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What changes this year for construction products and the digital product passport?

For construction products, the introduction of the digital product passport is taking place via a separate regulation, alongside the general ecodesign regulation. This year will mainly clarify which product categories are first in line.

What changes this year for construction products and the digital product passport?

For construction products, the path to a digital product passport is via a separate, revised regulation for construction products, distinct from the general regulation that applies to most other product groups. This year, the focus is mainly on developing this: which product categories will first receive a passport, and what data must be included. A fixed entry date for a mandatory passport per product category has not yet been set; this will follow per category via separate implementing rules.

This is relevant for anyone placing construction materials on the European market: manufacturers of insulation materials, windows and doors, pipework, roofing and similar products, but also importers and installation companies that have products manufactured under their own name. Those already following other product groups, such as electronics or textiles, will notice that the pace and approach for construction products runs slightly differently than for those groups.

Why construction products are taking a separate route

The general regulation on ecodesign governs the digital product passport for most product groups. However, construction products have long been subject to their own European regulation, which concerns performance, safety and CE marking of construction materials. This regulation has been revised and now also contains a legal basis for a digital product passport, specifically tailored to the construction sector.

Two regulations, one principle

The underlying idea is the same as for other product groups: data about a product must be available digitally and in structured form, via a QR code or similar carrier, throughout the entire life of the product. What differs is the path to get there. For construction products, the mandatory data and timing are determined separately for each category, rather than through a single central plan for all product groups at once. Those who have not yet grasped this distinction will find an overview of the concepts and the different regulations in the knowledge bank by subject.

What specifically happens this year

This year the focus is on preparatory work: identifying priority product categories within the construction sector, and developing the technical requirements a passport must meet. For businesses, this means there is no hard obligation yet to maintain a passport for construction products, but the direction in which this is developing is becoming increasingly clear. Authorities and industry organisations in construction are following this process, and it is likely that concrete obligations per product category will be introduced gradually over the coming years, although this timeline is not fixed.

Businesses already dealing with other product groups often see a similar pattern: first a framework regulation, then a priority list per product group, and only then concrete data requirements and deadlines. For construction products, this process is now in the priority list phase.

What this means for your business

If you manufacture, import or market construction materials under your own brand, it is now mainly important to follow which product category within your range comes into focus first. This varies considerably: insulation materials and certain metal construction products are mentioned more frequently in EU documents as areas of attention than, for example, sanitary ware. An indication of where your own product group stands can be obtained with a brief scan of your situation, which you complete free of charge and without any obligations.

For installation companies that are not manufacturers themselves but do purchase and resell construction products, it is important to know which role you actually fulfill according to the rules. That role determines who is responsible for the product passport: the manufacturer, the importer, or sometimes you yourself if you place a product on the market under your own name. Frequently asked questions on this subject, with short and concrete answers, are collected on the page with frequently asked questions.

What you can do now

There is no reason to start collecting data now for an obligation that is not yet established, but it is wise to know where your products stand in the process and which data your suppliers are already keeping. A number of manufacturers in the construction sector are starting to organize material data as a precaution, because it is needed anyway for other purposes, such as CE documentation. Those who want to start that process in advance can register for free with a business account and follow developments per product group.

Do you want to know if, and if so when, this will apply to your specific products? Take the free quick-scan or read the other topics in the knowledge base. For the translation to your own situation, a lawyer or the competent supervisory authority remains the appropriate contact point.

This article is general information and not legal advice.