CRA Dossier
Who Signs for the Kitchen
Digital Product Passports and EU Product Compliance Across an Installed System
What happens when separate EU product-compliance regimes meet inside one installed system? A fitted kitchen sits across two EU product regimes. The carcases and fronts fall within the furniture product group being developed under the Ecodesign for Sustainable Products Regulation (ESPR), while the floor and the door may be regulated as construction products under the Construction Products Regulation (CPR). Each regime keeps its own product records. However, neither of them describe the installed room that the owner insures and a professional signs for on the day of acceptance. This dossier is a fitted kitchen in a Milan apartment as a practical case study in Digital Product Passport requirements, EU product compliance and responsibility for installed works. It tests against the operative texts of the CPR, the ESPR and the recast Energy Performance of Building Directive. It explains why the join sits at the works level, which the CPR leaves to Member States, why neither digital product passport exists yet, and why a stone worktop may be part of the furniture rather than a construction product. Professionals who certify installed works get eight operational steps for classifying each item, collecting the matching records and writing the assembly record themselves.
Written for professionals who certify installed works in which products regulated under the CPR and ESPR meet.
How Do Digital Product Passports Apply to Installed Works?
Both the CPR and the ESPR are placing-on-the-market regimes within the wider EU product-compliance framework. Their obligations attach to the product and its economic operators, not the installed result. The CPR leaves competence over construction works to Member States, and its recital 113 states that the basic requirements for construction works are not obligations on economic operators.
The EU Digital Product Passport infrastructure is operational, but the relevant product-specific passport obligations examined in this dossier are not yet mandatory.
The ESPR furniture delegated act is indicated for 2028, and the CPR passport becomes mandatory 18 months after a delegated act under Article 75(1) that has not been adopted. When both arrive, they will link compliance information from product to product, and neither Regulation provides for an assembly passport. The duty to describe the finished room comes from national law and the works contract, with the individual Digital Product Passports, declarations and other product-compliance records serving as evidence.
What is inside
- The boundary between EU product compliance and responsibility for installed works, read from CPR Articles 1 and 3 and recitals 9, 26 and 114, and from ESPR Articles 1(2), 2(12) and 5(4).
- The implementation timeline for the relevant Digital Product Passport requirements, from the ESPR furniture preparatory study (feedback open to 25 November 2026) to the CPR product families for doors, floorings and building kits.
- An item-by-item product-classification and compliance analysis of the kitchen, including why a stone worktop may be an ESPR component of the furniture rather than a CPR construction product, and the priority rules that resolve overlaps between the two Regulations.
- A table of the four partial Union mechanisms for products that straddle both regimes, the Member State channels that operate without a complaint, and the EPBD digital building logbook as the only Union-named container for an assembly record.
- Who owns the join under CPR Article 14(a)(iv), with the Italian direttore dei lavori as worked example, followed by eight operational steps, eight monitoring triggers and an annex of the operative texts relied on.
Who is it for
Manufacturers, system integrators, product-compliance teams and professionals who sign for installed works on the day of acceptance, wherever separately regulated products meet within one installation.
Written by Daniel Thompson-Yvetot for CrabNebula Ltd. Desk assessment of published Union Law. Not legal advice. Italian law not assessed.
