Delegated act expected Q4 2026

The iron and
steel digital
product passport

Iron and steel is the first product group where ESPR itself will set Digital Product Passport content. No act has been adopted and no draft text has been published.

What exists is a European Commission Joint Research Centre (JRC) study proposing what the passport should contain, prepared for stakeholder consultation. This page describes that proposal and cites the study directly.

 

This is a proposal, not law.

 

The JRC states that its proposed design choices require validation through stakeholder consultation and may be refined during the impact assessment phase of the delegated act, including through a cost-benefit analysis of the recommended data elements.

Study on DPP content for iron and steel products under ESPR. JRC Science for Policy Report, 2026. Published under CC BY 4.0.

Intermediate steel products

The obligation would apply to intermediate steel products placed on the EU market. EU manufacturers and importers placing such products on the market would be responsible for meeting the requirements.

  • Hot rolled coil

    HRC. The highest-volume intermediate product in the sector.

  • Wire rod

    WR. Coiled bar drawn down into wire and fasteners.

  • Galvanised cold rolled coil

    CRCG. Zinc-coated strip for automotive and appliances.

  • Electrical steel

    ES. Silicon steel for motors and transformers.

  • Stainless steel

    SS. Analysed as a representative product in the study.

What “intermediate” means here

It covers semi-finished and finished intermediate products as the industry uses those terms: slabs, blooms, billets, hot-rolled coil, cold-rolled coil, wire rod, galvanised coil. Some are called finished products inside a steelworks, but they are not final products in the regulatory sense. They are inputs for further processing.

Who carries the obligation

Responsibility cannot be outsourced

  1. Manufacturer

    Must meet the manufacturer obligations under ESPR, including the passport requirements once the steel act applies. This is not limited to manufacturers established in the EU.

  2. Importer

    Checks that products from outside the EU meet the applicable requirements, including passport availability, before placing them on the market. This does not remove the manufacturer’s obligations.

  3. Authorised rep

    May perform specific tasks within the limits of the mandate, without assuming overall responsibility for product compliance unless the Regulation provides for it.

  4. Distributor

    Must verify compliance before making a product available, including access to a passport where a delegated act requires one.

ESPR Article 2 defines a digital product passport service provider as an independent third party authorised by the economic operator, which processes the passport data to make it available to those entitled to access it. That is what a platform is. The obligation stays with the operator who placed the product on the market, and no vendor can take it off you.

Blue excavator sorting a large pile of scrap metal at a recycling yard.

Identifiers

Three identifiers, not one

ESPR requires three types of unique identifier. Most coverage mentions only the first.

Identifier What it identifies
UPI Unique product identifier. The product, and the digital link to its passport. The primary reference point for all passport data.
UOI Unique operator identifier. An economic operator in the value chain, supporting attribution of responsibility.
UFI Unique facility identifier. A location or facility in the value chain, where a delegated act makes that relevant.

These are subject to substantial standardisation input through CEN-CENELEC JTC 24, which develops the horizontal standards for identifiers, data structures and interoperability.

Granularity

Does every coil need its own passport?

This is the question that decides the size of the project. ESPR Article 9(2)(d) lets a delegated act set the level, and the three levels do not map cleanly onto how steel is actually made.

ESPR level Steel equivalent
Model Steel grade designation (EN 10027-1), steel number (EN 10027-2), product form (EN 10079), treatment condition. Also CN code, product family, product number.
Batch Heat number, cast number, or lot / bundle number.
Item A single physical unit: coil number, sheet number, tube number.

This is the opposite of batteries, where every EV, LMT and industrial battery above 2 kWh gets its own passport because each unit has an individual service history. There is no single answer to granularity across sectors.

Proposed content

Four areas of mandatory content

Plus a set of voluntary inputs. The legal hooks sit in Article 9 and Annex III of ESPR.

  1. Product identification and classification

    Annex III (b-d) and (g-k). Built on identifiers the industry already issues.

  2. Producer identification and origin

    Who made it, where, and which facility. Already on the mill test certificate.

  3. Material compliance and substances of concern

    Article 7(5), with substances of concern defined in Article 2(27). The approach aims at targeted, actionable information rather than comprehensive chemical inventories.

  4. Product environmental and circularity information

    Carbon footprint and recycled content both sit here. This is where the new work is.

Readiness

The data exists. The format does not.

Technical data is already shared through mill test certificates, whose content and format are defined by EN 10204 and EN 10168. The gap the study identifies is exchange, not measurement: certificates are generated digitally, then sent as PDFs.

  • Technical data

    High value, low effort. Most steelmakers hold the data and EU standards already regulate this type of inspection document.

  • Carbon footprint

    Tool-supported at source, but heterogeneous on interoperability, granularity and structured exchange.

  • Recycled content

    Low operational and digital maturity, methodological inconsistency, limited upstream data availability. This is the real work.

Overlap

One code, two passports

If your steel goes into buildings, two regimes apply. The Construction Products Regulation (EU) 2024/3110 requires its own passport under Article 75, and that system must stay fully interoperable with the ESPR Registry and Web Portal.

The architecture described in the CPR feasibility study: a single data carrier, for example one QR code, gives access to the product’s digital information, but the interface then provides two distinct entry points, one for the ESPR passport and one for the CPR passport. Product identifier, granularity level and basic traceability are common. Other data points differ, because the two regimes have distinct objectives and calculation rules.

Practical consequence. A platform that models a passport as one flat record cannot serve a reinforcing bar.

What to do now

Four things that do not need the final text

  • Check whether your heat number is usable

    It exists on the certificate. Whether it is a queryable field linked to the analysis and the carbon figure is a different question, and in many plants it lives in three systems that disagree.

  • Decide which recycled content story you can defend

    The lowest-maturity data domain in the study’s own assessment. Your scrap and charge records decide this long before any software does.

  • Attach carbon to the product, not the reporting period

    ETS and CBAM figures are installation-level and annual. A passport is product-linked. That is a change of granularity, not a copy and paste.

  • Decide who owns this internally

    It touches quality, environment, IT and sales. Projects like this stall when they belong to all four and to none of them.

The groundwork is the same whichever way the act lands

None of those four steps depends on choosing a vendor, and none is wasted if a field moves between mandatory and voluntary. DPPVIEW handles model, batch and item identity, so a passport can attach to a heat, a coil or a bundle without rebuilding anything when the delegated act sets its granularity.

Discuss passport preparation

Sources

Every claim on this page is traceable to a primary source. Where only secondary reporting exists, we say so rather than presenting it as fact.

Last reviewed: . This page describes a proposal, not adopted law. We update it when the Commission publishes a draft delegated act.