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Digital Product Passports for Construction

A building is a material bank with a fifty-year horizon. What the CPR recast requires, and why construction passports must outlive the firms that issue them.

CirculeID Research5 min read1,218 words

Regulation (EU) 2024/3110 introduces a digital product passport for construction products alongside the declaration of performance. Its distinguishing requirement is longevity: the data must remain reachable across a building’s service life, which routinely exceeds the lifespan of the manufacturer that issued it.

What this gives you

What the CPR recast asks of construction products, how declared performance and passport data relate, and the timeline for planning your data collection.

Key takeaways

  • Construction passports sit alongside the declaration of performance rather than replacing it.
  • Service life is the defining constraint — data must survive decades, ownership changes and company failures.
  • Reuse potential and hazardous content are the attributes that determine what happens at demolition.
  • Environmental product declarations expire, which makes passport maintenance an ongoing obligation rather than a launch task.

Construction is where the product passport idea is oldest and the regulatory instrument is newest. Material passports have circulated in the sector for years as a voluntary practice; Regulation (EU) 2024/3110, the recast Construction Products Regulation, gives them a legal basis.

The sector also has a constraint no other product group shares to the same degree. A jacket lasts five years and a laptop three. A structural element lasts fifty, and the person who needs its data has not been born yet.

How it relates to the declaration of performance

Construction products already carry a declaration of performance stating how the product performs against essential characteristics under a harmonised technical specification. That instrument does not disappear.

The passport sits alongside it, carrying information the declaration does not: environmental impact, reuse potential, hazardous content and the detail a future refurbishment or demolition team needs. The two answer different questions — one is about whether the product performs, the other about what it is and what happens to it afterwards.

Declaration of performance and product passport in construction, compared
AspectDeclaration of performanceProduct passport
Question answeredDoes it perform as claimed?What is it, and what happens next?
AudienceSpecifier, building controlPlus recycler, refurbisher, future owner
Lifespan of relevanceAt specification and installationThe whole service life of the building
Typical contentEssential characteristics, AVCP systemComposition, EPD reference, reuse potential, hazards
Declaration of performance and product passport in construction, compared

Why longevity changes the architecture

Most passport design assumes the issuing company persists. In construction that assumption is unsafe over the relevant horizon. Manufacturers merge, are acquired, and fail; product ranges are discontinued; the specific plant that made a batch closes.

A passport reachable only through a manufacturer’s own web infrastructure is therefore likely to be unreachable exactly when it is needed, which is during a refurbishment thirty years later.

The practical answers are open standards for identity and content, a resolver independent of the corporate website, and duplication of the data into the building’s own as-built record so that it survives independently of any external service.

The attributes that matter at end of life

Construction end-of-life decisions turn on three things, and each is a passport attribute that is difficult to reconstruct after installation.

  • Reuse potential. Whether the element can be removed intact, how it was fixed, and what condition assessment is needed before reuse. Removability is determined by the fixing method chosen at design.
  • Hazardous content and its location. Not merely whether a substance is present but which component contains it, so refurbishment does not release it unknowingly.
  • Material composition by mass. What the element is actually made of, at a level of detail that lets a recycler decide whether recovery is economic.

The second of those is the one with immediate safety consequences. A refurbishment team cutting into a panel needs to know what is in it before the cut, and a passport that says only that the product complies with restrictions does not answer the question.

Environmental product declarations expire

Construction has a mature environmental declaration practice through EN 15804, and those declarations carry validity periods, typically five years.

That creates a maintenance obligation most passport programmes are not designed for. A passport referencing an expired declaration is stating something that is no longer supported, and because building products stay specified for years, the expiry will often occur while the product is still being sold.

The operational implication is that expiry dates need to be tracked as data rather than remembered, with the passport surfacing the status rather than silently continuing to present a stale reference.

Where this connects to building-level records

A product passport describes a product. A building needs to know which products are where, which is a different record maintained by a different party.

Each layer is maintained by a different party and references the one below.

The connection between them is the identifier, which is why identifier stability matters more here than almost anywhere else. If the product identifier changes, the building record’s reference to it breaks, and nobody discovers that until somebody tries to use it.

Frequently asked questions

Does the construction passport replace the declaration of performance?

No. The declaration of performance continues to state how a product performs against essential characteristics. The passport carries different information — composition, environmental impact, hazardous content and reuse potential — and serves audiences including recyclers and future refurbishment teams that the declaration was never intended for.

How long must a construction passport remain available?

For the service life of the product in the building, which routinely exceeds fifty years and frequently exceeds the lifespan of the manufacturer. That constraint should drive the architecture: open formats, an identifier anyone can interpret, and duplication into the building record.

What happens when an environmental product declaration expires?

The passport is then referencing an unsupported figure. Because declarations typically carry a five-year validity and construction products stay specified for years, expiry often occurs while the product is still selling. Tracking expiry as data rather than as a calendar reminder is the workable approach.

Is reuse potential a design decision or a data field?

Both, and the data field only records what design decided. Whether an element can be removed intact depends on the fixing method, so a product bonded in place is not reusable regardless of what its passport says. The attribute makes the earlier decision visible rather than changing it.

Who maintains the passport once the building is occupied?

The manufacturer remains responsible for the product passport itself. The building owner maintains the record of what is installed where, which references the product identifiers. Neither party can reconstruct the other’s record, which is why capture at handover matters so much.

How does this affect specification and procurement?

Specifiers increasingly require passport data at tender rather than at delivery, because reuse and end-of-life obligations sit with the client. A manufacturer that cannot supply composition, hazard location and reuse data at specification stage is progressively excluded before any regulatory deadline applies.

Does this apply to products already installed?

Obligations attach to products placed on the market after the requirement applies, so existing building stock is not retrospectively covered. In practice owners of large portfolios are commissioning material surveys anyway, because refurbishment and demolition planning needs the data whether or not a regulation compels it.

Sources

  1. Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction productsEUR-Lex, European Union, 2024-12
  2. Regulation (EU) 2024/1781 establishing a framework for ecodesign requirementsEUR-Lex, European Union, 2024-06

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