Construction products sold in the EU will need a Digital Product Passport under the recast Construction Products Regulation, with requirements phasing in through delegated acts. For coatings and materials makers, preparing means getting composition, sourcing, and embodied-carbon inputs structured and connected now, so a passport can be generated from live data rather than rebuilt by hand.
Construction is one of the clearest examples of the Digital Product Passport moving beyond batteries. A Digital Product Passport (DPP) is a structured digital record of a product's key information, accessed through a data carrier on or with the product. The recast EU Construction Products Regulation (CPR), Regulation (EU) 2024/3110, introduces a construction-specific Digital Product Passport, delivered through a dedicated system and connected to a data carrier. For the coatings, adhesives, sealants, and specialty-materials teams that supply the built environment, that means the composition and environmental data behind every product will need to be structured, verifiable, and ready to publish.
What Will the Construction Digital Product Passport Require?
The construction DPP centers on composition, origin, embodied carbon, and reuse or recycling potential, made accessible across the value chain through the construction DPP system. In practice a coatings or building-materials producer will need a verifiable record of what a product is made of, where its inputs came from, its environmental footprint including embodied carbon, and how it can be reused or recycled at end of life. Much of this overlaps with the Environmental Product Declarations (EPDs) the sector already produces, but the passport raises the bar on how connected, current, and auditable that data must be.
Why Is Embodied Carbon So Hard to Report Today?
Embodied carbon, the greenhouse gas emissions associated with making a product and its inputs, and other lifecycle data are only as reliable as the formulation and sourcing records they are calculated from, and in most R&D organizations those records are fragmented. A single coating is a system of resins, pigments, additives, and solvents, each with its own supplier, lot, and footprint, and the formulation changes over time. When the composition, the supplier data, and the test results live in separate systems, every carbon figure and every EPD becomes a manual assembly exercise, and every reformulation risks leaving the environmental data out of date. That is the gap the passport will expose.
How Connected R&D Data Supports the Construction Passport
When formulation, raw materials, suppliers, lots, and performance results live on one connected record, the inputs a passport and an EPD depend on stay accurate and traceable as the product evolves. A change to a pigment or resin filters through the affected formulations, and the composition and sourcing behind any product revision can be queried rather than rebuilt. Uncountable is built to hold that foundation, the connected thread from raw material through formulation to finished product. It does not calculate your embodied carbon or issue the passport itself, but it keeps the composition, provenance, and test data that a lifecycle assessment (LCA, the method used to calculate a product's environmental footprint) and a passport draw from structured and current, so the environmental record reflects what you actually make today.
What Coatings and Materials Teams Should Do Now
Coatings and materials teams should get the formulation and sourcing data connected before the delegated acts land. The CPR framework is already in force and its passport requirements phase in through delegated acts, so the products and dates are being set now. Teams that structure composition, supplier, lot, and performance data on one record, and capture change history as it happens, will be able to generate a passport and keep EPDs current as a matter of routine. The same foundation also speeds reformulation and makes sustainability claims defensible, value that lands well before the passport is mandatory.
How to Prepare a Coatings Formulation Record for the Passport
Preparing for the construction DPP is mostly a data-structuring exercise that R&D and product stewardship teams can start now. A practical sequence for one product family:
- Map where composition, supplier, and test data currently live, and note which figures are copied by hand into EPDs today.
- Record each formulation's raw materials as structured data, with supplier, grade, and lot, rather than as a document or spreadsheet.
- Link supplier documentation, such as composition and environmental data, to the raw material it describes, with the version and date it applies to.
- Capture formulation changes as controlled revisions, so you can tell which product version an EPD or lifecycle figure was based on.
- Agree who owns each data field, so the record stays current after the first passport is produced.
For example, a coatings maker replacing a resin for supply reasons would want to see straight away which products use it, which EPDs drew on its data, and which environmental figures now need updating. Without connected records, that check depends on someone remembering where the numbers came from.
A common mistake is treating the passport as a reporting project for the sustainability team alone. The data it relies on is created in R&D and procurement, so the record has to be built where the formulation work happens. The same principle applies across construction materials, from adhesives and sealants to lower-carbon cement.
Why Construction Passport Readiness Starts With Structured Data
The construction passport turns environmental data from a periodic reporting task into a live requirement. Coatings and materials makers that keep their composition and sourcing data connected will meet it without slowing R&D. Those that leave it fragmented will find every passport, and every EPD, is a rebuild. Structure first.
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