Regulation, read in full
What is settled in law, what is still pending, and which work already falls due — taken from the regulations themselves, not from trade reports.
A digital product passport is a machine-readable record for one manufactured unit — not for the model. It carries the identifier, specification, materials, lot numbers, performance values and the evidence behind them, and it is reachable through an identifier on the product itself.
For windows and doors it is not mandatory today. The Construction Products Regulation provides for it, but the system is created only by a delegated act of the Commission — and no such act is in force. There is therefore no date from which a window manufacturer must issue a passport.
Legal status
Six points, each taken straight from the text. As of 16 September 2026.
The new Construction Products Regulation has applied since 8 January 2026. Individual articles applied from 7 January 2025, and Article 92 applies from 8 January 2027.
The old Regulation (EU) No 305/2011 is repealed with effect from 8 January 2026 — some of its articles and Annexes III and V only with effect from 8 January 2040.
The construction digital product passport system is set up only by a delegated act of the Commission. Until then, the system all further obligations refer to does not legally exist.
Six months after that act enters into force, the system must be fully operational. The obligations under Article 22(7) apply 18 months after its entry into force. For the period before that, the regulation states expressly that manufacturers may use the system voluntarily.
By 19 July 2026 the Commission establishes the central registry storing at least the unique product identifiers.
A delegated act applies no earlier than 18 months after its entry into force. Departures are provided for only in duly justified exceptional cases.
Sources: eur-lex.europa.eu/eli/reg/2024/3110/oj and eur-lex.europa.eu/eli/reg/2024/1781/oj. The Commission's own overview page gives 7 January 2026 for the CPR; Article 96 of the regulation itself governs, and it says 8 January 2026.
The deadline for windows and doors hangs on an event, not on a calendar date: the entry into force of the delegated act under Article 75. From that day there are six months until the system runs and 18 months until the obligations bite.
So anyone who wants to know how much time is left watches for the publication of that act, not the calendar. While it is pending, every year mentioned for windows and doors is an estimate — including those in the trade press.
The dates named are two years apart, and none of them traces back to a legal act. A German metalworking trade magazine runs the headline "For windows and doors from 2028" and writes that for certain important construction products the start begins as early as 2028. Other vendors and test institutes name mid or late 2028, others again 2029 or 2030.
These are estimates of when the delegated act might appear — not deadlines. Planning against them means planning against a number nobody has guaranteed.
Whatever the date: a passport cannot be invented after the fact. The data has to come into existence at the moment of manufacture.
In additional working time: nothing. Labels are printed in production anyway, and the QR code goes onto the same label in the same step. Connecting to the passport system is a one-off setup; after that the passports are issued without anyone doing anything.
This is why the question of the mandatory date weighs less in practice than it sounds. Where per-unit production data exists anyway, the passport is a by-product rather than an extra task. Where it does not exist, no deadline will help.
Common questions
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