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EU Regulation

What Data Will a Digital Product Passport Actually Need?

No official field list exists yet. Here's what you can reasonably expect, and why it's worth getting organized before the rules are final, not after.

Tylko Academy·23 October 2026·6 min read

No construction-specific Digital Product Passport field list has been finalized yet, no delegated act for construction products has been adopted under ESPR or CPR. That means nobody can hand you an exact, binding list of fields to fill in today. What's useful instead is thinking in terms of the broad types of data a DPP is likely to involve, and starting the groundwork now, because almost none of that groundwork disappears once the official list eventually lands.

Quick answer: expect a DPP to eventually draw on five broad types of data: who made the product and how it's identified, what it's made of, how it performs environmentally, what compliance documentation already exists for it, and how it should be handled at end of life. None of these are fixed legal field names yet for construction products. The one piece that's already a confirmed, real requirement, not a prediction, is the GWP declaration under CPR, mandatory from 8 January 2026.

Identification

This covers the basic "what is this, and who's responsible for it" information: how the product and its specific batch or model are identified, which legal entity manufactured it, and who else handled it along the way, importers or distributors, for example.

  • Product and batch-level identification
  • Manufacturer and other involved parties' identity
  • Production and import/distribution details
Why prepare it now: this is mostly data your company already generates for other reasons, company registration, trade documentation, batch tracking. It just tends to live in different systems depending on who created it, so pulling it into one consistent place is worth doing gradually rather than all at once later.

Composition

This covers what the product is actually made of, materials, substances, and how much of it comes from recycled sources.

  • Material and substance composition
  • Substances already tracked for other EU compliance purposes
  • Recycled or recovered material content
Why prepare it now: this kind of information usually already exists somewhere, bills of materials, supplier data sheets, but rarely in a format anyone outside engineering can actually use. Getting it into a usable shape takes real time, more than most people expect, so starting before there's a deadline attached is the easier path.

Environmental

This covers the product's environmental footprint and durability, how it performs over its lifetime, not just at the point of sale.

  • Carbon footprint / environmental impact data
  • Durability and expected lifetime information
Why prepare it now: part of this isn't speculative at all. The GWP (Global Warming Potential) declaration is already a confirmed, mandatory requirement under CPR from 8 January 2026, nested inside your Declaration of Performance and Conformity. We go through exactly what that involves, and how it relates to a full EPD, in EPD vs DPP. Whatever broader environmental data a future DPP requirement eventually asks for will likely build on that same underlying calculation work, so doing it properly now pays off twice.

Compliance

This covers the documentation that proves the product meets the rules it's already subject to, conformity declarations, technical files, safety information.

  • Conformity and compliance documentation
  • Technical documentation and certificates
  • User and safety information
Why prepare it now: this is the one category where most manufacturers already have the raw material. The open question is usually whether it's digitized, current, and clearly linked to the right product, not whether it exists at all.

End-of-life

This covers what happens to the product after its useful life, disposal, recycling, and in some cases how it can be taken apart into separable materials.

  • Disposal and recycling guidance
  • Disassembly or separability information, where relevant
Why prepare it now: this tends to be the least-developed category inside most companies, because end-of-life has traditionally been treated as someone else's problem, the waste industry's, not the manufacturer's. That's exactly why it's worth a head start here specifically.
The exact field names will come later, through whichever delegated act eventually covers your product. The question of who in your company actually holds this information doesn't need to wait for that.

None of these five categories are something one person or department owns end to end. Identification data tends to sit with compliance or legal, composition with engineering, environmental data increasingly with sustainability, compliance documentation with quality. We go through why that split exists, and why no regulation currently assigns it differently, in who owns product data. Figuring out who already holds each type of data is most of the real preparation work, well before any specific field list becomes law.

DPP

If you'd rather map this out properly than guess at it, that's exactly what our DPP course walks through. What's already confirmed, what's still coming, and how to get your internal data organized either way.

See the DPP course →

Frequently asked questions

Is there an official, finalized list of data fields for a construction product's Digital Product Passport?

No. No delegated act specific to construction products has been adopted under ESPR or CPR yet. What can be described today are the broad types of data likely to be involved, not a fixed, final field list.

What's the one piece of this that's already a confirmed legal requirement, not a prediction?

The GWP (Global Warming Potential) declaration required under CPR from 8 January 2026, nested inside the Declaration of Performance and Conformity. Most of the rest of a construction product's eventual DPP content is still undefined.

Who inside a company usually ends up responsible for this kind of data?

It varies, and no regulation assigns it. In practice, compliance or quality teams tend to hold conformity and identification data, engineering or sustainability teams hold composition and environmental data, and supply chain teams hold import and distribution data.

Why bother preparing this data before the exact rules are finalized?

Because most of this data already exists somewhere inside a company. The real work is usually locating it, checking it's current, and getting it into one place, not creating it from nothing, and that takes longer than people expect once a deadline actually lands.

Of these five types of data, which one would take your company the longest to actually pull together today, not once it's legally required, but right now?
Digital Product Passport ESPR Data EU Regulation

Learn DPP Properly,
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Why it's worth it:

  • The full regulatory picture, not just the deadline. ESPR and CPR explained together, with the real timeline.
  • What's actually inside a DPP. Real data fields and how governance works once it's a system of record.
  • Where this is going next. A bonus module on AI in DPP.
  • A certificate on completion, plus team licenses for whole organizations.
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