EuroWindoor, the European association representing manufacturers of windows, doors and curtain walling, welcomes the opportunity to contribute to the public consultation on the draft Implementing Regulation on the Digital Product Passport (DPP) Registry pursuant to Article 13(5) of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781.
The draft Implementing Regulation explicitly includes construction products covered by Article 76 of the Construction Products Regulation (EU) 2024/3110 within its scope (Article 1(1)(c)). This establishes a direct regulatory link between the ESPR-based DPP registry and the construction products sector: manufacturers of windows, doors and curtain walling will be required to register digital product passports in the registry established under the ESPR framework, even though the underlying obligation originates from the CPR.
EuroWindoor would like to draw attention to the need for coherent timing between this implementing act and the development of harmonised technical specifications under the CPR. The DPP data requirements for construction products will be defined in the harmonised standards currently under development. This Implementing Regulation should ensure that the DPP registry and its data models are operationally ready and tested before sector-specific DPP obligations take effect, and that no registration obligations arise before the relevant data scope has been defined through harmonised standards.
It is essential to highlight that the European window, door and curtain walling manufacturing is almost exclusively composed of small and medium-sized enterprises (SMEs). The vast majority of manufacturers are small craft businesses, often with fewer than 10 employees, limited IT infrastructure and no dedicated digitalisation departments. Any obligation arising from this Implementing Regulation will directly and significantly affect these SMEs. While SMEs are disproportionately affected, it should be noted that many of the challenges identified in this feedback apply to all economic operators regardless of size, including the larger manufacturers in the sector as well as component suppliers. The proposed solutions should therefore be designed to benefit all economic operators.
For the full EuroWindoor EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry see the following link:
EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry (May 2026)