Digital product records are not yet a general legal requirement in Great Britain, but construction businesses should start improving product traceability now. Existing duties already require project teams to select suitable products, control substitutions and retain reliable building information. Future digital records are likely to make those processes more visible—not replace them.
The government is currently gathering evidence on how digital product records could work in the UK. For contractors, the important question is not whether another QR code will appear on product packaging. It is whether the business can show what was specified, approved, delivered and installed.
What is the government considering?
The Department for Business and Trade has opened a call for evidence on digital product records. The consultation is exploring how digital records could improve access to product information, supply-chain transparency, regulatory compliance, recalls, maintenance and sustainability data.
The Construction Leadership Council highlighted the consultation on 31 July 2026. Responses are due by 21 September 2026.
The government has not yet settled the format, technical standards or scope of a future Great Britain system. This is a policy-development exercise, not a new compliance deadline.
A future digital product record could contain information such as:
- Manufacturer and supplier details
- Product, batch or serial identifiers
- Declared performance and certification
- Materials and composition
- Installation instructions
- Inspection and maintenance requirements
- Safety notices and recalls
- Environmental, repair and recycling information
Access might eventually be provided through a QR code, barcode or another digital identifier. However, the technology is less important than the reliability of the information behind it.
Is this already a legal requirement?
There is currently no general requirement for every product placed on the Great Britain market to carry a digital product record.
Businesses supplying products into Northern Ireland or the European Union may encounter digital-product requirements earlier because relevant EU requirements can apply in Northern Ireland under the Windsor Framework.
For contractors working solely in England, Scotland and Wales, it would therefore be misleading to claim that Digital Product Passports are already mandatory across construction.
That does not mean contractors can ignore product information until new legislation arrives. Existing construction-product, Building Regulations and building-safety duties already require decisions to be supported by suitable evidence.
What records should contractors already be keeping?
For building work in England, regulation 7 of the Building Regulations 2010 requires building work to use adequate and proper materials that are appropriate for their intended circumstances and properly applied.
Approved Document 7: Materials and Workmanship provides guidance on satisfying that requirement. It is statutory guidance rather than the legislation itself.
The current construction-products regime in Great Britain also regulates the placing of relevant products on the market. CE marking continues to be recognised for construction products in Great Britain, while UKCA marking remains available.
However, a conformity mark does not prove that a product is suitable for every project or application.
The project team must still compare its declared characteristics and limitations with:
- The approved design
- Its intended location and use
- Fire and structural performance requirements
- Compatibility with adjoining products
- Environmental exposure
- The manufacturer’s installation instructions
Why product substitutions are a particular risk
Substitutions often arise because the specified product is unavailable, has a long lead time or can be replaced by a cheaper alternative.
That does not make the alternative equivalent.
Consider a specialist contractor proposing a different fire-stopping product because the original material is out of stock. The substitute may look similar but have different tested applications, supporting-construction requirements, annular-gap limits or installation conditions.
A proper substitution process should record:
- The original specification
- The reason for the proposed change
- The technical information for the alternative
- Comparison against the required performance
- Designer or other appropriate approval
- Any revised installation requirements
- The final product and location installed
An informal email saying that a product is “similar and approved” is unlikely to provide a reliable audit trail.
How do digital product records relate to the golden thread?
They are related, but they are not the same.
A digital product record concerns information about a product. That information may accompany the product through manufacture, supply, installation, maintenance and eventual reuse or disposal.
The golden thread concerns information about a particular higher-risk building. Government guidance requires specified dutyholders to maintain an accurate, accessible and usable digital record for relevant higher-risk buildings.
Product data may contribute to the golden thread, but it does not demonstrate on its own:
- Which product was approved for a particular location
- Whether it was installed in accordance with the design
- Who carried out the installation
- Whether concealed work was inspected
- Whether a substitution was properly controlled
- Whether testing and commissioning were completed
A QR code can provide access to technical information. It cannot prove that the product was installed correctly.
What should contractors do now?
There is no need to purchase a complex new digital platform solely because the consultation has been announced.
A more useful first step is to review how product information currently moves through the business.
Set a minimum product-information requirement
For safety-critical or performance-critical products, determine what must be obtained before approval or installation. This could include:
- Product and manufacturer identification
- Technical data and declared performance
- Applicable certification
- Installation and compatibility requirements
- Batch or serial information where proportionate
- Inspection and maintenance instructions
- Evidence approving any substitution
Connect the paperwork to the installed product
A folder containing product literature is of limited value if nobody can identify where each item was installed.
For relevant products, records should connect:
- The approved specification
- Purchase and delivery information
- Batch or serial details
- Installation location
- Installer details
- Inspection and photographic evidence
- Handover information
This is particularly important for fire doors, fire stopping, structural fixings, façade components, insulation, structural products and safety-critical building services.
Preserve the information relied upon
Do not rely exclusively on a manufacturer’s live webpage. Pages, downloads and product ranges can change.
Retain the relevant version of the technical information, declaration, certificate or installation document used when the product was selected and approved.
Test the process on one project
Select three or four safety-critical products and trace each one from design through procurement, delivery, installation, inspection and handover.
This will quickly show whether the process contains:
- Missing approvals
- Uncontrolled substitutions
- Duplicate records
- Unclear responsibilities
- Product information that cannot be connected to the installed work
Our professional view
Digital product records could make construction information easier to access and audit. They will not correct weak procurement, installation or quality-control systems.
The priority for contractors should be to establish a reliable product-information process before investing heavily in technology. Once the responsibilities, approval stages and records are sound, digital tools can make the process more efficient.
Poor information does not become good evidence simply because it is delivered through a QR code.
Businesses reviewing product approval, substitution and construction-compliance processes can obtain support through All Star Safety’s health and safety consultancy service. Managers responsible for procurement, quality and project controls may also benefit from appropriate Supervisory and Management NVQs.
Frequently asked questions
Are Digital Product Passports mandatory for UK construction products?
Not generally in Great Britain at present. The government is gathering evidence to inform possible future policy. Different requirements may apply when supplying products into Northern Ireland or the European Union.
Is CE or UKCA marking proof that a product is suitable?
No. Marking provides information about conformity and declared performance under the relevant product regime. The project team must still confirm that the product is suitable for the approved design and intended use.
Is a QR code enough for the golden thread?
No. It may provide access to product information, but the project record must also show approval, change control, installation, inspection and other building-specific evidence.
Who should approve a product substitution?
That depends on the project and the significance of the change. Approval may require the designer, principal designer, client, principal contractor, building control authority or another competent specialist. The process and authority should be defined before substitutions arise.