For iron and steel, it is not expected that anything concrete will change in your company's practice this year, but something important will change on paper: the European Commission is working on the first delegated act that specifically addresses iron and steel. This is the document where it will finally be determined which data must be included in the digital product passport, for which products exactly, and from which moment. As long as that act does not exist, the implementation date remains an expectation and not an established fact.
For those to whom it matters: everyone who produces, imports or processes iron and steel and can at any time qualify as a manufacturer within the meaning of the regulation. For steel traders and metal processors who primarily source from others, this is primarily a moment to follow developments, not to respond to now. Those who produce or import themselves should keep an eye on the planning, because the time between publication of the delegated act and the moment when obligations come into effect is relatively short.
What a delegated act actually is
The regulation that makes the digital product passport possible, the ESPR, is a framework. It sets out the main lines: that a passport will be created, who is responsible for it, and what rights supervisory authorities and recipients will have. The detailed rules for each product group, including iron and steel, will be determined through separate delegated acts. Only in that act will it be specified which data are mandatory, which standards apply and what the passport will look like concretely for this product group. Without that act, there is a law that says that a passport will be created, but not yet how.
The Commission's work programme for the period 2025-2030 names iron and steel as one of the product groups for which a first delegated act is being prepared, with 2026 as the year in which publication is expected. After that, an 18-month period normally applies before the obligations actually come into force. This means that publication in 2026 could lead to obligations sometime in 2028, which is in line with the expectation that has been mentioned on this site for some time. Important to remember: this is a plan, not a commitment. Work programmes change, and the final text may differ in some respects from what is being prepared now.
What you can do this year
Even without a final text, it can be useful to start mapping out which products your company puts on the market, what role each player in the chain plays and what data on origin, composition and processing is already available. This work does not have to wait for the delegated act, because the basic data that a passport will eventually need does not fundamentally differ from the data that is already being recorded for other purposes, such as in purchasing contracts or quality certificates. If you bring structure to this now, you will not have to do it in a short time later.
This is also the time to check whether your own software supplier is already thinking about how data will need to be supplied in a standardised passport in the future. This conversation can take place now, even though the exact dataset is not yet determined. In the knowledge base per subject you will find an overview of the concepts and obligations known so far, with a direct reference to the official text on EUR-Lex.
How you can follow this for your own situation
Because the date and precise content are not yet fixed, the risk of incorrect preparation is mainly that you lock in too much too early based on text that may still change, or start too late because 2028 seems far away. A middle way is: map out your own situation now, and only take concrete steps once the delegated act has been published. By answering a few questions, you can see where your company stands now this gives an initial indication, without any obligation attached to it.
For those who want to know how this information is created and where the data about the planning comes from, the page how we compile the information which sources are followed and how often they are checked. Questions that frequently come up about timing and applicability are bundled at the answers to frequently asked questions.
Whether the digital product passport applies to your specific products and role in the chain, and exactly when, is a question that can only be answered with certainty once the delegated act is in place. For your own situation, a lawyer or the competent supervisory authority remains the appropriate contact point. If you want to keep track of what changes in the meantime, feel free to do the free quick-scan or go through the topics in the knowledge base.