GS1 2D Codes in Construction: What the CPR Asks For, and When

GS1 2D codes in construction are one way to provide the data carrier the new Construction Products Regulation (CPR) will require next to the CE marking, once a Digital Product Passport (DPP) exists. Regulation (EU) 2024/3110 names neither GS1 nor any symbology.

No 2D code is mandatory today. The passport duty starts 18 months after a delegated act not yet adopted, family by family. This guide is for construction industry manufacturers placing products on the EU market. It covers what GS1 2D codes in construction must open, when the duty starts and how to code boards, packs and pallets.

What are GS1 2D codes in construction?

GS1 2D codes in construction are QR Codes or GS1 DataMatrix symbols encoding a product's GTIN, plus a batch or serial number where needed. The data is either GS1 element strings or a GS1 Digital Link URI. On the product, label, packaging or delivery document, a Digital Link code can open the declaration of performance today and the passport later.

The law itself is neutral. The CPR defines a data carrier as "a linear bar code symbol, a two-dimensional symbol, or other automatic identification data capture medium that can be read by a device" (Article 3(41)). It names no symbology and no standards body.

GS1 comes in through its identification keys. GS1 2D codes in construction carry the Global Trade Item Number (GTIN) of the product or pack. Around them, the Global Location Number (GLN) identifies the company and plant, and the Serial Shipping Container Code (SSCC) the pallet. For the symbols themselves, see GS1 2D barcodes and GS1 Digital Link.

What must the code open under the CPR?

The CPR lists what the construction passport must contain (Article 76(2)(a)). That is what GS1 2D codes in construction would open if they become the passport's data carrier.

One passport per product type, not per board. The passport connects to "a persistent unique identification code of the product type" (Article 77(1)(a)).

Batch or serial is conditional. You must mark the product-type code and, "where available", a batch or serial number (Article 22(5)).

In GS1 terms each trade item gets its own GTIN. So one product type often covers several GTINs, such as sizes and packs, all pointing to the same declaration. Batch maps to Application Identifier (AI) (10) and serial to AI (21). That is a fit, not a legal requirement.

The code can free up space next to the CE marking. For products already under the new CPR, a data carrier or permalink to a website DoPC may replace the printed product-type code and declaration code.

Once a passport data carrier is given, both may be omitted (Article 18(2)). The walkthrough below shows why plasterboard cannot use this yet.

Access is free, but tiered. Every operator, client, user and authority can reach the passport free of charge through the data carrier. The delegated act decides which actors see which information (Articles 75(2)(c), 76(2)(e) and (f)). For the wider architecture, see what a Digital Product Passport is.

When will GS1 2D codes in construction become mandatory?

Not yet, and not on one date. GS1 2D codes in construction are voluntary today. Three conditions must stack before any data carrier on your product becomes a legal duty.

1. The passport act must exist. The Commission must adopt a delegated act setting up the passport system (Article 75(1)). A delegated act is a Commission regulation that fills in the detail of the CPR. It enters into force only if Parliament and Council do not object within two months, extendable by two more (Article 89(6)).
2. Then 18 months run. The manufacturer must provide the passport 18 months after that act enters into force (Article 22(7)).
3. Your family must have moved to the new CPR. Your duties under the new CPR start one year after an implementing act makes a new harmonised standard mandatory for your family (Article 95(9)). A harmonised standard sets how a product family's performance is tested and declared; an implementing act is a Commission act that puts the law into practice.

The Commission's working plan says passports are for products under the new CPR, "not the CPR-2011", meaning the old Regulation (EU) No 305/2011.

The 18-month clock has not started. On 6 October 2026, EUR-Lex lists three delegated regulations supplementing the CPR: 2026/331 and 2026/557 on fire classes, and 2026/1310 on assessment and verification systems. None sets up the passport system.

What the arithmetic says. If the act is adopted early in the indicated quarter and cleared without objection, 18 months later lands at the end of 2028 at the earliest. With the full scrutiny period, or any slip, the duty moves into 2029. That is our arithmetic, not an official date.

The Commission's CPR page also counts the 18 months from the act "for their product family", so the start may differ by family. Until then, GS1 2D codes in construction remain a voluntary choice.

What does GS1 say about 2D codes on construction products?

GS1 has two documents that shape GS1 2D codes in construction, and they carry very different weight.

Ratified: the GTIN Management Guideline for Construction Products (Release 1.0, January 2023). It uses plasterboard to show when a new GTIN is needed.

A plasterboard whose density changes for an extended application or function needs one. So does a pack whose declared number of boards changes from 8 to 10. So does a product that moves from a national standard to an EU harmonised standard and must newly carry CE marking.

Provisional: the GS1 DPP application standard (release 2, June 2026). It says plainly: "This is NOT a ratified GS1 standard." Its rules may change once delegated acts are known:

• The identifier is the GTIN, possibly with a version, batch/lot or serial number, depending on the regulation.
• The carrier is a QR Code or Data Matrix in GS1 Digital Link syntax. RFID and NFC may only be added on top of the 2D barcode.
• The code goes on the product, otherwise on the packaging or accompanying documentation.
• For construction products, its own table lists granularity and carrier as "TBD".

GS1 in Europe's CPR position paper uses the GTIN for products, batches and serialised instances, and the GLN for the manufacturer and its sites. It says the SSCC "can be utilized" for pallets.

National GS1 organisations fill in the practice. A Finnish pilot on plastic water pipes, with GS1 Finland among the implementers, recommended GS1 DataMatrix or GS1 QR, with GTIN plus batch or production date as the minimum.

GS1 Sweden says a batch number, where one exists, belongs on the delivery note. GS1 Netherlands describes a QR code with GS1 Digital Link on the product, and GTIN plus serial for maintenance history.

Put together, the GS1 keys behind GS1 2D codes in construction work at five levels:

Walkthrough: coding a plasterboard line in Bydgoszcz

Here is how GS1 2D codes in construction work on one line, step by step. Take a hypothetical plasterboard maker in Bydgoszcz, Poland. It makes two 12.5 mm boards, a standard board and a fire-rated board, each in one size. It ships them to a distributor in Utrecht: each week 30 pallets of 6 packs of 8 boards, or 1,440 boards.

Step 1: one GTIN per board. The two boards declare different performance, so they are two product types, and each gets its own GTIN. If the maker later adds sizes, each size gets its own GTIN, and all GTINs of one type link to that type's declaration.

Step 2: new GTINs where GS1 says so. The distributor asks for 10-board packs. Under the GS1 guideline that is a new pack GTIN, while the board GTIN stays. A later board with higher density for an extended application gets a new board GTIN.

The guideline is silent on migration to the new CPR. Its CE-marking rule covers products newly CE marked, and this board already is.

Step 3: batch in the code. Each shift gets a batch number. The 2D barcode on each pack label encodes the pack GTIN plus batch in a GS1 Digital Link URI, on a domain the maker controls.

Where the line can print on the board, the board carries its own code: the board GTIN plus the same batch. The pack GTIN resolves to the declaration of the board it contains.

Step 4: SSCC on each pallet, batch on the delivery note. Each pallet label carries an SSCC and the batch; the delivery note lists GTIN and batch per line. A complaint about one shift traces to the sites that received it.

Step 5: what the code opens today. Plasterboard is still under a CPR-2011 harmonised standard, so the old Regulation still governs its CE marking (CPR Article 95(8)). That Regulation requires the printed product-type code and declaration reference after the CE marking (its Article 9(2)). So the 2D code goes alongside, not instead.

It opens the declaration of performance on the maker's website, published under Article 7(3) of the old Regulation and Delegated Regulation (EU) No 157/2014. Once gypsum products move to the new CPR, the code may replace those printed codes (Article 18(2)).

If the delegated act accepts a GS1 Digital Link URI as the passport carrier, the resolver can then redirect the same URI to the passport.

The counterfactual. Suppose the fire-rated packs go out with the standard board's GTIN because the line reused a print template. The check digit is valid, so every scanner accepts it. On site, a scan opens the standard board's declaration, with the wrong fire performance, for a board chosen for a fire-separating wall.

A single mistyped digit always fails the check digit. A valid but wrong GTIN is the error GS1 2D codes in construction cannot catch on their own: it passes every scanner. Under the passport regime it would sit in a system that helps authorities verify compliance (Article 76(3)(b)). The fix is a pre-print check of GTIN against product specification, per line and per shift.

Edge cases: products that do not fit

These cases change where GS1 2D codes in construction go, or what they encode.

Custom-made and heritage products. If you use the Article 14 exemption from the DoPC, the passport duty falls away too (Article 76(4)).

The exemption is narrow. It covers non-series products made to a specific order and installed in one identified construction work (Article 14(a)). The installer must be the manufacturer, also responsible for safe incorporation, under national rules and supervision. It also covers non-series heritage products for officially protected works (Article 14(b)).

Families still under CPR-2011 standards. They stay outside the passport duty until their family moves (Article 95(9)).

Kits. The passport includes the data carriers of key parts that have their own passport (Article 76(2)(a)(vii)). Plan GTINs for the kit and those parts.

Online sales. Once the duty applies, an online offer must show the data carrier, and intermediaries share the duty (Article 29(2)–(3)). Give online sellers a digital copy of the data carrier, free, within 5 working days of a request (Article 77(3)).

Paper on request. The DoPC, instructions and safety information must be given on paper, free, if the end-user asks at the time of purchase (Article 91(2)).

Surfaces that cannot take a code. The CPR's order is product, affixed label, packaging, then accompanying document (Articles 18(1) and 22(5)). GS1's provisional standard mirrors it.

Boards sold through retail. Store tills move to 2D on their own timetable: see GS1 Sunrise 2027 and our 2D barcode transition guide.

Makers outside the EU. The passport duty is the manufacturer's wherever it is based (Article 22(7)). Under the new CPR, a manufacturer outside the EU must also appoint a single authorised representative in the Union (Article 23(1)). See DPP and non-EU manufacturers.

Zoom out: how the construction passport connects to the ESPR

The construction passport must be based upon the passport of Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), without compromising Building Information Modelling (BIM) interoperability (Article 75(2)(a)). ESPR rules on identifiers, data carriers and the registry apply unless the construction act sets other rules (Article 79).

The EU DPP Registry was launched on 20 July 2026, and Implementing Regulation (EU) 2026/1778 names CPR Article 76 products in its scope. ESPR Annex III names the GTIN under ISO/IEC 15459-6 "or equivalent": a GTIN is one compliant option, not a mandate.

Whether GS1 2D codes in construction will match the legal passport carrier is still open. The Commission's FAQ says the delegated act will set it per product group, with QR codes and NFC under assessment.

Implementing Decision (EU) 2026/1736 has since cited EN 18220:2026 on data carriers and EN 18219:2026 on unique identifiers under the ESPR. Which carrier construction products must use remains for the CPR act.

Longevity is the real constraint. The passport system must stay accessible for 25 years after the last product of a type is placed on the market. You must keep each passport available for at least 10 years (Article 75(2)(i)).

A board in a wall outlives several website redesigns, so the domain and resolver behind GS1 2D codes in construction matter more than the symbol. See our ESPR guide.

What should construction manufacturers do now?

• Audit GTINs against product types. Map every GTIN to exactly one product-type code; one type can have many GTINs. GTINs come from a licence with your national GS1 member organisation.
• Decide batch or serial granularity. Batch suits boards and bags; serial suits products with a maintenance history.
• Publish declarations on stable URLs, on a domain you control.
• Pilot GS1 2D codes in construction on packs and pallets. Test print and scan on real surfaces; GS1 2D barcodes covers print basics. Passmith's free GS1 Digital Link QR generator runs in the browser with no signup. Passmith also has a free plan.
• Watch the Article 75(1) act and your family's row in the CPR working plan. Our note on the ESPR working plan explains how to read indicative dates.

GS1 2D codes in construction are a voluntary, reversible step today, ahead of a data-carrier duty that is already law but not yet switched on. Get the identifiers right now. If the delegated act accepts a QR Code or Data Matrix with a GS1 Digital Link URI, the passport may then need only a redirect, not a new identifier scheme.

Further reading: GS1 Digital Link vs QR code · What is a Digital Product Passport? · GS1 2D barcodes

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