How do I record the scrap share in the melt?

No fixed calculation method yet for scrap content

The share of scrap in iron and steel melts will likely be included as an information element in the future digital product passport, but how that share must be precisely measured, calculated and substantiated is not yet established. The ESPR (Regulation (EU) 2024/1781) provides in Article 10 the general framework for what belongs in a digital product passport — think of material composition and environmental characteristics of a product — and in Article 39 the power to establish specific test, measurement and calculation methods with which such data must be determined. For iron and steel, that second step, the product-specific calculation method for scrap content, is not yet there. So there is indeed a legal framework that indicates that this type of data could become relevant, but no established way to calculate or document them yet.

For whom this will apply, and for whom not

This topic affects manufacturers and importers of semi-finished iron and steel products who will soon have to supply a digital product passport under the ESPR. This specifically concerns the share of scrap processed in the melt as part of the material composition of the product — not the origin of the scrap in the broad sense, not CO2 accounting via other regulations such as CBAM, and not voluntary sustainability labels that producers already carry now. These latter often already exist longer and follow their own definitions; the product passport under the ESPR will, once the calculation method is available, prescribe its own, harmonised way of recording that does not automatically have to be the same as what a manufacturer already puts on a certificate or in an environmental statement. For end products that do not fall under the iron and steel category, or for recycling processes that do not involve a melting step, this specific question is not at issue.

When the calculation rules become known

There is no concrete date. What is certain is that the Commission is working according to the ESPR work plan 2025-2030, in which the first delegated acts are expected in 2026, with an obligation period that usually follows eighteen months later. For iron and steel, it has not yet been published which product-specific requirements — including any requirements on scrap content — will be included in such an act, and therefore also not from when an obligation to record would apply. Until a delegated act for this product group is published, Article 39 remains a power of attorney without substantive content for this specific data. As soon as that act is published, it will be mentioned here, including the actual calculation method and the date on which the obligation takes effect.

What can be done now

Anyone who is already working on this question would be well advised to start with their own production records, not with the legislation text. In practical terms, this means: documenting what proportion of the input per melt or per batch consists of scrap, and linking that to the origin and any certificates of the scrap supplier. Many steel producers already record this for their own quality or procurement purposes; those data form a good basis, even though the format in which the ESPR will want them is not yet known. A second step is to keep track of the distinction between scrap from different origins — for example production waste versus scrap that has been returned after use — insofar as that distinction can already be made now, because this kind of subdivision appears frequently in earlier EU legislation on recycling content. A third step is to follow the publication of the delegated act for iron and steel, because that will determine whether, and if so how, the scrap proportion in the passport must be included and whether third-party verification is part of that. Until then, the main thing is to keep the source data in order, so that converting to the final calculation method does not require reconstructing data from years ago.

Where this is based on: Article 10 and 39 ESPR

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what types of information can be included in a digital product passport, including data on material composition and origin of raw materials — the category under which the scrap proportion in the melt would fall. Article 39 provides that the Commission shall establish test, measurement and calculation methods to determine how such data must be measured or calculated, so that the information in the passport is reliable and comparable. For iron and steel, that second, supplementary step has not yet been taken, which explains why there is currently no concrete calculation rule or documentation requirement for the scrap proportion.

Anyone who wants to follow this topic should keep an eye on the publication of the product-specific delegated act for iron and steel; once it appears, this page will be updated with the actual calculation method and entry into force date.

What this is based on

The regulation itself can be found on EUR-Lex. We provide references for each statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

Scrap share as part of the product passport

The digital product passport contains product information that will be further developed per product group in a delegated act based on Article 10 of the ESPR (Regulation (EU) 2024/1781). The share of scrap in the melt — the percentage of recycled steel processed in a charge — is in line with the data that are already standardly requested regarding origin and composition. For a company with 10 to 100 employees, this means mainly that the figures which may now only be kept internally for quality assurance must subsequently also be traceable and transferable externally. Whoever records that percentage per charge or per production batch now will only need to arrange the connection to the passport upon implementation of the obligation. Whoever does not yet do so must set up a registration process that does not yet exist.

A substantiated and traceable calculation

A scrap share is not a standalone figure — it must be traceable to a calculation or measurement that is consistent with a recognised method. Article 39 of the ESPR provides that the test, measurement and calculation methods for the data in the passport must be reliable, accurate and reproducible, and that, where possible, harmonised standards are adhered to. For a medium-sized metal processing company, this means that an estimate based on rules of thumb ("usually around forty percent") is not sufficient; there must be a calculation method that is traceable per charge to input materials, weighing receipts or charge protocols. More information on how such values must be substantiated can be found on the page about the method for measuring values for the product passport.

Traceability of scrap origin

The scrap share says something about the quantity, but without origin the figure is of little significance. Scrap from own production waste, scrap from third parties, and scrap purchased via intermediaries each have different traceability. For companies that melt themselves or that pass on melt data to customers, this means that the origin registration of the scrap must be placed alongside the origin of primary iron ore. This directly raises the question of how the origin of raw materials is recorded, as discussed on the page about recording the origin of iron ore.

Integration with existing quality documentation

For many steel companies there is already a 3.1 inspection certificate in which the chemical composition and physical properties of a charge are recorded. The scrap share is currently not usually a mandatory part of that certificate, but the underlying charge administration often already contains sufficient data to derive it nonetheless. How that certificate relates to the new passport obligations is explained on the page about the relationship between the 3.1 inspection certificate and the product passport.

Where things go wrong in practice

Estimation instead of registration. A foundry works with a fixed formula of scrap and primary material, and has reported "approximately 30% scrap" for years based on an old process calculation. There is no current, per-charge substantiation anymore, whilst it is precisely that traceability that will become relevant later.

Scrap from mixed sources. A processor buys scrap via multiple suppliers, sometimes sorted, sometimes mixed. The share in the melt is calculated on the basis of the total weight of scrap that enters the furnace, without distinction by origin or quality. Once origin is requested alongside share, that breakdown is missing.

Difference between accounting and physical share. Some companies calculate the scrap share on an annual basis (total scrap purchases divided by total production), not per charge. That gives a company average, but no value that can be attributed to a specific product or specific batch — and the passport is after all product-bound.

Passing on without substantiation. A trader passes on a scrap percentage from a manufacturer to a customer one-to-one without knowing which measurement or calculation method that figure is based on. If the customer asks for substantiation, it is not available because the intermediary has only taken over the figure.

Confusion with CO2 figures. The scrap share is sometimes treated as synonymous with low CO2 emissions, whereas it is separate data with its own calculation basis. Those who equate the two run the risk that the substantiation of the CO2 value — described on the page about demonstrating CO2 emissions per tonne of steel — does not align with the substantiation of the scrap percentage, resulting in contradictory figures in the product passport.

What you can document

Charge recording: per melt charge the quantity of scrap and the quantity of primary material, by weight, with date and furnace number.
Scrap provenance documentation: supplier, declaration of origin (own production waste, external scrap, imported scrap) and any sorting certificates.
Calculation method: a defined calculation procedure (for example scrap weight divided by total charge weight) including the source of the weighing data, so that the result is reproducible.
Link with quality documentation: a fixed location in or alongside the inspection certificate 3.1 where the scrap share per charge can be found.
Change log: an overview of when and why the calculation method was adjusted, so that older and newer figures do not exist side by side without explanation.
Distinction between average and per-product value: a clear note or annotation whether a reported percentage is a yearly average or a value attributable to one specific batch.

This documentation is also important when determining the broader composition of the material, such as the question of which steel grade and standard are included in the product passport and when substantiating the recyclability of the steel for the passport, for which the scrap share is one of the underlying data points.

This is not legal advice. This page provides general information about the legislation that this platform deals with. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something not right? Let us know — corrections are given priority.