Digital Product Passports for Construction:

In December 2025, the European Commission published the first Working Plan for the implementation of the Construction Products Regulation (CPR) for 2026–2029, including its roadmap for Digital Product Passports (DPPs) and associated harmonised standards development. This marks the first time stakeholders across the construction ecosystem can see when and how DPP requirements will unfold for specific product families.

In this article, we break down what this means in practical terms, why it matters, and how manufacturers and their partners can prepare today, ideally before obligations become enforceable.

The CPR (EU 2024/3110) sets out harmonised rules for construction products placed on the EU market, including safety, performance and for the first time the requirement for a Digital Product Passport once the supporting standards and delegated acts are in place.

The Working Plan 2026–2029 provides a clear roadmap for how the Commission and standardisation bodies will deliver:

• revised harmonised standards for product families (Annex VII),
• timelines for standardisation delivery and adoption

Although the DPP is still not yet mandatory for construction products as of early 2026, this plan signals to manufacturers, contractors, architects and other stakeholders that the transition is no longer theoretical. The sequence and timelines are emerging.

The working plan sets out when different product families move through:

• delivery of harmonised standards (under the new CPR framework), and
• mandatory reference in legislation via implementing and delegated acts — the actual trigger for DPP obligations.

To make this more tangible, the European Commission has mapped out indicative timelines for each construction product family in the CPR Working Plan 2026–2029. Please refer to the table below.

Two examples help illustrate how this applies in practice:

A point we cannot over-emphasise: there are currently no official DPP service providers for construction products as recognised under EU rules.

The CPR Working Plan and underlying CPR text set the obligation framework, but operational details around:

• who hosts DPP systems,
• how data carriers and registries will work,
• whether service providers will be certified

These are still to be defined through:

• By 19 July 2026, the Commission shall set up the DPP Registry which stores at least the unique identifiers.
• A delegated act which will set the rules for DPP Service Providers in Q4 2026
• A delegated act which shall supplement the CPR by setting up a construction DPP system

In other words, systems that facilitate the transition to DPP readiness exist today — from data management platforms to digital product documentation tools, but no entity can yet claim to be a certified or mandated DPP service provider or that they can issue DPPs as there are no DPPs for construction products yet under EU law and standards.

One of the most common questions manufacturers ask is: “If DPP isn’t mandatory yet, what should we be doing?”

The answer lies in data readiness, and here, the new CPR requirements dovetail with an existing obligation that manufacturers already know well: the Declaration of Performance (DoP).

DoPs already require structured performance data linked to harmonised standards. The emerging DPP model will build on this same core dataset — extended with lifecycle, sustainability, traceability and end-of-life information transitioning to a machine – readable Declaration of Performance and Conformity (DoPC) — but the backbone in both cases is standardised, machine-readable product information.

Put simply:

• manufacturers that have already moved beyond PDF DoPs to digitized and structured data,
• that consistently manage identifiers and harmonised attributes,
• are already building the foundation through Digitized DoP for future Digital Product Passport requirements.

This is where platforms like Cobuilder Supply, through its Digitized DoP functionality, come into play: they help manufacturers manage, validate, and publish product data in a way that aligns with current DoP practice and can help for easier transition to future DPP requirements.

Whether your DPP obligation starts in 2027, 2029, or beyond, the fundamentals of readiness are consistent:

• Standardise your data model for all products, not just a handful.
• Digitise your product information in structured, machine-readable formats.
• Ensure interoperability with industry data standards and lifecycle tools used by contractors and specifiers.

This isn’t just “regulatory compliance”. It’s a transformation toward a data-enabled business model where product data is an asset, not an administrative burden.