The new Construction Products Regulation (EU) 2024/3110 establishes a dedicated Digital Product Passport system for construction. It must interoperate with the ESPR DPP without obstructing Building Information Modelling. Manufacturers therefore need a data bridge from the product model through the building lifecycle to deconstruction, not another archive of PDFs.
A DPP system connected to the building lifecycle
Article 75 requires the European Commission to establish the construction DPP system through delegated acts. It must be based on the horizontal DPP framework under ESPR while reflecting the characteristics of construction products.
This matters because a construction product usually becomes part of a long-lived assembly. A window, insulation product or precast element is designed, delivered, installed, maintained and potentially removed for reuse. Product information needs to survive beyond the sale and remain usable in planning and building-data systems.
The Commission's indicative DPP timeline lists requirements for construction products and DPP service providers for the second quarter of 2027. Detailed rules are still being developed, but the basic architecture is already in the Regulation.
Information connected by the passport
Article 76 includes, among other elements:
- the declaration of performance and conformity,
- general product information and use and safety instructions,
- technical documentation,
- the required label,
- unique identifiers,
- documentation required under other applicable Union law,
- data carriers of key parts where those parts have their own DPP.
The passport generally corresponds to the product type and its unique identification code. Information must be accurate, complete and up to date. Different actors receive different access rights and, depending on their role, may introduce or update information.
DPP and BIM have different responsibilities
A BIM model describes a building and its components in a project context. The DPP describes the product and its regulatory data across the lifecycle. The systems should reference each other, but not duplicate each other's content.
A practical pattern is:
- The manufacturer assigns a persistent product identifier.
- The DPP provides authoritative product and conformity data.
- The BIM object stores the identifier and project-specific installation information.
- Updates to the passport remain accessible through the same reference.
- During deconstruction, the component can be matched to its product type and relevant data again.
Copying full technical files into every BIM model creates stale versions. Storing an ordinary web link without a stable identifier risks link loss. A durable, machine-readable reference with clear data ownership is the stronger middle path.
Open standards and no vendor lock-in
Article 77 requires open standards, interoperable formats and machine-readable, structured, searchable and transferable data. Article 78 adds security, privacy, integrity and trade-secret protection.
When procuring a DPP service, construction-product manufacturers should ask at least:
- Can all data and identifier mappings be exported?
- Do URLs and identifiers remain stable when providers change?
- Are APIs documented and formats open?
- Can public, project and authority access be separated?
- Are changes versioned and auditable?
- What backup applies after insolvency or cessation of activity?
The Regulation also prevents service providers from selling, reusing or processing hosted DPP data beyond what is necessary to provide the service unless the economic operator specifically agrees.
Long availability changes system selection
Construction products remain in use for decades. The Regulation requires the system to remain accessible for 25 years after the last product of a type is placed on the market, while the economic operator is to provide the passport for at least ten years. Detailed implementation will follow in the construction DPP system.
These periods are longer than typical software contracts. Companies therefore need:
- portable data and media,
- documented transfers of responsibility,
- an independent backup,
- durable domains and identifiers,
- processes for product changes, successors and discontinuation.
Operation must not depend on one employee account or a non-transferable short-term contract.
Roles across the construction lifecycle
Manufacturers, authorised representatives, importers and distributors have different responsibilities from designers, clients, installers, deinstallers and authorities. The future system will define who may see which information and who may change it.
Manufacturers should represent these roles in their data model now. Public performance data do not belong in the same access channel as confidential technical documentation. A deinstaller needs different information from a market-surveillance authority. Role-specific views should nevertheless refer to the same product identifier.
What manufacturers can prepare now
- Model product types, variants and key components unambiguously.
- Convert performance and conformity information from PDFs into structured fields.
- Define a stable reference between product master, DPP and BIM object.
- Outline access roles for designers, customers, authorities and deconstruction.
- Make export, APIs, backup and provider portability mandatory in procurement.
- Pilot one product made up of several DPP-relevant components.
The construction DPP becomes valuable when it does not stop at the factory gate. The Regulation sets a clear direction: open data, durable identity, differentiated access and interoperability with BIM. Companies can implement those foundations before all detailed acts are adopted.
