The CPR Recast and Construction DPPs

Construction products reach the digital passport by a different route from almost every other sector. Rather than waiting for an ESPR delegated act, they get one through the recast of the Construction Products Regulation itself.

That matters practically, because it means the obligations attach to a framework construction manufacturers already work within rather than to an unfamiliar one.

What the recast changed

Regulation (EU) 2024/3110 replaces Regulation (EU) 305/2011. The core mechanism survives — products are assessed against harmonised technical specifications and their performance is declared — but the scope of what must be declared widens considerably.

The fourth row is the most consequential shift in principle. The original regulation declared what a product achieved without saying what it had to achieve. The recast creates a power to set minimum requirements, which changes it from a transparency instrument into a product regulation.

The declaration of performance is the foundation

A construction manufacturer placing a product covered by a harmonised standard on the EU market already produces a declaration of performance. It states which essential characteristics were assessed, by which method, and with what result.

The passport builds directly on that. It is not a parallel dataset assembled from scratch, which puts construction in a considerably better starting position than sectors where nothing comparable exists.

Environmental characteristics become declarable

The widening of essential characteristics to include environmental ones is where most new work sits. Global warming potential is the headline, and it arrives alongside other lifecycle indicators.

These are not new to the sector — environmental product declarations under EN 15804 have been produced voluntarily for years — but declaring them under the CPR moves them from a marketing document into a regulated performance statement carrying the liability that implies.

• Global warming potential across defined lifecycle modules, not a single headline figure.
• Other impact categories where the harmonised specification requires them.
• Recycled and reused content, where relevant to the product type.
• End-of-life characteristics including whether the product can be separated and recovered.

The first point is frequently underestimated. A lifecycle figure is only interpretable with its module boundary stated, and a number covering cradle to gate is not comparable with one covering cradle to grave however similar the two products are.

Systems of assessment decide who signs

Construction products are assigned to systems of assessment and verification of constancy of performance, numbered from the most stringent to the least, and the assignment determines how much third-party involvement is required.

At the stringent end a notified body assesses the product and audits factory production control continuously. At the other end the manufacturer declares performance on the basis of its own testing. The same product characteristic therefore carries very different assurance depending on the product it belongs to.

For the passport this matters because a declared value should be readable together with how it was verified. A figure assessed by a notified body and one self-declared are both legitimate and they are not equivalent evidence.

Reuse and remanufacture get a route

The recast addresses used products explicitly, which the original regulation did not. This is significant for a sector where reclaimed structural material has historically been difficult to place back into regulated use.

A steel section whose original declared performance remains retrievable is a materially different proposition from an identical section without that record. This is the clearest case in any sector of a passport creating value rather than merely recording it.

What manufacturers should do now

The sequence that works starts with data structure rather than with new testing, because the testing has largely already happened.

Convert declarations of performance from documents into structured records keyed to a product identifier. Establish where environmental characteristics will come from, since EN 15804 declarations may exist for some products and not others. Then confirm the system of assessment applying to each product family, because it determines what evidence each declared value needs behind it.