Construction products

What Digital Product Passport rules apply to construction products?

EU construction law already establishes a Digital Product Passport system framework, and the complete system is not operational today. Regulation (EU) 2024/3110 generally began to apply on 8 January 2026, adopted, and Articles 75 to 80 set the framework. A Commission system-setting delegated act is still required, and the current timing for it is Q2 2027, indicative.

This category is unusual because so much is fixed in the parent Regulation rather than left to the act. Product-type identity is established. Information classes for the passport are established. One or more data carriers are established, with implementation detail still to be completed. Access differentiation is established, with the detailed access matrix to be set by the system. What is not established is the operational system itself.

Two things follow that catch people out. The passport is centred on product type rather than on the individual item, which is the opposite default from batteries. And the CPR mandates no universal GTIN, whatever a customer asks for.

The transition is also not one date. CPR-2011 and CPR-2024 coexist while product families migrate, so two products on the same pallet can sit under different regimes.

2 pages here, plus the origin question.