Two different questions
Traceability gets used for two things that need separating. The first is: what is this product, and what evidence stands behind it? That is a question about the product family and its versions. The second is: which particular doorset is this, when was it made, and what went into it? That is a question about a batch or an individual item.
Almost every manufacturer needs the first. Fewer need the second, and those who do usually need it because of a contract rather than a statute. Building the second without the first produces a serial number that points at nothing useful.
What identification the law already requires
For products within scope of the Construction Products Regulation, the manufacturer must indicate a type, batch or serial number that allows the product to be identified, together with the manufacturer's name or registered trade mark and a contact address. Where the product's size or nature does not allow that on the product itself, it goes on the packaging or in an accompanying document. That duty has the status LAW.
Note what it does and does not say. It requires identification. It does not require a database, a data carrier, or an online record. Those are things you may sensibly choose to build on top of the identification the law already asks for.
Where the direction of travel points
The Construction Products Reform White Paper and the general safety requirement consultation, both published on 25 February 2026, point towards a unique product identifier and a data carrier linking a product to digital product information. Neither is a legal requirement today, and no scheme has been mandated or endorsed. Our tracker records that as EXPECTED.
Meanwhile, those responsible for higher-risk buildings have information duties of their own, and the practical consequence is that product information is increasingly requested in a form that can be handed on. A scanned certificate emailed as an attachment creates work for the recipient, and they will say so in the specification.
A sensible level to build to
Give each product family a stable public identity that never changes, and version the record behind it. Make sure any label, mark or code on the product points at that stable identity rather than at a document. Keep revision history so a doorset made in 2024 can be described as it was specified in 2024.
Add batch or item-level records only where a customer, a scheme or a contract actually requires them. The cost of item-level traceability is real and continuing, and it is wasted if the product-level record underneath it is not in order first.