Figure 1. DPP and DPL concepts.

As an example of multiple ‘logbooks’, the DPL of a batch (owned by the distributor) can record information related to transports and installation in a building, and an additional DPL for each item (owned by the facility manager) can record information related to maintenance activities.

Figure 2 provides an example including a remanufactured product (see 3.10). The figure does not preclude if the maintenance is regulated or non-regulated, or if the consumption data is retrieved from sensors (IoT).

Figure 2. Aggregation of DPPs and DPLs based on the granularity of the relevant product.

Each DPL issuer is responsible for maintaining the information and establishing any relevant data management procedures. The DPL can contain regulated, confidential and/or privacy-related information, which shall be considered in the data management procedures.

The DPL must have its own unique identifier and refer to the relevant DPP_core. Where relevant, it will also include a reference to the DPP_add and/or other DPLs, defining a chain of containers. DPPs and DPLs may use different technologies or approaches for the data storage (see 3.8).

The concept of DPP generally used in literature, including information stored or modified through the lifecycle, can be considered the aggregation of the concepts of DPP_core, DPP_add, DPL_r and DPLnr. This proposed subdivision facilitates the allocation of roles and responsibilities.

3.5. Products without mandatory DPP ↑

Construction products not CE marked according to the CPR cannot issue a DoPC and will not have a ‘regulated’ DPP linked to the CPR-2024. For products not covered by a DPP-regulation, manufacturers should be able to generate a ‘passport’ on voluntary basis. However, this information must be differentiated from the regulated information. Therefore, for these products, the DPP_core should be empty and the information generated before placing the product on the market should be stored in DPP_add. The data structure for the DPP_add should be as aligned as possible with the data structure for the DPP_core. A similar structure was implemented in UNE 41316 by storing DoP data in the element DeclaredPerformance and voluntary data in the element Additional Information, as described in Aragón [25][25] Aragón, “Reliable communication of product performance information in the BIM value chain: Smart CE marking”, Spanish Journal of BIM, 2020. Available: https://www.buildingsmart.es/app/download/12726368926/Smart%20CE%20marking.pdf.

For the DPP issuer, ensuring data accuracy and integrity from upstream actors (such as materials providers) is of the utmost importance. Any inaccurate data may result in noncompliance, which risks fines and reputational damage. Decentralized technologies provide certainty regarding the identification (authenticity) of the data issuer. However, they have limited capacity to demonstrate the accuracy or reliability of the data itself. Therefore, it is essential to establish validation mechanisms, such as certification systems, verification protocols, or data integrity mechanisms along the value chain. The proof of these validations can be cryptographically stored in the chain. This possibility requires additional research.

These products can also have DPLs, linked to the DPP_add. Therefore, any product can communicate its performance using the DPP+DPL structure, even if the product family is not covered by a DPP-regulation. This approach allows for a common data structure in the whole value chain, facilitating the information flow.

3.6. Logbooks within logbooks ↑

The EPBD recast [8][8] European Union, “Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (recast)”, 2024. describes Digital Building Logbook (DBL) as a common repository for all relevant building data, including data related to energy performance such as energy performance certificates, renovation passports and smart readiness indicators, as well as data related to the life-cycle GWP.

A DBL should enhance transparency and trust, and support informed decision-making and efficient information exchange along the construction industry value chain. The study [26][26] European Commission, “Study on the development of a European Union framework for digital building logbooks”, Publications Office of the European Union, 2021. Available: https://op.europa.eu/en/publication-detail/-/publication/40f40235-509e-11eb-b59f-01aa75ed71a1/language-en, published by the European Commission, concludes that the DBL is a necessary and valuable tool whose implementation should be strongly supported given its alignment with key European priorities like the European Green Deal and the Renovation Wave, but it faces interoperability and computational complexity challenges which can be tackled via standardization.

The integration of the DPLs and the DPPs into the DBL is illustrated in Figure 3.

The DBL can be based on the BIM model of the built asset, including all the DPPs and the relevant DPLs. It can also incorporate real time information from sensors or other sources, constituting the basis for a digital twin (DTw) of the built asset. This DTw of the asset can be linked with the DPL_IoT.

Figure 3. Relationship between the DPP, the DPL and the DBL.

3.7. Roles and responsibilities ↑

3.7.1. Economic operators ↑

The proposed structure allows for an effective allocation of responsibilities based on the role of the EO. In particular:

• DPP_core: The DPP issuer (usually, the manufacturer) is the EO allowed to create, modify, or cancel the relevant DPP_core. The DPP issuer can, under certain circumstances, allow other EO to act on his behalf (for example, the authorized representative of the manufacturer) and create or modify the DPP_core, but the DPP issuer remains liable for its content. The DPP issuer is also responsible, where relevant, for the backup system and can contract a DPP-backup service provider (backup-SP). Some regulations may require to always have a DPP service provider (DPP-SP).
• DPP_add: The DPP issuer is the EO allowed to create, modify, or cancel the relevant DPP_add. The DPP issuer can delegate the creation or modification to other EO acting on his behalf, but the liability must be clarified. The backup of the DPP_add is not mandatory.
• DPL_r: The EO responsible for the fulfilment of the relevant Regulation is responsible for the creation and management of the regulated DPL. The DPL issuer is responsible for the backup system, if required (the DPP issuer can’t be made responsible for the backup of the DPL_r unless otherwise stated in a regulation). The EO responsible for the DPL_r can authorize other EOs to modify the data, but their level of access and responsibility must be defined. A single DPP can have several DPL_r, if the product is covered by different regulations affecting the use stage (operation) or the end of life of the product.
• DPL_nr: The definition of common responsibilities for EOs issuing a DPL_nr varies depending on the organizations, as there are no legal requirements particular for a product family. Regulations related to privacy and confidentiality may apply. A single DPP_corecan have several DPL_nr. The DPP can’t be made responsible for the backup of the DPL_nr unless otherwise stated in a regulation.
• DPL_IoT: This proposed logbook requires further definition before establishing roles and responsibilities. Any real-time data contained in the logbook may be sensitive, as it could reveal personal information and enable actors to determine users’ behaviour patterns. IoT and sensors present weaknesses which should be considered in the design of the system, with special attention to privacy concerns. The DPP issuer is not responsible for the backup of the DPL_IoT unless otherwise stated in a regulation. The definition of the DPL_IoT is included as a line for future research.

3.7.2. Service providers ↑

Another relevant actors are the service providers (SPs):

• DPP-SP: The DPP service provider is an organization authorized by DPP issuer to make the DPP_core data available, fulfilling all the requirements from the relevant European Regulation and delegated acts. For a distributed architecture approach in which the source data can be stored by the manufacturer, the DPP-SP makes the back-up copy available (therefore, is the backup-SP, as described in the item below). The DPP-SP can also store the primary copy of the DPP_core on behalf of the EO placing the product on the market (DPP issuer). The final approach for SP according to the ESPR will be defined in delegated acts. For products covered by the CPR, the data storage (primary and, if relevant, backup) will also be defined in a delegated act. This delegated act will be partially based on the feasibility study for the CPR-DPP system conduced by Tecnalia, Cobuilder, and UNE [27][27] European Commission: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, “Cobuilder, Tecnalia and UNE Normalización Española, Feasibility study on the establishment of the Construction Products Regulation (CPR) Digital Product Passport (DPP) system”, Publications Office of the European Union, 2025. Available: https://op.europa.eu/en/publication-detail/-/publication/cf329d5e-3464-11f0-8a44-01aa75ed71a1/language-en.
• Backup-SP: The backup service provider is the organization that stores the DPP_core copy. EOs can, on voluntary basis, use a SP to store a backup of the DPLs or the DPP_add.

The need for DPP-SP and backup-SP, together with relevant requirements, will be established in delegated acts and may require certification. It should be possible to transfer DPP data from an SP to another without any technology or vendor lock-in.

Any confidential data stored outside the DPP issuer premises (including backups) must be protected by the SP to prevent leaks of information that could compromise the intellectual property. Concerns have been raised by industry regarding data ownership and sovereignty when management, security and access rights are not within their control. On the other hand, SPs must cooperate with the market surveillance authorities and facilitate any action required to mitigate the risks posed by products with data available through their systems. The balance between data availability for market surveillance purposes and data confidentiality is sensitive and requires dedicated research.

SPs can provide additional functionality beyond the management or backup of the DPP_core. It would be advisable to store the DPP_add in the same system and with the same technology. The DPLs can be stored in the same SP as the DPP_core or in other SP, and they can use the same or different technologies.

3.8. Centralized, federated and decentralized approaches ↑

The feasibility study for the CPR-DPP system [27][27] European Commission: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, “Cobuilder, Tecnalia and UNE Normalización Española, Feasibility study on the establishment of the Construction Products Regulation (CPR) Digital Product Passport (DPP) system”, Publications Office of the European Union, 2025. Available: https://op.europa.eu/en/publication-detail/-/publication/cf329d5e-3464-11f0-8a44-01aa75ed71a1/language-en analysed three options for the storage and management of DPPs:

1. Centralized database managed by the European Commission.
2. Distributed system using authorised DPP-SPs (federated).
3. Decentralized system: primary DPP stored by the manufacturer and mandatory copy in a backup-SP.

The Commission is expected to adopt a delegated act with the definition of the data storage for the CPR, including the requirements for the SPs in case they are legally established. A delegated act for the requirements for the SPs for the ESPR-DPP is also under development.

Regardless of the option selected by the Commission for the storage and management of the DPP_core, the DPLs can follow a different approach and use different technologies. A distributed approach, which may be supported by a blockchain framework, can provide the modular architecture, transparency and adaptability required by DPLs with complex interactions between different actors. Hulea, Miron & Muresan [28][28] M. Hulea, R. Miron, and V. Muresan, “Digital Product Passport Implementation Based on Multi-Blockchain Approach with Decentralized Identifier Provider”, Applied Sciences, vol. 14, no. 11, p. 4874, 2024. https://doi.org/10.3390/app14114874 analysed the management of DPPs using a blockchain network and decentralized identifiers (DID). For regulated information, the location of the server may have limitations which can affect blockchain. Diego & Gutiérrez-Aguero [29][29] S. Diego and I. Gutiérrez-Aguero, “Decentralized Digital Product Passport Building Blocks for Enhancing Supply Chain Sovereignty and Circular Economy Practices”, IEEE Access, vol. 13, pp. 137973-137985, 2025. https://doi.org/10.1109/ACCESS.2025.3594826 provides additional insights into the use of the Asset Administration Shell (AAS) for decentralized DPP management.

For the DPL issuer, one of the technical challenges lies in the management of dynamic data, such as installation details or maintenance records, in which different EOs may interact. Although the DPP-SP may provide a system to manage the DPLs attached to a DPP, fully decentralized solutions managed by the DPL issuer may be preferable when they want to retain full control of the data or when privacy requirements apply. The DPL issuer may grant editing rights to other operators, subject to specific restrictions and supervision.

The number of construction product manufacturers in the EU, estimated at around 430 000 [30][30] European Parliament, “Revision of the Construction Products Regulation”, European Parliamentary Research Service, 2024. Available: https://www.europarl.europa.eu/RegData/etudes/BRIE/2022/739243/EPRS_BRI(2022)739243_EN.pdf, clearly exceeds the number of manufacturers covered by other regulations, such as those for batteries. Another sector with a huge number of manufacturers is the textile industry, but they will probably diverge significantly in the use and access to DPP data compared to the construction sector. Therefore, the design of the DPP+DPL system for each industry must consider the differences in the generation and use of data in their value chain and may have some differences.

3.9. Management of LCA-based environmental data ↑

The main challenge associated with LCA (life cycle assessment) implementation for environmental assessment, according to the ranking presented in the study [31][31] O.I. Olanrewaju, W.I. Enegbuma, M. Donn and O.N. Oyefusi, “Assessment of environmental product declaration and databases: Towards ensuring data quality assurance practices”, Environmental Impact Assessment Review, vol. 112, no. 107803, pp. 502-528, 2025. https://doi.org/10.1016/j.eiar.2024.107803, is ‘Problems with data availability and quality for LCA’. Improving access to reliable product data should reduce the cost of the environmental assessment of buildings and infrastructure, using BIM and other digital tools to support the calculations. Therefore, the inclusion of EPD-data into the DPP (and the DPLs) can have a significant impact on reducing the resources needed for the LCA of built assets.

LCA-based environmental indicators will be included in the DoPC and, therefore, in the CPR-DPP. These indicators are presented in Environmental Product Declarations (EPDs) on a voluntary basis. In the future, some products will have the obligation to include it in the DoPC in Europe. Therefore, today all products can include EPD-data on the DPP_add and, when applicable, this information will be stored in the DPP_core.

The same data structure should be used in for both containers (DPP_core and DPP_add), and also in the DPLs when storing LCA-based data. For construction products and services, ISO 22057 [32][32] International Organization for Standardization, “ISO 22057:2022 Sustainability in buildings and civil engineering works. Data templates for the use of environmental product declarations (EPDs) for construction products in building information modelling (BIM)”, 2022. should be used to digitalize this environmental LCA-based information. This international standard is currently under revision.

DPLs can be used to store actual lifecycle information after the product is placed on the market (e.g. the transport to the site, correcting the assumptions based on averaged data made by the manufacturer in the LCA). This approach will facilitate more precise environmental assessments for built assets.

The data structure for this information is more complex than that of simple measured performance characteristics, as the results are linked with scenarios and assumptions that are needed to interpret them. The limitations for the automatic transfer of EPD-data have been analysed in Aragón & Alberti [33][33] A. Aragón and M.G. Alberti, “Limitations of machine-interpretability of digital EPDs used for a BIM-based sustainability assessment of construction assets”, Journal of Building Engineering, vol. 96, no. 110418, 2024. https://doi.org/10.1016/j.jobe.2024.110418, which provides a list of topics to solve in current formats. Current systems such as OpenDAP or databases integrated in the InData network [34][34] S. Otero, S. Montilla, J.A. Tenorio, G. Sotorrio, T. Garnica, B. Abad and M. Conde, “European Environmental Databases. OpenDAP, Spanish context”, Acta Polytechnica CTU Proceedings, 38, 131–137, vol. 38, 2022. https://doi.org/10.14311/APP.2022.38.0131 should also consider machine-interpretability in their implementations. A dedicated research for IFC 4.3, the main data structure used in BIM, was conducted in Aragón, Spudys, et al. [35][35] A. Aragón, P. Spudys, D. Pupeikis, Ó. Nieto and M.G. Alberti, “Bridging interoperability gaps between LCA and BIM: Analysis of limitations for the integration of EPD data in IFC”, Buildings, vol. 15, no. 15, 2025. https://doi.org/10.3390/buildings15152760. The automation of the integration of this environmental information will support the implementation of policies such as the EPBD recast [8][8] European Union, “Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance of buildings (recast)”, 2024., which requires the calculation of the global warming potential according to EN 15978 [9][9] European Committee for Standardization, “EN 15978:2011 Sustainability of construction works - Assessment of environmental performance of buildings - Calculation method”, 2011. for new buildings since 2030. The European standard EN 15978 has been reviewed and the new version approved in October 2025. EN 15978:2026 was published in March 2026.

3.10. Rebranding, modifications and remanufacturing ↑

If the EO places a product requiring a DPP in the EU Single Market, the EO must issue a DPP according to the relevant regulation and, in principle, assumes the responsibility for its conformity. This requirement also applies to rebrands (an importer or distributor placing a product on the EEA under its own name or trademark) or modifications affecting the performance or the conformity with the requirements established in the relevant regulations).

EOs placing a remanufactured secondary product in the EEA will also issue a DPP and assume responsibility for the information declared. CEN/TC 350 standards applied the polluter pays principle by allocating all the environmental burdens to the primary product. Therefore, if its waste enters into a new system as a recycled product, it does not need to incorporate any burden until the end-of-waste state is reached. A similar approach is applied in the CPR for remanufactured products, as they did not include events before the product’s last deinstallation when calculating the environmental impact. There are differences including, for example, the transport to the recycling facility, but it is beyond the scope of this paper.

These cases may require traceability to the original DPP and, where relevant, all the DPLs which may affect the performance or the compliance of the rebranded, modified, or remanufactured product.

4. LINES FOR FUTURE RESEARCH ↑

The following lines for future research have been identified during the study.

1. Compatibility of DPPs of products installed in construction assets covered by different DPP-regulations: Products covered by regulations other than from the CPR are installed in buildings and infrastructure, such as lighting systems, elevators, or batteries. The management of their DPPs in the context of the asset should be analysed. This analysis should consider potential differences in relation to the content or data structure. This compatibility should support the use of DPP data to perform environmental assessment or other calculations using BIM.
2. Interoperability and semantic alignment: The publication of regulatory data requirements across sectors poses significant interoperability challenges. A horizontal mechanism based on a sector-agnostic semantic layer can mitigate this issue by allowing sector specific semantic-defined data points to be declared and be interoperable. In particular, the approach of decoupling the semantic definitions and keeping them into a controlled vocabulary as defined in ISO 25964-1 [36][36] International Organization for Standardization, “ISO 25964-1:2011 Information and documentation — Thesauri and interoperability with other vocabularies — Part 1: Thesauri for information retrieval”, 2011.. As an example, the EU has centralized vocabularies [37][37] European Union, “EU Vocabularies” [Online]. Available: https://op.europa.eu/en/web/eu-vocabularies [Accessed 05 October 2025]. which can improve the cross-sector interoperability paradigm.
3. Asset Administration Shell (AAS): The AAS is a standardized digital representation of an asset defined in IEC 63278-1 [38][38] International Electrotechnical Commission, “IEC 63278-1:2023 Asset Administration Shell for industrial applications - Part 1: Asset Administration Shell structure”, 2023. which can be used to exchange product data in the value chain. The AAS can be used to manage multiple DPLs related to a DPP using an asset ID. Further research is necessary to define roles and data flows, ensuring that data is persistently available and findable. Lecture and editing access must be based on predefined rights which, in some cases, will be globally assigned (e.g. market surveillance authorities).
4. Validation of the information in distributed systems: The DPP_add for products not required to issue a mandatory DPP (and therefore without the DPP_core) and the DPLs may be stored in distributed systems supported by distributed ledger technologies (see 3.5 and 3.8). The quality and veracity of the data is of the outmost importance and, therefore, a proof of validation, issued by a third party (e.g. a verifier, a certification body or a test laboratory), can be included in the chain. The management of this proof of validation requires additional research for its implementation in the DPP system.
5. Integration of DPPs and DPLs into the environmental assessment of built assets: The information from passports and logbooks constitutes the basis for any life cycle assessment of buildings or infrastructures. The indicators calculated according to EN 15978 can be based on LCA-data provided in DPPs and DPLs. The automatic integration of this data at built asset level requires further research to reduce the resources required for the environmental assessment. This information can also be used to analyse the operational energy performance according to CEN/TC 371/WG 5 developments. The integration of the IoT-DPL in the context of this energy performance calculation requires additional research and standardization.
6. Modifications and software updates made by the manufacturer: Under certain conditions, the manufacturer can modify the performance of the product once placed on the market (for example, an official software update). In some cases, the implementation of these modifications will not be under the control of the DPP issuer (e.g. the customer may decide not to apply the update). Therefore, the allocation of this information to the DPP_core or to a DPL requires additional research.
7. Definition of the IoT-DPP and relation with DBLs and the DTw of a construction asset: Any real-time data from built assets will impact privacy of the users of the building or infrastructure and, therefore, additional research will be needed to ensure that their data is protected. The integration between the Digital Product Twin (DPT) and the Digital Twin (DTw) of the building should also be analysed.
8. Business confidentiality: The DPP_core data must be available for market surveillance authorities. However, the DPP may contain sensitive proprietary information including the composition of a product, manufacturing processes information, or the identification of raw materials suppliers. It is imperative to establish effective mechanisms to safeguard intellectual property.
9. Privacy: The DPP and the DPL may contain personal data (information contact details, users’ pattern behaviour, etc.). Therefore, requirements from the data protection regulations can apply. It is necessary to identify the different typologies of personal data which can be stored in DPPs or DPLs, the related threats, and the measures to mitigate them.
10. Transition from legacy IT infrastructure: The resources required to transfer data from current tools and formats (ERP, PLM, CAD files, etc.) into the DPP system imposes important challenges for manufacturers, especially SMEs. The identification of the main gaps for the transfer from current systems into the DPP and how these gaps can be bridged requires additional research.

5. CONCLUSIONS ↑

This research analyzed the roles and obligations related to the DPP of products installed in buildings and infrastructure. This paper proposes splitting the expanded concept of DPP used on scientific and industrial literature in terms of allocation of responsibilities, differentiating the restricted DPP concept used in EU Regulations. The objective is to clearly define the allocation of responsibilities in the product value chain; particularly those related to placing the product in the EEA. This paper proposes a new concept, the ‘digital product logbook’ (DPL).

The restricted concept of ‘digital product passport’ proposed in this paper is based on based on the CE marking defined in the New Approach policies, as it has been the ‘product passport’ in the last decades, ensuring the free movement of goods in the Single Market. Therefore, the DPP should only contain the information required to place the product on the market. Other valuable information generated along the value chain is stored in the ‘digital product logbook’ by different EOs. The roles and responsibilities differ between ‘passport’ and ‘logbook’.

This paper proposes two containers for the ‘passport’ (DPP_core and DPP_add) and three containers for the ‘logbook’ (DPL_r, DPL_nr and DPL_IoT), as described in section 3. This structure provides the required distinction between the EO placing the product in the EEA (the DPP issuer) and any other EO attaching lifecycle-related information (DPL issuers), and between regulated and non-regulated data (see Figure 1).

The results include a description of functions and responsibilities for the service providers in relation to the ‘passport’ and ‘logbook’, and proposes different approaches in the data storage combining a federated approach with service providers for the DPP and a fully distributed approach for the DPLs, which should ensure interoperability.

This paper also intends to trigger research on topics such as the relation between the DPP and the ‘digital building logbook’ (therefore, between the product and the asset in which they are installed), the management of data through the life cycle using the AAS and/or distributed systems, and the consideration of privacy concerns. These topics are listed in section 4.

The terminology proposed in this paper can be modified to strengthen the connection with the broader concept of DPP found in literature. An alternative naming convention could use the same acronym “DPP” adding the subscript letters ‘lg’ for logbook, incorporating an acronym for each module, as follows:

• DPL_r can be called DPP_lg,r.
• DPL_nr can be called DPP_lg,nr.
• DPL_IoT can be called DPP_lg,IoT.

The standards under development in CEN/CLC/JTC 24 and in CEN/TC 442 constitute the foundations of the DPP system and the approach will be applicable to the new containers proposed. As the implementation of the concept of DPL and its management will largely rely on private implementation of these concepts, new standards may emerge from the actual experiences derived from this implementation.

Both industry and citizens will benefit from a transparent allocation of roles and responsibilities, based on a clear structure for the digital product ‘passport’ and ‘logbook’. The DPP+DPL system can provide straightforward access to all relevant product data, including information on its origin, composition, environmental footprint, and maintenance instructions. It will facilitate both public and private procurement processes, taking environmental criteria into consideration. It can also support the right to repair in line with the Directive on the repair of goods  [39][39] European Union, “Directive (EU) 2024/1799 of the European Parliament and of the Council of 13 June 2024 on common rules promoting the repair of goods and amending Regulation (EU) 2017/2394 and Directives (EU) 2019/771 and (EU) 2020/1828”, 2024. Available: http://data.europa.eu/eli/dir/2024/1799/oj or the calculation of the GWP according to the EPBD recast. The DPP (and the DPLs) can be integrated into the ‘digital building logbook’, ensuring a record to improve facility management of built assets.

Supplementary information ↑

Funding sources

Not applicable.

Supplementary material

Not applicable.

Data availability

Not applicable.

Acknowledgements

The authors would like to express their gratitude to Óscar Nieto and Manuel Achúcarro for their revision of the manuscript.

Authorship contribution statement

Aitor Aragón: Conceptualization, Formal analysis, Funding acquisition, Investigation, Methodology, Project administration, Writing – original draft, Writing – review & editing.

Vincenzo Daponte: Conceptualization, Formal analysis, Funding acquisition, Investigation, Methodology, Writing – review & editing.

Competing interests

The authors of this article declare that they have no financial, professional or personal conflicts of interest that could have inappropriately influenced this work.

Statement on the use of Artificial Intelligence

Not applicable.

NOTES ↑

REFERENCES ↑

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