EU Construction Products Regulation 2024/3110: Construction DPP and Compliance Guide

The construction sector has its own Digital Product Passport — and it predates the broader ESPR rollout for most other categories. Construction is one of the most regulated industries in the EU, and the new CPR 2024/3110 stitches together CE marking, the Declaration of Performance, environmental reporting and the new DPP into a single sector framework. For producers of cement, steel, insulation, glass, doors, windows, sanitary products and the rest of the construction product spectrum, the next 24 months are about getting the data infrastructure right.

The Legal Basis: Regulation (EU) 2024/3110

The revised Construction Products Regulation, Regulation (EU) 2024/3110, replaces the 2011 CPR (Regulation 305/2011) and carries forward most of its core architecture — CE marking, harmonised European Standards (hENs), the Declaration of Performance — while adding new layers:

• Mandatory environmental performance reporting (CO2 emissions, energy consumption per kg of product) through a phased approach 2026–2032.
• The Construction Product Digital Passport (Article 76), a sector-specific DPP linked to the CE marking and the Declaration of Performance.
• Stronger obligations on online marketplaces and importers.
• Updated harmonised technical specifications (hENs) being negotiated.

The regulation entered into force on 7 January 2025 (20 days after publication on 18 December 2024) and applies to most construction products from 8 January 2026, with full mandatory compliance for priority categories by January 2028.

Why the Construction DPP Is Separate from the ESPR DPP

Construction products were historically governed by their own legal framework (the 2011 CPR). When the EU drafted the ESPR (Regulation 2024/1781) in 2022–2024, it explicitly excluded construction products from its scope, deferring to a parallel revision of the CPR. The result is two coexisting DPP frameworks:

Practically, both systems will use the same QR/NFC carrier standards and the same EU DPP Registry, but the legal obligations and content lists are defined separately.

The Compliance Timeline

• 18 December 2024 — CPR 2024/3110 published in the Official Journal.
• 7 January 2025 — CPR 2024/3110 enters into force.
• 8 January 2026 — most provisions apply to construction products (CE marking under updated rules, environmental performance reporting starts).
• 19 July 2026 — EU DPP Registry opens (shared infrastructure with ESPR and Battery Passport).
• From 2026 — Commission delegated and implementing acts are progressively adopted, defining DPP datasets, access rules, and category-specific rules.
• January 2028 (target) — full mandatory compliance for priority product categories under updated harmonised technical specifications.
• 2032 (latest) — full environmental reporting obligations phased in across all in-scope products.

Which Products Are In Scope?

The CPR 2024/3110 covers any product or kit "placed on the market for incorporation in a permanent manner in construction works." Practically, this includes:

• Cement, concrete, mortar and binders
• Steel for construction (rebar, structural sections)
• Insulation materials (mineral wool, EPS, XPS, PIR/PUR)
• Bricks, blocks, tiles and ceramics
• Wood and wood-based products for construction
• Glass for construction (flat glass, insulating glass units)
• Doors, windows and curtain walling
• Pipes, fittings and sanitary products
• Roofing materials
• Floor coverings (when used as construction products)
• Reinforcement bars, fixings, fasteners

What Data the Construction DPP Will Contain

The detailed data lists are being defined through Commission acts. From the CPR text and ongoing standardisation work, the data layers expected are:

Always public — linked to the CE marking

• Manufacturer name and contact
• Product type, model, batch
• Essential characteristics (performance per harmonised standard)
• Declaration of Performance (DoP)
• Intended use(s)
• Environmental performance: CO2 emissions per kg/m²/m³ produced, energy consumption
• Recycled content share
• Recyclability and end-of-life information
• Substances of concern (REACH SVHC, harmonised CLP classifications)

Restricted — designers, contractors, installers

• Design and installation instructions
• Maintenance information
• Lifecycle expected performance under specified conditions

Restricted — recyclers and demolition operators

• Disassembly instructions
• Hazardous substances at end-of-life
• Recycling pathways and materials recovery options

Environmental Performance Reporting (Phased 2026–2032)

The CPR 2024/3110 introduces mandatory reporting on climate-related performance indicators. The phasing is gradual and follows priority product categories. Cement, concrete, steel and insulation are expected to be in the first wave. Specific phasing dates are set in implementing acts.

Practically, manufacturers must implement an EPD (Environmental Product Declaration) under EN 15804 or equivalent for each in-scope product. These EPDs will feed directly into the DPP data layer.

How Construction Manufacturers Should Prepare

1. Audit your current CE marking. Confirm every product family has a valid Declaration of Performance under the 2011 CPR. Gaps need closing first.
2. Build an EPD library. If you don't have an EPD per product family, start now. Use EN 15804 or ISO 14025-aligned methodology. The carbon footprint data will become public.
3. Trace recycled content. For steel, glass, aluminium, plastics — recycled share data must be evidence-based. Tier-1 suppliers usually can provide it; tier-2 often cannot. Engage early.
4. Map your substances. REACH SVHC and CLP classifications need to be current. The DPP will surface this data publicly — don't get caught with outdated documentation.
5. Plan IT integration. The DPP is structured machine-readable data, not a PDF in a vendor portal. Your PIM, ERP, and document management need to feed a DPP-compatible data layer.
6. Watch hENs work. The harmonised European Standards being updated under the new CPR are the technical backbone. CEN/CENELEC working groups publish drafts throughout 2025–2027.

How This Connects to Other Sustainability Rules

• Energy Performance of Buildings Directive (EPBD recast 2024/1275) — building-level energy and carbon reporting. Construction product DPP data feeds upward into building EPCs.
• EU Taxonomy — sustainable finance reporting for buildings and infrastructure. Construction product carbon data is needed to qualify projects.
• CSRD and Scope 3 — construction giants reporting under CSRD increasingly demand DPP-grade product data. See our Scope 3 supply chain guide.
• Battery Passport (Regulation 2023/1542) — overlap for off-grid and storage products. See our Battery Passport guide.
• EU Green Claims Directive — product environmental marketing claims need regulatory-grade evidence. See our Green Claims Directive overview.

Frequently Asked Questions