Discussion draft · illustrative product and numbers · no company systems assumed

One governed regulatory data foundation — AI upstream, outputs and value downstream

Write each regulatory fact once, with an owner and a source. Let AI do the capture, checking and drafting around it, with people approving. Every passport, label and declaration then reads the same facts — and every new regulation becomes another reader, not another project.

From source documents to passports, labels and value

Upstream, AI turns documents and system data into candidate facts. In the middle, people own and approve the facts. Downstream, AI and templates generate every output from the same approved facts. Click any box.

sources →AI capture →governed facts →AI services →outputs
EffortFewer hours per document
SpeedFaster product and country launches
QualityFewer relabels and rejected submissions
AccessProducts stay sellable when passports become mandatory
ReuseEach new rule reads existing facts

Click a box above

Each box shows what it is, what AI does there, what people do, and how we would measure it.

Walk-through: one illustrative product

Tile adhesive TA-200 (illustrative) — a cementitious adhesive. All values below are invented for the example.

AI guardrails: fast where it is safe, human where it matters

Regulated data needs AI that is useful and accountable. The same pattern already runs in production for regulatory label content in crop protection: AI drafts, a person decides, everything is logged.

AI does

  • Extract candidate facts from SDS, test reports and supplier documents, with a confidence score and a link to the source page
  • Check consistency across documents (SDS vs label vs declaration) and flag conflicts
  • Draft outputs and translations from approved facts
  • Watch regulation changes and list affected facts, products and documents
  • Answer staff questions from approved facts only, with sources

AI never does

  • Invent a value that has no source — a missing performance value stays a gap
  • Approve a fact or publish an output on its own
  • Decide a hazard classification or a declared performance
  • Overwrite a fact without a new version and a reason

Human in the loop

Low-confidence extractions go to the fact owner. Every output is released by a named person.

Audit trail

Each fact keeps source document, page, extraction run, reviewer and date — what an authority or a customer audit asks for.

Kill switch and limits

Any AI service can be switched off without stopping the process; spend caps and monitoring per service.

How we know it works

MetricWhy it matters
Field-level extraction accuracy vs a reviewed sampleDecides how much review is needed
Share of facts auto-accepted vs sent to reviewShows where people still spend time
Review time per documentThe real efficiency gain, measured against the baseline
Conflicts found between documentsQuality value that was invisible before

Value case: from assumptions to an annual number

Move the sliders to your own assumptions. Defaults are illustrative only — the first step of the programme is to measure the real baseline for one product family.

Estimated annual value (illustrative)
–

Not counted: market access (revenue that stays sellable once passports are mandatory) and reuse across future regulations. Both are often the largest items — show them as risk avoided, not as savings.

How to take it to a steering committee

  1. Measure today for one product family: hours per document, errors, launch lead time.
  2. Run the pilot with the same measures — no new numbers without a baseline.
  3. Present three numbers: effort saved (hard), launch time saved (revenue), risk avoided (market access).
  4. Ask for funding by phase, each phase released on measured results.

Roadmap: start small, prove it, then scale

The passport deadline is not here yet — that is the opportunity to build the foundation calmly instead of a rushed passport project later.

0–90 days

Listen, map, prove one flow

  • Listening tour: regulatory, product data, R&D, IT, a few countries
  • Fact inventory for passport and packaging: ~15–20 facts, each with source and owner
  • Baseline one product family
  • Generate one output from governed facts; show the measured difference

6–12 months

Foundation and first AI services

  • Fact register live for priority families
  • AI capture from SDS and test reports with review
  • Consistency checks across SDS, labels, declarations
  • Mapping to data templates (EN ISO 23386/23387)

12–24 months

Passport-ready and scaling

  • Passport records generated per family when the delegated act lands
  • Packaging facts for the labelling rules
  • Regulation-change monitoring
  • Roll out family by family, measured each time

Regulatory clock (as far as published)

8 Jan 2026Construction Products Regulation (EU) 2024/3110 generally applicable
Aug 2026Packaging Regulation (EU) 2025/40 main obligations apply
Not yet adoptedDelegated act setting up the construction passport system (status late Sept 2026)
+18 monthsManufacturers must provide passports after that act enters into force; first families expected: cement, steel, insulation, windows
~2028Packaging labelling, depending on implementing acts
2030Packaging recyclability and recycled-content targets

Industry context: nobody has to solve this alone

What the passport must carry

Declaration of performance and conformity, instructions and safety information, technical documentation and labelling, unique identifiers — reached through a data carrier on the product.

Regulation (EU) 2024/3110 · Belgian FPS Economy

A data model already exists

CEN/TC 442 makes declarations machine-readable through data templates (EN ISO 23386 and 23387; 23387 revised 2025). The task is to map existing facts to them, not to invent a private format.

ISO 23387 · CEN/TC 442 digital DoPC

The industry pilot

CIRPASS-2 construction pilot (EU-funded, 2024–2027), led by Cobuilder with GS1 France, Soprema, Velux, Autodesk and others: QR codes to passports and a standard data model.

Cobuilder · Construction Management

What batteries learned first

The Battery Pass consortium concluded the passport is a strategic opportunity, not only a compliance cost. Pilots: open standards work, engage suppliers early, value appears only when data is trusted.

Battery Pass value study · Circulor

Packaging is the same foundation

Material, weight and recycled-content facts are product-master facts too. The packaging rules become one more reader of the same register.

CMS · ComplianceGate

Done before, in another regulated industry

A common label data model agreed by competing crop-protection companies for a 27-country EU digital label, and AI agents in production for regulatory content with human review. The method transfers; the facts are new.

Questions to bring: Which product families and rules come first? Where do regulatory facts live today? Which associations or pilots does the company follow?