# Construction Product Passports: A Deep Dive into CPR Articles 75–80

> The new Construction Products Regulation connects product declarations, persistent digital information and BIM interoperability without turning a product passport into a building passport.

## A construction-specific passport within a wider European architecture

Regulation (EU) 2024/3110 introduces a construction Digital Product Passport framework in Chapter X, Articles 75–80. Its purpose is not to move PDFs onto QR-linked webpages, but to establish persistent, accessible, interoperable product information supporting compliance and downstream construction work. [1](https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng)

Construction is distinctive: products stay in buildings for decades, change ownership without moving, become inaccessible after installation and may later be recovered for reuse. The regulation requires compatibility with the ESPR passport while protecting interoperability with **Building Information Modelling (BIM)** — which does not make the passport a BIM model.

## Article 75: establishing the passport system

Article 75 empowers the Commission to establish the construction DPP system through delegated acts, compatible with and based on the ESPR passport. The system must resolve:

- Which actors can access particular information
- Which actors can introduce or update information
- How updates to existing passports are managed
- How intellectual property and sensitive commercial information are protected
- How the system supports safety of construction works

Detailed design not yet adopted is **expected**. Don't mistake a supplier's proposed access model for the legal one.

## Article 76: what a construction passport contains

Listed content includes the declaration of performance and conformity, general product information, instructions and safety information, technical documentation, labels and identifiers, documents required by other Union law, and carrier information for key parts.

| Information layer | Typical content | Main control |
|---|---|---|
| Product identity | Product type and identifiers | Consistent references |
| Regulatory declaration | Declared performance and conformity | Authorised approval and versioning |
| Supporting evidence | Assessments, calculations, technical documentation | Provenance and controlled access |
| Use information | Installation, safety, maintenance | Language and revision management |
| Circularity information | Dismantling or recovery information | Continued accessibility |

This is an implementation structure, not an additional statutory list.

### DoP, DoC and the combined declaration

The previous CPR centred on the declaration of performance (DoP). The new regulation uses a **declaration of performance and conformity** (Articles 13–16). Keep it legally distinct from declarations under other legislation. The passport does not replace the declaration — it is the infrastructure that makes it accessible.

## Article 77: general passport requirements

The passport links to a persistent unique identifier **of the product type** through one or more data carriers, using open standards, with machine-readable, structured, searchable, transferable data and no vendor lock-in. Don't assume battery-style item-level granularity.

End-user personal data must not be stored without explicit consent under GDPR. Linking an installed product to a household should not expose the resident.

## Article 78: essential technical requirements

Interoperability, access, information management, continued availability and protection against misuse. For decades-long product lives, ask:

1. Who maintains access if the original provider fails?
2. Can another provider take over without relabelling installed products?
3. Are historical declarations preserved?
4. Can public and restricted information be separated?
5. Can authorised updates be distinguished from the original declared record?

## Article 79: identifiers and data carriers

Separate the identifier (product type), the carrier (how it's accessed) and the resolver (where it points now). Insulation labels may disappear on installation — project records should retain the product reference and declaration version.

## Article 80: when the passport becomes mandatory

Mandatory application is linked to the act establishing the system, with an **18-month interval** after it enters into force. The CPR's general application date is not a construction DPP deadline.

| Milestone | Status and significance |
|---|---|
| 7 January 2025 | Regulation entered into force |
| 8 January 2026 | General application, subject to transitions |
| System-establishing delegated act | Detailed arrangements — timetable **expected** |
| 18 months after that act | Statutory passport application |
| Product-family transition | Assess against specifications and transitional rules |

## BIM: reference the product, preserve the building context

Store the product identifier, installed quantity, location and declaration version in the project environment, linking to authoritative product information. Owners may need what was declared at installation, not only what is published today.

## EPDs and EN 15804

EN 15804 EPDs provide structured environmental data, but an existing EPD should not automatically be treated as satisfying the new CPR's environmental declaration requirements. Map every indicator, calculation rule and verification step before reuse.

## National building passports and Level(s)

A product passport is not a building passport, renovation passport or digital building logbook. Level(s) is the Commission's building sustainability framework — six macro-objectives and sixteen indicators — not a product-passport scheme. [2](https://environment.ec.europa.eu/topics/circular-economy/levelsold/quick-introduction-levels_en) The relationship is a chain: product evidence → project quantities → building assessment → building records.

## What manufacturers should do now

- Inventory declarations, technical documentation, instructions, identifiers and environmental datasets
- Assign owners and fix inconsistent product references
- Pilot a full journey: manufacture, sale, specification, installation, maintenance, recovery
- Involve a designer, contractor and downstream user — not just your own portal
- Prioritise durable identification and demonstrable portability over an **expected** schema

## Sources

- https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng
- https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
- https://environment.ec.europa.eu/topics/circular-economy/levelsold/quick-introduction-levels_en
- https://environment.ec.europa.eu/topics/circular-economy/levels/start-using-levels_en