Every building is a stack of products. Brick, insulation, window frames, a roof membrane, the fixings that hold it together. On most projects the paperwork for those products lives in a drawer, in a supplier's PDF, or in the head of the person who ordered them. The European Union has decided that is not good enough for the next fifty years of a building, and the rule that says so is now in force.
It is called the Construction Products Regulation, the CPR, and it is the law that decides how a product gets sold across the European market in the first place. Most people on site never read it, because it sits upstream of them, at the factory gate. This version reaches further down the chain than the last one.
A regulation, not a directive
The distinction sounds like lawyer's small print, and it matters. The earlier post here on the EPBD was about a directive, a European aim that each country had to turn into its own national law before it bit. The CPR is a regulation. It applies directly, the same text, the same day, in the Netherlands as in Belgium or Germany, with no Dutch version to wait for.
Regulation (EU) 2024/3110 was adopted on 27 November 2024, entered into force at the start of 2025, and repeals the old 2011 regulation it grew out of. It keeps the familiar idea, a product declares its performance so it can be sold across borders, and adds a layer the 2011 rules never had: the product's data has to become digital, structured and durable.
The digital product passport
The centre of the new CPR is the digital product passport. The plain version is this. A construction product, once it falls under the harmonised rules, carries a data record you can open with a scanner or a link, holding its technical, safety and environmental information. The Commission has been explicit that this passport is built on open, non-proprietary international standards, and that it is meant to give access to businesses, public authorities and the public alike. The point is traceability. The data follows the product along the value chain instead of evaporating at the loading dock.
None of this lands overnight. In December 2025 the Commission published its first working plan for the CPR, covering 2026 to 2029. It sets out, family by family, the timeline for the harmonised standards and the delegated acts that will make the passport real for each product group. So the honest reading today is that the framework is law, the direction is fixed, and the switch-on is phased across the coming years.
Why it reaches a Dutch site
A Dutch contractor might read all this as Brussels business, far from the pour. It is closer than it looks. Dutch practice already runs on product data. The milieuprestatie score a new building has to meet leans on the environmental data of the products in it. A KOMO or comparable certificate is a product proving it is what it claims. The dossier bevoegd gezag at gereedmelding is, in part, a file of exactly these proofs. The CPR is pointed at the same thing your Wkb dossier already needs: product information you can trust and find again.
Because the CPR applies directly, there is no separate Dutch statute to wait for, and the same is true for a Belgian or Luxembourg site. The passport, when it arrives for a product family, arrives across the Benelux at once.
The passport is about the product, not your building's compliance
The CPR governs how a product is put on the market. It does not replace the Wkb, and it does not check whether your finished building meets the Bbl. Those checks stay where they are. What the passport changes is the quality of the raw material every one of those checks feeds on.
The data has to land somewhere
A passport is a promise about data. The open question every contractor should ask is a practical one: when the product is built into a wall and the wall is closed, where does its passport live so anyone can find it two years later at gereedmelding, or twenty years later at a renovation.
A product passport is only worth having if you can find it again the day someone asks.
The building itself already has an answer to that question, and it is the model. An element in an IFC model has a stable identity and carries its own properties. It is the natural hook to hang a product's data on, the same hook a snag or a compliance rule already uses. The product data and the place it belongs are, for once, the same object.
Where we come in
To be plain about the edges: BimDossier does not check the CPR, and it does not read a digital product passport today. What it does is treat the model element as the anchor it was built to be. It reads the product and property data an IFC already carries, runs its Bbl and Wkb rule packs against that data, and keeps certificates in the dossier next to the element they belong to. As the passport turns loose product paperwork into structured data, the model is where that data has always wanted to sit. Everything you build on top of it, the findings, the certificates, the Wkb dossier, still sits on your model.