Construction product passport abroad: what is different?
If you supply construction products to customers in multiple EU countries, it is reasonable to ask whether the digital product passport works the same way everywhere. The answer is twofold: the obligation to maintain a passport and the data that must be included in it stem from EU regulations and in principle apply equally in each Member State. What can differ is mainly in the implementation: the language in which the passport must be accessible, which national authority supervises it, and how the passport relates to building regulations that already existed in each country.
For construction products this applies more strongly than for many other product groups. Construction products have long been subject to their own European rules on performance declarations and CE marking, which in turn run in parallel with national building regulations. The digital product passport does not exist separately from these, but sits on top of them.
What remains the same in every EU country
The regulation governing the digital product passport is directly applicable EU law. This means that a Member State cannot soften or tighten the core: which data are mandatory, who is responsible for providing it, and that the passport must be accessible via a QR code or comparable carrier, is fixed at EU level. A construction company selling the same product in the Netherlands, Germany and France therefore does not need to have three substantively different passports drawn up.
A supervisory authority's competence to look across borders is also a shared EU matter: market surveillance authorities cooperate and exchange information. For the precise operation of this, the text of the regulation itself is the most reliable source, supplemented by what the supervisory authority in the relevant country publishes about it.
Where countries do retain flexibility
The differences lie in the margins around it. Member States appoint their own market surveillance authority themselves, and not every country has the same authority or the same procedures for this. For construction products this can be a different service from the authority that supervises, for example, electronics, and this varies again by country.
In addition, national building regulations continue to exist alongside the European ones. A performance declaration that is sufficient in one country may need to be supplemented in another country with a national technical approval or an additional declaration, because building standards such as fire safety or structural requirements are defined nationally. The product passport does not replace that national documentation; it stands alongside it, and in practice often refers to it.
The language of the passport
An issue that companies with export activities regularly encounter is the language in which data must be accessible. The regulation sets requirements for accessibility of the passport, but the precise language requirements can be defined by each Member State, similar to how this already works with instructions for use and safety information. Anyone placing a product on the market in multiple countries would do well to check when drawing up the passport whether a translation or multilingual version is needed, rather than discovering this afterwards.
What this means for a construction company with export
For an installation company or manufacturer that mainly supplies within the Netherlands, these differences result in little change: the product passport is set up according to Dutch supervisory practice and that is sufficient. As soon as you also supply customers in other Member States, it is advisable to check per destination country which additional national requirements remain alongside the product passport, and who the supervisory authority is there. This is not a legal exercise that you only have to do yourself; the official text of the regulation and the information from the national supervisory authority are the appropriate sources for this, possibly with a lawyer who translates it to your situation.
In the knowledge base with topics per product group and country identifies for each situation which source belongs to which topic, including the reference to the official EU text. If you first want to know where your product and your export countries stand exactly, the scan that gives an indication in a few questions provides an initial direction. How we collect that data and where the information comes from, you can read on the page about how prodpas.eu works.
If you have a specific question about a specific country, there is a good chance it has been asked before; a look at the frequently asked questions about the digital product passport can save time before you search further or engage a lawyer.
Mapping your situation yourself
This article describes where the rules for construction products can differ per country, not how that works out for your specific export. Take the free quick-scan or browse through the knowledge base to see which topics are relevant for your products and export countries, and consult the official text or the competent supervisory authority if in doubt.