Construction products do not get their Digital Product Passport from the ESPR. They get it from their own law, and mixing the two is the most common mistake in this sector.
In ESPR's scope, but the passport comes from elsewhere
First, the nuance that matters, because the shortcut is tempting: construction products are within the scope of the ESPR, which covers nearly every physical product placed on the EU market and does not exclude them. What they do not take from it is their passport, which comes from their own regulation. The two texts are built to run in parallel, and where the ESPR does apply to a construction product group it aligns its own act with the construction regime rather than duplicating it.
So "the ESPR does not concern me" is the wrong conclusion. The right one is narrower: your passport deadline is not in the ESPR working plan.
A separate regulation for the passport, not an ESPR product group
The Construction Products Regulation (EU) 2024/3110 replaced the 2011 regulation. It entered into force on 7 January 2025 and applies in stages from 8 January 2026. It provides for a digital product passport for construction products, on its own schedule and with its own content, independent of the ESPR working plan.
So a manufacturer of insulation, cladding, plumbing or electrical fittings will not find its deadline in the ESPR timetable. Looking for it there and finding nothing is not reassuring news: it means you are reading the wrong law.
What the construction passport is expected to carry
The regulation builds on documents this sector already produces rather than inventing a parallel set:
- the Declaration of Performance and Conformity, which remains the load-bearing document for market access;
- CE marking data;
- environmental information, including the Environmental Product Declaration where one exists;
- substance information, and data supporting deconstruction and reuse.
The passport makes that material digitally accessible and attaches it to the product, rather than replacing it.
The dates, and how firm they are
Firm: in force since 7 January 2025, staged application from 8 January 2026.
Indicative: the first delegated acts for construction products are expected from 2026, with harmonised technical specifications and the corresponding act discussed for around the end of 2027. Obligations then phase in by product family through 2032. Relief is foreseen for SMEs and micro-enterprises, with boundaries that depend on the product family and the acts.
Treat everything in the second group as a planning horizon. No construction product family has a confirmed passport date today, and anyone giving you one is reading a draft as if it were law.
What this changes in practice
The hard part is not the document, it is the identity. A Declaration of Performance describes a product reference. A passport attaches to an item, or at least to a batch, and has to stay reachable for years after the product is installed in a building. That means serialisation, a carrier printed or embedded on the product, and a resolver that still answers in a decade.
That work touches production and labelling, not the marketing department, which is why it is worth starting before the act that mandates it is published.
Where SealTrust fits
We do not write your Declaration of Performance and we do not produce the sector's exchange files. We give each item an identity, ingest the data you already hold, structure it in DPP form and make it verifiable: a proof replayed on every scan and a fingerprint anchored on a public blockchain, so a distributor, an auditor or a building owner can check it without taking our word for it.
See also the DPP timeline for how this sits next to batteries and textiles, and the regulation radar for the status of each text.