Is Data More Valuable Than Concrete? How the Digital Product Passport Ends Construction's Information Chaos

Construction is stuck in what amounts to an analogue data nightmare. Declarations of performance, EPD certificates, safety data sheets, and installation instructions sit scattered across thousands of PDFs, on manufacturer servers, and inside operator databases. Finding a single fact about a material's chemical composition or recyclability twenty years after a building went up is close to impossible. The Digital Product Passport is the project meant to fix that, building one source of truth and pulling scattered data into a single machine-readable ecosystem. It is not only a legal requirement. It is the foundation for a genuinely transparent circular economy.

1. This is not one deadline, it's a staged rollout

Although the revised Construction Products Regulation, 2024/3110, becomes applicable from 8 January 2026, the Digital Product Passport itself does not arrive for the whole market on a single day. The obligation is introduced sequentially, product family by product family, as new harmonised technical specifications are published under the CPR Acquis process. According to research shared by the myDPP team, priority product families in the first wave are expected to include cement, reinforcing steel, precast concrete products, and windows and doors, while the old system is phased out gradually into the 2030s. For manufacturers in these priority categories, the window to prepare structured, exportable data is closing faster than it looks.

2. GWP is the new foundation of compliance, not marketing

The most consequential near-term change sits in Article 6 of the revised CPR: mandatory disclosure of Global Warming Potential. Here is the detail that gets missed: while the physical DPP data carrier, such as a QR code, arrives later, the GWP declaration inside the Declaration of Performance and Conformity becomes a mandatory legal artefact much sooner. A product's carbon footprint, calculated to EN 15804+A2, stops being a voluntary addition to a tender submission and becomes a condition of legal market access, carrying the same technical weight as mechanical strength or fire resistance. Manufacturers without verified emissions data risk losing the ability to legally place a product on the EU market at all.

3. System 3+ raises the bar for environmental data

The other structural change is the introduction of AVCP System 3+, a new assessment and verification category built specifically for environmental data. It requires independent third-party verification of GWP and other environmental indicators, closing the door on manufacturers self-declaring that specific data without checks. System 4 self-declaration is not disappearing altogether, it continues to apply to other product characteristics outside the scope of System 3+. Manufacturers who already hold verified EPD certificates carry a real strategic advantage here, since their existing processes are already close to what the new system requires.

Firms that leave verification until the last moment risk running into a capacity bottleneck among LCA auditors, which could stall certification processes across an entire product category at once.

4. How bulk products like cement carry a passport

One question comes up constantly: how do you put a QR code on a tonne of sand or a truckload of ready-mix concrete? The revised CPR is deliberately flexible here, allowing the DPP data carrier to appear on packaging or on accompanying documents rather than on every physical unit. For bulk and loose materials such as cement or aggregates, the data carrier can sit on unit packaging, such as a bag, or on delivery documentation. That flexibility creates a separate challenge: durability of the link itself. For the data to still be useful during a renovation or demolition fifty years from now, the link to the passport has to survive inside the project's own documentation, which is exactly why connecting DPP data to BIM models and digital building logbooks is becoming a natural next step rather than an optional add-on.

5. The registry is a connector, not a central database

It is worth clarifying the technical architecture behind this, since it drives a lot of the confidentiality concerns manufacturers raise. The registry itself is not a construction-specific requirement, its 19 July 2026 setup deadline comes from the ESPR, the general regulation governing the whole DPP system across all product categories, and it applies to construction only because the registry is shared across sectors. It will not be a giant warehouse holding every manufacturer's trade secrets. It functions as a central EU index of unique identifiers, closer to a directory than a database. The detailed underlying data stays distributed, held by manufacturers or by DPP service providers. That architecture protects commercial confidentiality while still giving customs authorities and market surveillance bodies a fast way to verify a product's declared parameters through a linking mechanism.

The Digital Product Passport is not another form to fill in. It is a shift in paradigm, from a paper-declaration economy to a data-driven one, where information about a product carries as much weight as the product itself. Passports are meant to make it possible to trace materials from raw extraction, through a building's full lifecycle, to deconstruction and reuse. Manufacturers should start with a real data inventory and digitisation of their DoPC processes today, keeping in mind that System 3+ leaves little room for shortcuts.

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