Digital product passports (DPPs) that are accurate, complete, up-to-date and interoperable with BIM are, in theory, just a few years away following the EU’s publication of the Construction Products Regulation (CPR).
Regulation (EU) 2024/3110 lays down harmonised rules for the marketing of construction products, emphasising digitalisation, transparency and sustainability. It will repeal its predecessor, Regulation (EU) No 305/2011. The text of the regulation runs to more than 45,000 words – the key detail about DPPs is covered by Articles 75-80, which run to less than 1,500 words.
In short, it states that DPPs will have to contain the following information:
the declaration of performance and conformity;
the general product information, instructions for use and safety information;
the technical documentation;
the label;
the unique identifier;
documentation required under other EU law applicable to the product; and
the data carrier (the barcode, QR code or data matrix that links to the digital file for that product).
While the CPR’s text proposes a timeline, those involved in the DPP process believe it will be 2027 and beyond before the passports and the system to operate them become live. However, the text is clear that product manufacturers will have to ensure that the digital record the passport links to can be accessed for 10 years after that product ceases production.
Product manufacturers are not the only actors in the supply chain to have DPP responsibilities placed upon them. The CPR text refers to other actors, including authorised representatives, importers, distributors, dealers and professional repairers.
The European Commission will manage a register that will make the DPPs available. This will store the unique identifiers of the manufacturer, the product, and the installation. It will hold the digital records that the DPPs link to for 25 years.
The creation of a European data dictionary to facilitate the exchange of information between different systems and applications is also expected.
Transformational moment
Patricia Massey, digital and technology manager at BEAMA (the UK manufacturing trade association for the electrotechnical sector), sits on the working group focused on the digitalisation of construction products performance characteristics, explicitly linked to the specific tasks related to the new CPR implementation.
She told BIMplus: “Under Regulation (EU) 2024/3110, the introduction of DPPs will transform the construction products sector by requiring businesses to maintain accessible digital records of their products’ performance and conformance characteristics.
Structured data
Aitor Aragón sits on the Spanish standards association and is involved in the consortium carrying out a feasibility study into how the DPP system should work, in particular the DPP register.
In a detailed post on LinkedIn, he explained that the DPP system has several requirements:
data must be structured to be computer readable and searchable, for which an API should be developed;
the information must be transferable without limitations derived from proprietary formats or systems; and
access to the information must be possible in the language of the country in which the product is marketed, with a permission system that guarantees accessibility, but also the confidentiality of sensitive data.
He noted: “The DPP system will be implemented – in principle – by the end of 2027 and the obligation to use it will apply 18 months later. However, this process will be progressive and will take years to complete.
“The first products are expected to be: rebar; cement; doors, windows and their hardware; and thermal insulation. This staggering between product families will improve the process and its results.”
Furthermore, Aragón warned: “For its deployment to be successful and for the efficiency gains to far outweigh the implementation costs, it is vital to ensure cooperation between manufacturers, designers, construction companies, developers, public administrations and other actors in the value chain. Standardisation is the forum that can facilitate this cooperation and ensure that formats, processes and systems are available so that manufacturers can issue their digital product passports.”
“The Regulation enters into force on 7 January 2025, providing an initial lead-in period for stakeholders to familiarise themselves with the new requirements. Its provisions will begin to apply from 8 January 2026. Beyond this, the EC is expected to adopt delegated acts that will define the detailed requirements (product-specific rules) for DPPs and eco-design measures, offering further clarity on the technical obligations for businesses and other relevant [stakeholders].”
Impact on the UK
The CPR clearly affects UK construction product suppliers wanting to do business in EU states. Furthermore, it should be noted that the vast majority of the biggest product suppliers to the UK construction sector are headquartered in Europe and are thus unlikely to want to run one DPP system for all their products in Europe and another for all their products in the UK. There is therefore an expectation from the UK construction sector that the Ministry of Housing, Communities and Local Government (MHCLG) will engage with the matter.
Massey said: “We have some engagement, it’s a start, but there’s definitely room for more impactful and visible engagement. The UK government needs to step up by prioritising investment, ensuring adequate system funding and establishing a solid governance framework.
“This will be essential to help businesses, especially SMEs, navigate the DPP process and meet emerging regulatory requirements. Taking action early and fostering cross-sector collaboration will be key to facilitating trade, staying competitive and achieving sustainability goals as we move into 2025 and beyond.”
Massey is also a nima ambassador and is confident that the Information Management Initiative “has a vital role to play. It can effectively engage with and support the UK supply chain, complementing efforts to roll out DPPs under both the Ecodesign for Sustainable Products Regulation (ESPR) and the CPR.”
Dumping ground?
Alex Small, digital platforms and innovation lead at Tata Steel, warned that the UK could become a dumping ground for construction products that do not conform with the EU regulations if the UK does not mirror the EU’s DPP system swiftly enough.
He added: “The UK government needs to publish a timeline, and manufacturers need to understand what they need to do pretty quickly. It’s 2025 next year; we’ll blink and it will be 2027. Some of us are very engaged in the DPP process. I’d be happy to work with the Construction Products Association (CPA) to stage some workshops with UK manufacturers.”
BIMplus has asked the CPA and MHCLG for their responses.
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