Construction Products and Digital Product Passports

Construction Products and the ESPR Regulatory Landscape

The construction sector accounts for approximately 40 per cent of the European Union's energy consumption and 36 per cent of its greenhouse gas emissions. Buildings and infrastructure are the single largest consumers of raw materials in the EU, using approximately half of all extracted materials. When demolition waste is included, construction and demolition activities generate around one-third of all waste in the EU. These stark figures explain why construction products are a priority focus of the EU's sustainability agenda.

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, establishes the framework for Digital Product Passports across product categories, and construction products are explicitly within its scope. At the same time, the revised Construction Products Regulation (CPR), Regulation (EU) 2024/3110, which governs the marketing of construction products in the EU, entered into force on 7 January 2025 and applies in stages from 8 January 2026. It is aligned with the ESPR to ensure consistency in sustainability and information requirements, and it carries its own construction product passport.

Construction Products DPP at a Glance

This dual regulatory framework, the ESPR providing the overarching DPP mechanism and the revised CPR specifying construction-specific requirements, means that construction product manufacturers face a particularly complex compliance landscape. However, it also means that when DPP requirements are finalised, they will be tailored to the specific characteristics and challenges of construction products.

The Circular Economy Action Plan identifies construction and buildings as a priority area for action, calling for sustainability requirements for construction products, increased material efficiency, improved waste management, and the promotion of circular business models. Digital Product Passports are seen as a key enabler of these objectives in the construction sector.

Expected Timeline and Regulatory Context

The timeline for construction product DPPs is intertwined with both the ESPR delegated act process and the revision of the Construction Products Regulation. Construction products are not a product group in the ESPR working plan 2025-2030 (iron and steel and aluminium are, as materials), so construction product passports arrive through the CPR rather than an ESPR delegated act; see the ESPR timeline for the product groups that are scheduled.

The revised CPR establishes the legal basis for sustainability requirements specific to construction products, including environmental declarations, recycled content and durability information, and for a digital product passport that is switched on product family by product family through Commission acts, none of which had been adopted by September 2026.

For construction product manufacturers, the message is clear: while mandatory DPP requirements may still be several years away, the regulatory trajectory is firmly established. The convergence of the ESPR and the revised CPR creates a comprehensive framework that will fundamentally change how construction products are documented and marketed in the EU.

Businesses should use the time available to prepare their data infrastructure, engage their supply chains, and build the internal capabilities needed for DPP creation. The construction sector's relatively long product development cycles, where a new product may take two to three years to move from development to market, mean that products being designed today may need to comply with DPP requirements when they are launched.

Data Requirements for Construction Product DPPs

The Digital Product Passport for construction products will need to contain a comprehensive set of data reflecting the product's performance, environmental impact, and circularity characteristics. Based on the ESPR framework, the revised CPR proposals, and existing industry standards, the following data categories are expected:

• Embodied carbon: The global warming potential of the product across its lifecycle, calculated using EN 15804 or equivalent standardised methodology, expressed as kg CO2 equivalent per functional unit.
• Thermal performance: For insulation and building envelope products, thermal conductivity and resistance values determined through standardised testing.
• Fire resistance: Fire classification data determined under harmonised European standards, including reaction to fire and fire resistance ratings where applicable.
• Recycled content: The percentage of recycled materials used in the product, broken down by material type, with verification through recognised standards.
• End-of-life recyclability: An assessment of the product's recyclability at end of life, including any limitations imposed by material composition, contamination, or installed condition.
• Hazardous substances: Information on substances of concern contained in the product, including volatile organic compounds (VOCs), heavy metals, and substances on the REACH candidate list.
• Durability and expected service life: The expected service life of the product under normal conditions, based on standardised testing or established performance data.
• Material composition: A detailed breakdown of all materials used, including quantities, types, and origins.
• Environmental Product Declaration (EPD) data: Where an EPD exists for the product, key data from the EPD should be incorporated into or referenced from the DPP.
• Installation and maintenance guidance: Information relevant to the correct installation and maintenance of the product to ensure optimal performance and longevity.

BIM Integration: A Unique Opportunity for Construction

The construction sector has a significant advantage over many other industries when it comes to DPP implementation: the widespread adoption of Building Information Modelling (BIM). BIM is a digital methodology for creating and managing information about a built asset throughout its lifecycle, and it is already mandated for public procurement in many EU member states.

BIM models contain detailed product data, dimensions, materials, performance characteristics, manufacturer information, that overlaps significantly with DPP requirements. The integration of DPP data into BIM workflows presents a powerful opportunity to create a seamless digital thread from product manufacture through building design and construction to operation and eventual demolition.

In practice, this integration could work in several ways. Product manufacturers could provide BIM objects for their products that include links to the product's DPP, enabling architects and engineers to access full sustainability and compliance data during the design process. Building operators could use DPP data embedded in the as-built BIM model to manage maintenance, assess renovation options, and plan end-of-life material recovery.

The data requirements for construction DPPs align closely with the information already captured in Environmental Product Declarations (EPDs) and BIM product data templates. Manufacturers who already produce EPDs and BIM objects will find that a significant proportion of the DPP data requirement is already met, reducing the additional effort needed for compliance.

Standardisation bodies, including buildingSMART International and CEN, are actively developing standards for the integration of sustainability data into BIM workflows. Construction product manufacturers should monitor these developments and engage with pilot projects to ensure their DPP strategies are compatible with emerging BIM-DPP integration standards.

Unique Challenges: Long Lifespans and Installed Products

Construction products face several unique challenges that distinguish them from other ESPR priority sectors. The most fundamental of these is the extremely long service life of many construction products. Structural elements, facades, and building services can have design lifespans of 50 to 100 years or more, far exceeding the lifespan of any consumer product.

This long lifespan has profound implications for DPP data hosting and maintenance. The DPP data must remain accessible for the entire service life of the product plus an additional period after the last unit is placed on the market. For a structural steel beam with a 100-year design life, this could mean maintaining data accessibility well into the 22nd century. This requires robust, long-term data hosting strategies and raises questions about data format longevity, organisational continuity, and the management of legacy data.

The installed nature of construction products presents another unique challenge. Unlike consumer products that remain discrete and accessible throughout their life, construction products are typically incorporated into buildings during construction and may become inaccessible once the building is complete. A concrete block, for example, may be covered by plaster, insulation, and cladding, making it impossible to scan a QR code on the product itself.

This necessitates innovative approaches to data carrier placement and management. Options include placing QR codes on accessible surfaces of the building where they can be linked to all products used in that area, incorporating DPP references into the building's BIM model or digital building logbook, and using component-level digital identifiers that are recorded during construction and linked to the building's overall information management system.

Renovation and refurbishment tracking adds further complexity. When a building is renovated, products may be removed, replaced, or supplemented with new ones. The DPP system needs to support this dynamic context, enabling the tracking of products through installation, maintenance, renovation, and eventually demolition or reuse.

Embodied Carbon: A Central Focus for Construction DPPs

Embodied carbon, the greenhouse gas emissions associated with the production, transport, and installation of construction materials, has emerged as a critical focus of building sustainability policy. As operational energy efficiency improves through better insulation and renewable energy, the relative importance of embodied carbon in the total lifecycle emissions of buildings is increasing rapidly. For some building types, embodied carbon now accounts for 50 per cent or more of total lifecycle emissions.

The circular economy principles embedded in the ESPR reinforce this focus. By requiring manufacturers to disclose the embodied carbon of their products, the DPP creates transparency that enables architects, engineers, and building clients to make informed choices about materials. Products with lower embodied carbon, whether through the use of recycled materials, low-carbon production processes, or sustainable sourcing, will be able to demonstrate their advantage through their DPP data.

The methodology for calculating embodied carbon in construction products is well established through the EN 15804 standard, which provides the framework for Environmental Product Declarations. However, the level of detail and verification required for DPPs may exceed what is currently standard practice for many EPDs. Manufacturers should review their embodied carbon data and calculation methodologies to ensure they meet the expected DPP requirements.

Whole-life carbon assessment, considering not just production emissions but also maintenance, repair, replacement, and end-of-life emissions, is increasingly important. DPP data on product durability, repairability, and recyclability all contribute to whole-life carbon assessment, enabling more sophisticated decision-making about building material selection.

Implementation Approach for Construction Product Manufacturers

Implementing Digital Product Passports for construction products requires a strategic approach that leverages existing data infrastructure while addressing the unique requirements of the sector. The following steps provide a practical roadmap for construction product manufacturers.

First, assess your existing data assets. If you already produce Environmental Product Declarations, BIM objects, Declarations of Performance, or CE marking documentation, you have a substantial foundation for DPP creation. Map the data in these existing documents against the expected DPP requirements to identify coverage and gaps.

Second, invest in product data management. Many construction product manufacturers manage product data across multiple disconnected systems, ERP, quality management, EPD tools, BIM authoring, marketing databases. The DPP requirement creates a compelling business case for consolidating product data into a single, authoritative source that can feed all downstream uses, including DPPs, EPDs, BIM objects, and marketing materials.

Third, develop your supply chain data capabilities. Construction products often incorporate materials and components from multiple suppliers. You will need data from these suppliers about the environmental characteristics of their inputs, the carbon footprint of aggregates, the recycled content of steel, the origin of timber. Establishing data exchange mechanisms with key suppliers should be a priority.

Fourth, select a DPP platform that understands the construction sector. The platform should support the specific data formats used in construction (EN 15804, IFC, GS1), accommodate the extremely long data retention periods required for construction products, and integrate with BIM workflows. MyProductPassport offers construction-specific capabilities designed for these requirements.

The Role of EPDs and Product Declarations

Environmental Product Declarations are already widely used in the construction sector to communicate the environmental performance of products in a standardised, third-party verified format. The relationship between EPDs and DPPs is a key question for the construction industry, and the answer is likely to be one of integration rather than replacement.

EPDs provide detailed lifecycle assessment data that will form a significant component of the DPP data set. However, the DPP goes beyond what a typical EPD covers by including additional information about repairability, disassembly, hazardous substances, and supply chain traceability. The DPP also has different accessibility requirements, it must be available to consumers and enforcement authorities via a QR code scan, not just to professional users via EPD databases.

The most efficient approach for manufacturers is to treat the EPD as a data source for the DPP rather than as a separate, standalone document. Data from the EPD, particularly embodied carbon, resource use, and waste generation indicators, can be incorporated into the DPP, supplemented by additional data points that the EPD does not cover.

Industry organisations such as ECO Platform (which manages the ECO EPD programme) and national EPD programme operators are working to align EPD data formats with expected DPP requirements. Manufacturers should engage with these initiatives to ensure their EPD strategies are compatible with the emerging DPP framework.

Preparing for Construction Product DPP Requirements

While mandatory DPP requirements for construction products may still be several years away, the preparation required is substantial and should begin now. The construction sector's complex supply chains, diverse product types, and unique lifecycle characteristics mean that implementation will take longer than in many other sectors.

The convergence of the ESPR and the revised Construction Products Regulation creates a comprehensive regulatory framework that will transform how construction products are documented, marketed, and used. Businesses that prepare early will be best positioned to comply efficiently and to capture the commercial benefits of product transparency.

The construction industry has strong foundations to build upon, EPDs, BIM, Declarations of Performance, and CE marking all provide existing data infrastructure that can be leveraged for DPP creation. The key challenge is to consolidate these disparate data sources, fill the remaining gaps, and present the information in the accessible, standardised format that the DPP requires.

MyProductPassport provides construction product manufacturers with the tools they need to prepare for DPP compliance. Our platform supports EPD data integration, BIM workflow compatibility, long-term data hosting, and the complex material composition data that construction products require. Start your preparation today and build the foundation for a more transparent, sustainable construction industry.

10-Step Action Plan for Construction Product Manufacturers

1. Map your product portfolio against CPR scope. List every product placed on the EU market with category, CE marking status, and current EPD coverage.
2. Audit existing EPDs. EN 15804 Environmental Product Declarations are the natural foundation for DPP carbon and lifecycle data. Identify products with current EPDs and those needing fresh assessments.
3. Engage raw material suppliers. Steel, cement, aggregates, and timber inputs all carry their own carbon-intensity data needed for the DPP. Issue supplier data requests now.
4. Build BIM-ready DPP data. Construction products are increasingly specified via BIM. DPP data fields should map cleanly into IFC or other BIM schemas used by your architectural customers.
5. Document embodied carbon. Cradle-to-gate embodied carbon is a central DPP field for construction products. Use ISO 14067 or EN 15804 methodology with third-party verification.
6. Capture recycled content evidence. Chain-of-custody documentation for recycled inputs becomes a DPP field. Align with whatever certification scheme your sector accep