How the Digital Product Passports Bring (Building) Material Passports Into Reality

Material passports have been part of the built environment conversation since the mid-2010s. The Netherlands built pilots into major urban regeneration projects. Belgium embedded them into public procurement. Scandinavia developed frameworks. Researchers published extensively. The concept was never the question; it was clear, compelling, and correct: document every material in a building, its composition, location, embodied carbon, recycled content, disassembly potential and you transform demolition from a waste event into a resource recovery operation. A structural steel beam isn’t rubble. It’s a documented asset with a known carbon value and a verified path to reuse.

The industry knew this. It agreed with it. It just couldn’t act on it at scale, because the three conditions required for any tool to move from voluntary best practice to standard operation were all absent at once:

What Material Passports Were Waiting For

A mandate: Without a legal requirement, material passports were a flagship-project gesture. Procurement pressure and cost constraints meant they stayed optional and optional tools don’t scale in construction.

A standard: Pilots across Europe used incompatible data fields, formats, and platforms. A passport produced in Amsterdam couldn’t be read by a database in Brussels. The framework existed; the interoperability didn’t.

A consequence: There was no moment in a project’s lifecycle where the absence of a material passport cost anyone anything. No penalty, no exclusion, no commercial disadvantage. So the incentive to produce one simply wasn’t there.

The EU’s Digital Product Passport regulation provides all three simultaneously. A legal mandate across 27 member states. Standardised, machine-readable data requirements defined in law. And a market consequence with real teeth: no compliant passport, no EU market access. The tool hasn’t changed. The conditions around it have.

For architects, this means the materials you specify will need to carry this documentation as a condition of being on the EU market not as a sustainability gesture, but as a legal requirement. For developers, the buildings you commission will have a material record that affects their circularity value, compliance standing, and asset value at end of life.

The DPP isn’t a reaction to a new problem it’s the regulatory architecture that puts a decade of material passport thinking into enforceable practice. It’s embedded across two pieces of EU legislation working in tandem. The Ecodesign for Sustainable Products Regulation (ESPR, Regulation EU 2024/1781) entered into force in July 2024 and establishes the horizontal DPP framework across the entire EU economy. The revised Construction Products Regulation (CPR, Regulation EU 2024/1305), adopted in December 2024, tailors those requirements specifically to the built environment. Together, they do what a decade of voluntary pilots couldn’t: make the digital material record a legal condition of market access.

The 18-month preparation window that applies after each delegated act sounds generous. It isn’t. Building the data infrastructure standardised product records, digital identifiers, lifecycle traceability takes time that most manufacturers haven’t started spending. The clock is already running.

What the Passport Actually Contains

The concept of a material passport has always described the same thing: a complete, accessible digital record of what a building is made of, where those materials came from, and what happens to them when the building’s life ends. The DPP operationalises that description into mandatory, standardised, machine-readable fields accessible via QR code, NFC, or API, and required to remain live for a minimum of 5 to 10 years post-sale. Here’s what one looks like in practice:

Every field in that card is a mandatory disclosure requirement under ESPR and CPR. The business placing the product on the EU market is legally responsible for its accuracy and that record must remain accessible long after the sale is complete.

EPDs Feed In. The Passport Goes Further.

If your team has been doing the work on embodied carbon specifying EPD-backed materials, building lifecycle carbon into design decisions that work is directly relevant here. EPDs don’t get replaced by DPPs; they get incorporated. EN 15804+A2-compliant EPD datasets are explicitly expected to feed into the DPP framework for construction products. An EPD provides the carbon chapter of a product’s passport. The passport itself is the full document: composition, origin, circularity attributes, disassembly potential, chemical disclosure, and regulatory compliance, all in a single interoperable record.

Teams that have been building EPD discipline have a meaningful head start their carbon data is already structured and third-party verified. The DPP extends that work upward: origin traceability, circularity metrics, chemical disclosure, unique digital identifiers. The direction has always been toward this. The regulation is what closes the gap between intention and requirement.

The Gap the Regulation Exposes

The DPP doesn’t create the industry’s data problem, it reveals it. The requirement for structured, standardised, machine-readable product data across the full passport scope isn’t new in concept. What’s new is that it’s now law, and the gap between what the industry has and what the regulation requires is suddenly measurable. A 2025 peer-reviewed study in Building & Environment found no unified approach to DPP data content in construction. A separate systematic review of 549 papers found fragmented data architectures and lack of interoperability as the primary barriers to scalability. The passport framework was ready. The data infrastructure behind it wasn’t.

The Opportunity in the Gap

The DPP requires product-level data infrastructure to exist before enforcement arrives which means the companies structuring their data now are building compliance readiness as a byproduct of doing good work. Manufacturers with verified, structured product data already have the foundation. The question is how much of the rest of the passport they can fill. Those who haven’t started will be building under pressure once the delegated acts land.

What the Research Confirms

The academic community has been tracking material passports closely for years and as the DPP regulation has sharpened, so has the research. The consistent finding across recent literature is that the concept is sound and the use cases are well established. What the studies identify now are the practical conditions required to take it from proven pilots to infrastructure at scale.

1. Materials Sustainability (Nature, 2025) — Eight Recommendations for Material Passport Adoption

1. European Commission. Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. July 2024.
2. European Commission. Construction Products Regulation (CPR), Regulation (EU) 2024/1305. December 2024.
3. Charef, R. et al. “Eight recommendations to adopt materials passports.” npj Materials Sustainability, 2025. nature.com
4. Jensen, P. et al. “Stakeholder perspectives on DPPs for construction.” Building & Environment, 2025. sciencedirect.com
5. Markou, I. et al. “Current methodologies of creating material passports.” Case Studies in Construction Materials, 2025. sciencedirect.com
6. “Digital material passports in the AEC industry: a scoping review.” Taylor & Francis, 2025. tandfonline.com
7. UKGBC. “EPDs and Materials Passports in Circular Construction.” 2025. ukgbc.org
8. One Click LCA. “Digital Product Passport: What’s a DPP.” 2025. oneclicklca.com
9. ESPR Working Plan 2025–2030. European Commission, April 2025.
10. Digital Construction Week. Material Passports: Data Infrastructure for the Built Environment. 2024.