation is not.

Construction DPPs will be introduced progressively as the Commission establishes the system and moves individual product families into the revised CPR framework.

The relevant question is therefore not whether all building products need a passport in 2026. It is when the new technical rules for a specific construction product become applicable.

How Viron can support

Viron helps manufacturers and importers distinguish between Digital Product Passport requirements, product compliance obligations and Extended Producer Responsibility.

We can assess how construction products and their packaging are affected by separate EU and national compliance frameworks and coordinate the relevant EPR registrations and reporting requirements.