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Structured Declaration of Performance Data: Getting Your DoPs DPP-Ready

· 9 min read · DPP Delivery
DoP DPP Data Structure

If you manufacture construction products covered by a harmonised European standard, you already produce Declarations of Performance. You have been doing so since the original Construction Products Regulation (EU 305/2011) came into force. But here is the uncomfortable truth: the DoPs you have been issuing for the past decade are almost certainly not ready for the Digital Product Passport.

The problem is not the data itself - your DoPs contain exactly the kind of performance information that DPPs need. The problem is the format. DoPs exist overwhelmingly as PDF documents, often created in Word, sometimes with inconsistent layouts, and virtually never in a structured, machine-readable format. CPR 2024 is about to change that requirement fundamentally.

The Declaration of Performance: A Quick Refresher

Under the current CPR, every construction product placed on the EU market under a harmonised standard must be accompanied by a Declaration of Performance. The DoP is the manufacturer’s formal declaration of how the product performs against the essential characteristics defined in the relevant harmonised standard.

For example, a manufacturer of concrete masonry units operating under EN 771-3 must declare performance against essential characteristics including:

  • Compressive strength
  • Dimensional tolerances
  • Configuration (solid, hollow, percentage of voids)
  • Density
  • Thermal conductivity
  • Water absorption
  • Fire reaction classification
  • Moisture movement
  • Bond strength

Each of these characteristics has a declared value or classification, determined through testing to the methods specified in the harmonised standard. The DoP also includes the manufacturer’s identification, product type, intended use, the notified body involved in the assessment, and the AVCP (Assessment and Verification of Constancy of Performance) system applied.

How DoPs Currently Exist - And Why That Is a Problem

Walk into any Irish construction product manufacturer’s office and ask to see their DoPs. What you will likely find is:

  • PDF files stored on a shared drive, sometimes well-organised, sometimes scattered across folders by year, product line, or customer request.
  • Inconsistent formats - even within the same company, DoPs for different product lines may use different templates, different terminology, and different levels of detail.
  • Static documents - once created, DoPs are rarely updated unless a significant change occurs. Version control may be informal at best.
  • Human-readable only - the information is laid out for a person to read, not for software to parse. Performance values are embedded in tables within formatted documents, not in structured data fields.
  • Gaps and omissions - some essential characteristics may be declared as NPD (No Performance Determined) when they should have values, or essential characteristics required by the harmonised standard may be missing entirely.

This is not a criticism of manufacturers. The current regulation requires DoPs but says very little about digital format. The system was designed for paper and PDF. Manufacturers complied with what was asked of them.

What CPR 2024 Requires: Structured, Machine-Readable Data

The revised Construction Products Regulation changes the game. Under CPR 2024, the Digital Product Passport must contain the Declaration of Performance data in a structured, machine-readable format. This means:

  • Each essential characteristic must be a discrete data field, not text embedded in a formatted document.
  • Declared values must follow defined data types - numerical values with units, classifications from controlled vocabularies, Boolean fields where appropriate.
  • The data must conform to a schema - a formal definition of what fields exist, what values are permitted, and how the data is structured.
  • The data must be accessible via digital means - retrievable through the DPP system, not requiring someone to email a PDF.

In practical terms, this means your DoP data needs to move from a Word template to something closer to a database record. Each product’s performance characteristics become structured data points that can be queried, compared, aggregated, and verified by software systems.

The Gap Between Current Practice and DPP Requirements

For most Irish construction manufacturers, the gap is significant. Consider what needs to change:

From Documents to Data

Your current DoP is a document. Your future DoP (within the DPP) is data. This is not a cosmetic change - it requires rethinking how you capture, store, and manage performance information. The source of truth for your product’s declared performance needs to be a structured database, not a Word file.

From Free Text to Controlled Vocabularies

Current DoPs often use free text descriptions. One manufacturer might declare fire reaction as “Euroclass A1”, another as “A1 (EN 13501-1)”, another as “Class A1 - non-combustible”. All mean the same thing, but software cannot reliably parse these variations. DPP data requires the use of controlled vocabularies - standardised codes and terms that eliminate ambiguity.

From Snapshot to Living Record

Current DoPs tend to be point-in-time documents. The DPP concept envisions a more dynamic relationship with data - where updates to test results, changes in formulation, or revised classifications are reflected in the structured data. This requires version control, audit trails, and update processes.

From Internal to Interoperable

Your current DoP format is your own. The DPP requires interoperability - your data must conform to schemas that other parties (notified bodies, market surveillance authorities, specifiers, contractors) can read and process using their own systems. This means adopting common data standards, not proprietary formats.

Practical Steps: Getting Your DoP Data DPP-Ready

Here is a structured approach to preparing your DoP data for DPP compliance.

Step 1: Audit Your Existing DoPs

Before you can structure your data, you need to know what you have. Conduct a thorough audit:

  • List every product covered by a harmonised standard.
  • Locate the current DoP for each product. Note where gaps exist - products that should have DoPs but do not, or DoPs that are outdated.
  • Check completeness against the harmonised standard. For each product, compare the essential characteristics declared in the DoP against those required by the relevant hEN. Flag any missing characteristics or unexplained NPD declarations.
  • Verify currency of test data. Are your declared values based on current testing, or are they relying on results from years ago that may no longer be representative?

Step 2: Identify Essential Performance Characteristics per Harmonised Standard

Each harmonised standard defines a set of essential characteristics and the corresponding test methods. Create a master list for each hEN that applies to your products:

  • EN 771 series (masonry units): compressive strength, density, dimensional tolerances, thermal properties, fire reaction, water absorption, etc.
  • EN 12620 (aggregates for concrete): grading, shape, resistance to fragmentation, density, water absorption, chloride content, etc.
  • EN 13162-13171 (thermal insulation products): thermal resistance, compressive strength, water absorption, fire reaction, dimensional stability, etc.
  • EN 1090 (structural steel and aluminium): yield strength, tensile strength, impact toughness, weldability, etc.

For each standard, document every essential characteristic, its data type (numerical, classification, Boolean), the relevant test method, and the unit of measurement.

Step 3: Create Structured Data Templates

Develop a structured template for each product category. This template should map directly to the essential characteristics identified in Step 2. At minimum, each record should include:

  • Product identifier (GTIN - see our article on GS1 registration)
  • Harmonised standard reference and year
  • AVCP system applied
  • Notified body identification number
  • For each essential characteristic:
    • Characteristic name (from controlled vocabulary)
    • Declared value or classification
    • Unit of measurement
    • Test method reference
    • Date of most recent test/assessment

Use a structured format - a well-defined spreadsheet is a starting point, but the target should be a data format like JSON or XML that can feed directly into DPP systems.

Step 4: Validate Against Schema Requirements

As DPP schemas for construction products are published (the European Commission is developing these through CEN/CENELEC standardisation work), validate your structured data against the official schemas. This ensures your data will be accepted by DPP systems without reformatting.

Until final schemas are published, use the draft structures emerging from standardisation work and pilot projects. Being approximately right and refining later is far better than waiting for perfection and then scrambling.

The Relationship Between DoP, EPD, and DPP Data

The DPP is not just a digital DoP. It integrates multiple data sources:

  • DoP data - declared performance against the harmonised standard.
  • EPD data - environmental impact across the lifecycle (see our article on EPDs).
  • Substances of concern - SVHC declarations and SCIP data.
  • Product identification - GTINs and data carrier information.
  • Manufacturer information - company details, factory production control, CE marking data.
  • Circularity information - recycled content, recyclability, disassembly instructions.

Your DoP data is one layer. Structuring it properly allows it to integrate cleanly with the other layers. If your DoP data is messy, the entire DPP structure is compromised.

Common Issues to Watch For

Having audited DoPs for numerous manufacturers, these problems come up repeatedly:

  • Missing essential characteristics. If the harmonised standard requires you to declare a characteristic and you have not tested for it, declaring NPD may not be sufficient under CPR 2024’s strengthened requirements. Review what genuinely requires testing versus what can legitimately be NPD.
  • Inconsistent declared values. The same product sold under different brand names or into different markets sometimes has inconsistent DoPs. The DPP will expose these inconsistencies.
  • Outdated test results. If your factory production control plan requires annual testing and you have not tested in three years, your declared values may not be defensible. Update testing before structuring the data.
  • Ambiguous product type identification. Your DoP describes a “product type” but the description may not clearly map to a specific product variant. Ensure a clear, unambiguous link between each DoP record and the specific product variant (identified by GTIN).

How to Prioritise

You cannot restructure every DoP overnight. Prioritise:

  1. Highest-volume products - these represent the largest compliance exposure and the greatest efficiency gain from automation.
  2. Products under regulatory scrutiny - if market surveillance authorities are active in your product area, structured data readiness reduces risk.
  3. Products with complete, current test data - start with the easy wins. Products where data quality is already good will be faster to structure.
  4. Export products - if you sell into markets that are moving faster on DPP implementation (Nordics, France, Germany), prioritise those products.

Your Declarations of Performance are not going away. They are becoming more important, more structured, and more visible. Starting the work of structuring your DoP data now - even before final DPP schemas are published - puts you in a strong position. The manufacturers who treat this as a data management challenge rather than a document formatting exercise will find the transition far smoother.