IN Brief:
- Mandatory EU digital passports begin affecting construction products from 2027.
- The consultation considers traceability, compliance, sustainability data, and business costs.
- Separate arrangements for Great Britain, Northern Ireland, and the EU could add complexity.
The Department for Business and Trade has opened a call for evidence on digital product records, including their potential effect on construction-product manufacturers, importers, distributors, recyclers, merchants, and contractors.
Open until 11.59pm on 21 September 2026, the consultation is examining how product information is currently managed, how forthcoming European requirements could affect UK businesses, and whether a domestic record system should be developed for goods placed on the Great Britain market.
Digital records could make compliance information, sustainability data, supply-chain documentation, and product identification available through a common technical architecture. The first mandatory European Union Digital Product Passport requirements covering batteries and construction products are expected to begin entering force in 2027.
Under the Windsor Framework, relevant European requirements will also apply in Northern Ireland. Manufacturers serving Great Britain, Northern Ireland, and European Union markets may therefore need to manage different regulatory arrangements for products leaving the same production line.
Depending on the final sector rules, supply-chain businesses could be required to create and maintain records throughout a product’s lifecycle, apply a physical data carrier such as a QR code, retain supporting technical information, and register the passport within an EU system.
Material composition, manufacturing origin, environmental performance, certification, repair requirements, batch identifiers, installation guidance, and information supporting reuse or recycling could all form part of the record.
Potential benefits identified by the government include more efficient supplier checks, improved auditability, faster recalls, simpler cross-border compliance, stronger transparency, and better management when products reach the end of their initial service life.
Businesses are also being asked to estimate the cost of introducing new systems, training staff, collecting data, engaging suppliers, applying labels, maintaining documentation, and securing external technical support. Respondents can indicate whether transition or annual expenditure is likely to exceed £100,000.
The consultation follows proposals for broader reform of construction-product regulation, including stronger oversight, clearer responsibilities, and greater use of digital information as new standards are adopted.
Construction begins from a particularly fragmented information base. A completed building can contain thousands of products assembled into systems that pass through manufacturers, distributors, merchants, specialist contractors, principal contractors, designers, and facilities teams.
Relevant data is frequently divided between declarations of performance, product sheets, safety information, environmental declarations, installation manuals, warranties, certification databases, BIM objects, and project handover records. Naming conventions differ, information is duplicated, and the connection between documentation and the physical product can weaken once materials reach site.
A reliable digital record could reduce that fragmentation by connecting a product or batch to a consistent information set. Safety-critical elements would benefit where specifiers, installers, owners, and regulators need to establish precisely what was selected, supplied, substituted, and incorporated.
Maintaining the relationship between product and record after manufacture will be difficult. Batch changes, local fabrication, repackaging, product substitution, and assembly into larger systems can all separate the original passport from the component eventually installed.
Interoperability will be equally important because construction information already moves through specification platforms, common data environments, merchant systems, asset-management software, regulatory databases, and facilities-management tools. A passport that cannot exchange data with those systems risks becoming another isolated compliance document.
The government is consequently seeking views on whether a Great Britain system should remain compatible with European and Northern Irish arrangements, potentially through common data carriers and shared standards, or follow a distinct domestic structure.
Domestic flexibility could allow requirements to align more closely with the UK’s construction-products regime, although divergence may oblige manufacturers to create separate records for several markets. Smaller producers with limited compliance teams would carry a disproportionate share of that burden.
Commercial confidentiality will require careful treatment as well. Detailed material and supply-chain information can strengthen transparency, yet companies may be reluctant to expose formulations, supplier relationships, production locations, or commercially sensitive performance data.
A workable system would distinguish between information available publicly, data accessible to clients and regulators, and restricted technical records. Responsibility must also be clear where information is missing, outdated, or incorrectly attached to a product.
Companies supplying construction materials across the UK and Europe will need to begin mapping their information flows before every regulatory detail is settled. Product identifiers, data ownership, supplier records, software capability, and lifecycle responsibilities cannot be established reliably during the final months before implementation.
