Cobuilder’s Senior Digital Construction Researcher Rumela Atanasova explains some key aspects of the proposed changes to the Construction Product Regulation and the Ecodesign for Sustainable Products Regulation. How will these changes address the need for digital product information in the form of Construction Digital Product Passports?
What is a Digital Product Passport according to the Construction Product Regulation?
The aim of a Digital Product Passport (DPP) is to provide comprehensive and standardised digital information about a product throughout its entire lifecycle, facilitating transparency, data exchange, and informed decision-making among various stakeholders. Additionally, it places a strong emphasis on the product’s environmental aspects, with the aim of simplifying and enriching sustainability practices within the construction industry.
To begin with, the ESPR establishes its requirements across various industries, including electronics, batteries, vehicles, textiles, plastics, construction products, and more. In contrast, CPR addresses its requirements in a sector-specific manner, focusing on the unique challenges and demands of the construction industry. Certainly, this implies the need for alignment and shared elements, but it’s important to acknowledge that sector-specific nuances also bring differences. Hence, understanding the link and the differences between the two regulations is essential, especially given their simultaneous revision. Timely alignment has significant importance, otherwise, it could lead to confusion for actors required to comply with or be influenced by these regulations.
One of the key distinctions between the DPPs according to the ESPR and the CPR lies in their scope. The DPP aligned with the ESPR prioritises environmental performance, concentrating on a product’s sustainability impact and environmental implications across its lifecycle. On the other hand, the DPP aligned with the CPR adopts a wider perspective, covering both the environmental and technical characteristics of a construction product, and it aims to facilitate information exchange and compliance with regulatory requirements within the construction sector. Another detail worth mentioning is the term established in the CPR – construction digital product passport.
Proposed changes to the Construction Product Regulation
Several aspects that are worth highlighting in the proposed amendments to the CPR revision, as of July 2023, states that:
- Article 81a “2. The construction digital product passport shall consist of:
(a) the declaration of performance or the combined declaration of performance and conformity;
(b) the product information laid down in Annex I Part D; and
(c) technical documentation referred to in Articles 64(1), 65(1), 66(1) and Annex II point 11(b).”
- Article 81a “3. The construction digital product passport shall be accessible via electronic means through the data carrier.”
- Article 81a “6. Construction digital product passports shall be made accessible on the manufacturer’s website, database or an online platform chosen by the manufacturer of the respective products for 10 years after the last product has been placed on the market. After this time frame, the information shall either continue to be made accessible by the manufacturer or shall be transferred to the centralised Commission registry established in accordance with Article 81d.”
- Article 81b “(d) all information included in the construction digital product passport shall be based on open standards, developed with an interoperable format and shall be machine-readable, structured, and searchable, in accordance with the essential requirements set out in Article 81c. Technical documentation referred to in Article 81a(2)(c) shall be exempted from this obligation when justified for technical reasons;”
- Article 81d “1. The Commission shall set up and maintain a registry storing information included in the construction product passports by delegated acts adopted pursuant to Article 87.”
These proposed changes are under work in the Council of the European Union. Therefore, they are not permanent until the final version of CPR is published.
Digital transformation is the way forward
Considering all of this, it is clear that digital transformation is now firmly integrated into regulations, explicitly mandating the utilisation of digital data and tools. Therefore, it is crucial for stakeholders to be well-informed about the existing resources available to assist them in staying on the right track with all regulations and their requirements, in particular the standardisation work related to Building Information Modelling.
Stepping on a solid foundation
ISO/TC 59/SC 13 and CEN/TC 442 are standardisation committees with the primary objective of enhancing information exchange within construction projects through the development of specifications, standards, and reports, commonly referred to as BIM (Building Information Modelling). Within its scope, there has been special attention to a few specific standards, focusing on the development, management, and use of a common data model, called data template. These are EN ISO 23386, EN ISO 23387, EN ISO 22057 and EN 17412-1 (soon to become an ISO standard).
Stay tuned for the next article from our Research Team that will bring in the latest updates around the revision of the Construction Product Regulation and will take a closer look at how the standards for creating, managing and sharing digital construction data may contribute to the development and adoption of Construction Digital Product Passports.