From DoP to DoPC: what changes when a declaration has to be read by machines

For years, a Declaration of Performance (DoP) has been a document: a signed page, usually a PDF, that a person reads. The revised Construction Products Regulation, Regulation (EU) 2024/3110, adopted on 27 November 2024, changes the document and changes who is expected to read it. The new Declaration of Performance and Conformity (DoPC) is meant for people and for software.

This article explains the direction the Regulation sets, the standards around it, and what it means for a manufacturer's product data. It is general information, not legal advice. For binding wording and dates, always consult the Regulation itself and the specifications for your product family.

What changes between the DoP and the DoPC

Two changes matter most.

First, performance and conformity are declared together. The old DoP covered performance only. The new declaration combines performance with conformity to the requirements that apply to the product, which reduces duplicated paperwork. Environmental information is also part of what the new regime cares about, so data you already hold, such as an Environmental Product Declaration, is likely to matter.

Second, the declaration has to be readable by machines. The Regulation expects declarations to be made available in a form that people and software can both read, that cannot be silently altered, and that stays reliably linked to the product. A PDF that only a person can interpret does not meet that direction.

Why "machine-readable" is more than a file format

A document can be stored in a machine-friendly file and still be unreadable to software. If one manufacturer writes "Compressive strength", another writes "Resistência à compressão" and a third writes "Rc", a computer sees three unrelated labels.

The Regulation recognises this. It points towards a common data dictionary based on European standards, so that every product family has agreed, published definitions for its essential characteristics and other properties. Authorities and the wider digital construction sector, including BIM, building records and passports, can then use the same definitions.

In other words, the law expects each declared property to mean one precise, published thing.

The standards around it

Several standards fit together here.

• EN ISO 23386 sets the rules for describing properties in a data dictionary, and EN ISO 23387 defines data templates, the structured lists of properties that describe a product type. Together they are the established way to define what a property such as "compressive strength" means.
• EN 18223:2026 is part of the new European family of standards for digital product passports. Its subject is system interoperability: how products and their lifecycle information are represented semantically, a shared information model, and how data dictionaries are brought into the picture.
• prEN 18357 is a European standard under development in CEN/TC 442 concerning the digital declaration of performance and conformity. It is still a draft and its content may change, so we do not describe it here.

This is why a data dictionary matters to a manufacturer. A declaration whose properties point to published definitions can be compared, checked and reused without anyone re-typing it. PDTs.pt is a data dictionary built on EN ISO 23386 and EN ISO 23387, a CT 197 initiative hosted at the University of Minho.

Where the passport fits

The Regulation provides for a construction digital product passport. Its information is meant to be structured, machine-readable and based on open standards, so that it can move between systems without being tied to one vendor. The DoPC therefore has two lives: it is the legal declaration, and it is a technical backbone of the passport.

When does this apply?

The Regulation has been adopted and its obligations apply in stages. For product requirements, timing depends on your product family and on when the harmonised technical specification for that family is available. There is no single date for everyone. Our standards timeline tracks it family by family.

What a manufacturer can do now

1. List what you declare today. Which essential characteristics does your current DoP cover, and where does that data live?
2. Gather your environmental data. If you already hold an Environmental Product Declaration, keep it close to your declaration data.
3. Make declared values consistent. The same characteristic should carry the same name, unit and meaning wherever it appears: in the DoP, the datasheet and the catalogue.
4. Watch your family's standards. Your product family's specifications set the timing and the list of characteristics.

If you would like to see how ready your catalogue is, the readiness check takes about two minutes.

Sources

• Regulation (EU) 2024/3110 of the European Parliament and of the Council of 27 November 2024 (Construction Products Regulation), EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng.
• Regulation (EU) No 305/2011 (the previous Construction Products Regulation), repealed by Regulation (EU) 2024/3110.
• EN ISO 23386 and EN ISO 23387, on data dictionaries and data templates for construction.
• EN 18223:2026, Digital Product Passport, System interoperability.
• CEN/TC 442, work on the digital declaration of performance and conformity (prEN 18357, draft).