Industry · Iron & Steel
The product passport for steel: set to be the first ESPR product group.
Iron & steel tops the ESPR working plan: the delegated act is expected for 2026 – originally planned for late 2025, pushed back by a year. The first stage is about information and data obligations for the intermediate product: carbon intensity, scrap content, alloy composition. Whoever produces, trades or processes steel will be the first to face the requirements.
- 2026Delegated act expected (pushed back from late 2025)
- ~2028Obligation at the earliest (act + ~18 months)
- Intermediate productInitially information and data obligations for steel as an input material
- CascadeData requirements travel on to processors, structural steelwork, machinery
01 — Situation
Why steel goes first.
In the first ESPR working plan (April 2025), the EU put iron & steel at the top of the priority list – ahead of textiles, tyres and aluminium. The reason: by volume and emissions, steel is the most important base material of European industry, and decarbonising production (“green steel”) needs robust, comparable product data instead of marketing claims.
As of July 2026: the delegated act had been announced for late 2025 and was pushed back to 2026 – it would be the very first product-specific ESPR act. With the usual transition period of ~18 months, the obligation would therefore apply from ~2028 at the earliest. All dates remain indicative; the current status is in the DPP timeline.
One particularity: steel is an intermediate product. What is expected first are information and data obligations for the input material – coils, sheets, sections, long products. But the data does not stop at the producer: processors, structural steelwork and machinery makers will have to pass it on in their own product passports and customer requirements. The data cascade runs up the supply chain.
02 — Requirements
What data the steel DPP is likely to require.
This only becomes binding with the delegated act – but from the ESPR, the working plan and standardisation work, the categories are clearly emerging:
Carbon intensity of production
Emissions per tonne of steel, differentiated by route (blast furnace/converter vs. electric arc, direct reduction in future) – the core of the passport and the basis for “green steel” evidence.
Scrap and recycled content
Share of scrap in the input material, origin and quality – central to circular-economy assessment and customer requirements from construction and automotive.
Alloy composition
Chemical analysis and alloying elements per batch – decisive for processors, recyclers and grade-pure recovery.
Traceability per batch
Identifier expected at batch/heat level rather than per piece – compatible with existing mill certificates (e.g. 3.1 certificates per EN 10204).
Data formats built for hand-over
Machine-readable, standardised data per EN 18219 et seq. that traders and processors can take into their systems – PDF certificates will not do.
Could you output the carbon intensity per batch in machine-readable form today?
A mill certificate as PDF is the status quo – the product passport demands structured data. In a short call, we will show you how far the path is from your current systems to that point.
03 — Approach
Steel readiness in five steps.
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1
Applicability check
Check your product portfolio against the working plan: which products fall under the expected act – and what will reach you additionally through customer requirements?
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2
Data audit for mill & trade
Take stock of carbon, scrap and analysis data: process control systems, LIMS, certificate management, ERP – where does what live, in what quality, at what level (heat, batch, line item)?
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3
Batch data model
Build the DPP data model along the heat/batch logic, compatible with mill certificates, CBAM reports and EPDs – collect once, use many times.
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4
Systems integration
Connect ERP and quality systems, define an identifier concept per EN 18219, and set up export interfaces for customers and the EU DPP registry.
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5
Pilot product passport
A real product – e.g. a coil or a batch of sections – with a complete data record and QR identifier as the blueprint for the rollout ~2028.
04 — FAQ
Frequently asked questions from the steel industry.
When does the Digital Product Passport become mandatory for steel?
The delegated act is expected for 2026 – originally late 2025, pushed back by a year. A transition period of typically ~18 months follows, so the obligation would apply from ~2028 at the earliest. The date is indicative; the only fixed dates so far are the battery passport (18 Feb 2027) and the EU DPP registry (deadline: 19 July 2026).
We are a steel processor, not a producer – does this still affect us?
Yes, in two directions: you will need to receive and process passport data from your upstream suppliers – and your own customers (construction, machinery, automotive) will demand that data from you in turn, partly even before the obligation. Anyone unable to pass steel data through becomes an inconvenient supplier.
Are our mill certificates (e.g. 3.1 per EN 10204) not sufficient?
In terms of content, certificates are an excellent data source – formally, they are not enough. The DPP requires machine-readable, standardised formats, unique identifiers and registration in the EU DPP registry. The good news: the certificate data flows straight into the DPP data model – nothing is collected twice.
We already report for CBAM – is that not the same thing?
No, but it overlaps. CBAM covers imports and their embedded emissions; the DPP covers the product placed on the EU market across its life cycle. The carbon data base is partly identical – we design data models so that CBAM, EPD and DPP are served from the same source data.
Does the passport apply per piece, per batch or per model?
The delegated act will decide. For steel as an intermediate product, an identifier at batch/heat level is expected – which fits the existing certificate logic. We build identifier concepts so that finer granularity later does not mean starting over.
Contact
The first ESPR product group has the shortest lead time.
Tell us briefly whether you produce, trade or process – you will get an honest assessment of which data obligations will reach you when and where you stand today.
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