Construction products: CPR and ESPR paths

Construction products are a special case in the world of the Digital Product Passport (DPP). Unlike most sectors, they do not follow the main ESPR route but have their own, separate path. This article explains how the CPR and ESPR relate, and what that means for manufacturers.

Two paths, one direction

Most products will be covered by a DPP under the ESPR (the Ecodesign for Sustainable Products Regulation, 2024/1781). Construction products, however, are governed by a separate instrument — the Construction Products Regulation, or CPR (Regulation (EU) 2024/3110).

It is the CPR, not the ESPR, that introduces the sectoral passport track for construction. The goal is shared — transparency of product data — but the legal basis and the detailed mechanisms differ.

Why construction took its own route

The construction sector already has a mature, well-developed documentation system. Manufacturers have for years produced a declaration of performance and used environmental product declarations (EPDs) based on recognised standards.

Rather than building this sector from scratch under the ESPR, the legislator based the construction passport on the existing CPR infrastructure. As a result, the passport draws on documents the industry already knows and uses.

The link to existing documentation

A construction-product passport is meant to draw on data that already exists in the sector:

• the declaration of performance — the core conformity document for a product,
• environmental product declarations (EPDs) — based on recognised environmental standards,
• environmental characteristics introduced in stages, including the carbon footprint.

Because of this, the passport does not so much create new data as organise and digitally publish what already exists in the technical documentation.

When the passport becomes mandatory

Here caution is needed: for construction products there are no binding, final dates yet for the passport obligation. The CPR provides that a passport must be available within a set period after the relevant delegated act for a given product group is adopted.

Environmental characteristics are being introduced gradually over this decade, but the specific deadlines for individual product groups remain unfixed. Treat the schedule as a direction of travel, not a closed list of dates.

Construction outside the first ESPR wave

It is worth remembering that construction products are not part of the first ESPR wave. They run on the parallel CPR track, and their inclusion in the broader ecodesign logic is subject to a review later in the decade.

For companies this means that following only the ESPR timeline is not enough — you also need to watch the development of construction rules. We set out the wider context in ESPR explained.

What it means for manufacturers

If you make or place construction products on the market, preparation is best started by taking stock of the documentation you already hold.

• Check that the declarations of performance for your products are current.
• Gather available environmental declarations (EPDs) and carbon-footprint data.
• Establish which data is already structured and which needs tidying.
• Follow the work on delegated acts for your product group.

We describe the staged introduction of detail in ESPR delegated acts, and the full sector picture in the ESPR timeline.

The declaration of performance as the starting point

In construction, the central document is the declaration of performance. It describes how a product behaves against essential characteristics — from load-bearing capacity to reaction to fire. A construction passport is meant to build on that declaration, not create a parallel, inconsistent data set.

For a manufacturer that is good news: the starting point already exists. The challenge is more about bringing the declaration into a digital, structured form that can be linked to the data carrier on the product or in its documentation.

Carbon footprint and environmental characteristics

Data on the environmental impact of products, including the carbon footprint, plays a growing role in construction. These characteristics are being introduced gradually over this decade and rest on recognised environmental product declarations (EPDs).

This is where a construction passport can add the most value: it brings into one place the data needed by designers, investors and those assessing buildings for sustainability. Manufacturers who already calculate the carbon footprint of their products will be better prepared for the stages ahead.

Where CPR and ESPR may meet

Although they are two separate tracks today, their goals converge: transparency and better product data. Bringing construction products into the broader ecodesign logic is subject to a review later in the decade.

For companies this means it is worth building data flexibly — so that the same tidy set of information can be used regardless of which track the regulation ultimately follows. A flexible data structure is the best hedge against change.

What to do differently from other sectors

A construction-product manufacturer should keep a few differences from the classic ESPR route in mind:

• the basis is the CPR, not an ESPR delegated act,
• the passport builds on the declaration of performance and EPDs,
• deadlines depend on the acts for specific product groups,
• environmental data phases in gradually, not all at once.

Following the right rules matters here as much as preparing the data itself.

Key takeaways

• Construction products have their own passport track under the CPR (2024/3110), not the ESPR.
• The construction passport builds on existing documentation: the declaration of performance and EPDs.
• There are no binding, final dates yet — deadlines depend on delegated acts.
• Environmental characteristics, including the carbon footprint, phase in over this decade.
• Construction sits outside the first ESPR wave and is subject to a separate review.

See how CyfroPass lets you organise construction-product data and prepare a Digital Product Passport without writing code. Visit cyfropass.pl and bring your existing documentation into one record.