What obligations does a steel distributor or trader have?
Pre-sale inspection, not self-assembly
A distributor or trader of steel and iron does not compile the digital product passport itself, but checks whether it is present before the product is resold. This follows from the obligations that the ESPR assigns to this link in the chain: to verify that the required information, the CE marking (where applicable) and the data of the manufacturer or importer are present, and that the QR code referring to the passport works and belongs to the correct product. Anyone who purchases steel from a manufacturer or importer and resells it to a processor or construction company therefore does not assume substantive responsibility for the compilation of the passport, but is responsible for flagging if something is missing.
Distributor versus manufacturer: where the boundary lies
These obligations apply to anyone who trades in steel or semi-finished iron products without manufacturing the product itself, importing it from a country outside the EU, or placing it on the market under their own name or brand. As soon as a trader sells a product under their own brand, processes it in a way that may affect compliance with the requirements, or imports it themselves from a third country, the lighter obligations of a distributor do not apply, but rather the obligations that apply to a manufacturer or importer. Storage and transport also fall within the points of attention: anyone who stores or transports steel does so in a way that does not jeopardise the accuracy of the information in the passport, for example by making labels or data carriers illegible or exchanging them.
From when: no fixed date yet
The date on which these obligations for steel and iron will actually come into force is not yet fixed. The ESPR itself is in force, but the concrete requirements per product group — and with it the moment when the product passport and the associated inspection obligation for distributors become mandatory — follow from a delegated act that is established per product group. For the iron and steel sector, the first delegated act is expected in the course of the ESPR Work Plan 2025-2030, with a period of eighteen months between publication of that act and the date when the obligations come into force. As long as that act has not been published, there is no passport obligation for steel and iron and therefore no concrete inspection obligation based on it. As soon as the act is published, that date will be stated here.
What to do when purchasing and selling
In practice, the role of distributor or trader recurs in a number of steps. When a batch of steel arrives, it is checked whether the supplier — manufacturer or importer — has provided the required documentation and QR data carrier. If there is doubt about the correctness or completeness of it, this is reported back to that supplier, and the product is not resold as long as that doubt has not been removed. During storage and processing, the data carrier remains linked to the correct product or batch, even if a batch is split or repacked. Upon sale, the data carrier passes unchanged to the next link in the chain. And when requested by a market surveillance authority, the available documentation is provided and cooperation is given with any follow-up steps, such as the withdrawal from the market of a batch for which the information has been found to be incorrect.
Where this is stated: Articles 30 and 31 ESPR
These obligations follow from Articles 30 and 31 of Regulation (EU) 2024/1781 (ESPR), which regulate the obligations of distributors and traders, including the situations in which the heavier obligations of manufacturers or importers apply to them. For the precise wording and the exceptions that the regulation itself mentions, the official text is the authoritative source.
Anyone currently trading steel or iron can already check which suppliers and products will fall under the first delegated act, and arrange their own procurement and sales administration so that a QR data carrier or documentation identifier can be easily linked to a batch. Once the delegated act and entry into force date are known, they will be added here.
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
A distributor or dealer is, under the ESPR, the party that places steel or steel semi-finished products on the market without being the manufacturer or importer. This is an intermediate position: you have neither made the product nor brought it into the EU from a third country, but you do sell it on. Articles 30 and 31 of the ESPR (Regulation (EU) 2024/1781) impose a number of compliance duties on this party, but no substantive compilation duty. Anyone uncertain about which role a company actually falls into will find a more detailed explanation on who is responsible for the product passport for steel?.
Check whether the product passport is present
Before steel is placed on the market, a product passport must, as a matter of description, accompany it if the product group already falls under this requirement. For a company with 10 to 100 employees, this means in practice that the purchasing department or the warehouse worker receiving goods has a control checkpoint: is there a QR code or link to a passport, and does it actually work. This is not a legal test but a factual one — is the passport there, and can it be opened.
Check whether the mandatory information is on the product or packaging
In addition to the passport itself, certain data must, according to articles 30 and 31, be directly visible, such as the name and contact details of the manufacturer or importer. For a trading company, this means that the incoming inspection not only looks at the passport but also at the accompanying documentation and labels on pallets or coils.
Do not supply if it is clear that the passport is missing or incorrect
When a distributor knows, or on the basis of available information should know, that a passport is missing or clearly incorrect, that same party is expected not to place the product on the market until this has been resolved. This is a different position from that of the manufacturer: no substantive verification of technical data is expected, but reasonable diligence in the information available.
Pass information on to the next party in the chain
The passport and associated data do not need to be compiled again, but must remain intact as they move through the chain. For a trading company that cuts, repackages or combines steel with other batches, this is one of the more challenging points: the passport must remain linked to the correct product, even if the physical unit changes.
Cooperate with requests from supervisory authorities
At the request of a supervisory authority, the distributor is expected to have data on origin and onward supply available. Who carries out that supervision in the Netherlands is described on which supervisory authority checks the product passport in the Netherlands.
Where things go wrong in practice
A few situations come up remarkably often in trade.
Resale without checking the link. Steel is purchased with a valid passport, but when resold to the next party only the traditional packing list is sent and the QR code or link on the packaging is lost. The recipient then effectively has no passport, even though one did exist.
Own labelling without retaining the origin information. When large coils are broken down into smaller deliveries, sometimes a new label is created without taking over the original manufacturer details. That comes close to the question of what changes if a company sells steel on under its own brand — an edge case that is explained on I sell steel under my own brand — what obligations do I incur?.
Relying on the supplier without factual checking. A trading company assumes that 'the manufacturer will have sorted that out' and never checks whether the QR code actually leads to a working passport. During an inspection, the link turns out to be dead, expired, or pointing to the wrong product.
Import via an intermediary outside the EU not recognized. Sometimes a supplier is regarded as a 'ordinary commercial partner', while in fact it is the first party within the EU to place the product on the market. In that case, obligations shift towards the importer, not towards the distributor — see more on this my manufacturer is outside the european union — who arranges the product passport then?.
Sale via own webshop or marketplace without passport reference. When selling steel semi-finished products online, the passport is sometimes not included in the product page, while the obligation to make it available does not disappear with online sales. More on this is found on what does the product passport mean if I sell steel via an online marketplace?.
What you can document
For a trading company it is practical to establish a number of matters structurally, also without requiring a lawyer for each case:
- A fixed receiving inspection upon purchase: is the passport present, does the QR code work, do the data match the delivery.
- An internal agreement on who may block delivery in case of doubt about a missing or incorrect passport, and to whom this is reported.
- A procedure for maintaining the passport link when cutting, repackaging or combining batches.
- An overview of suppliers with an indication of whether they act as manufacturer, importer or other distributor — relevant in case of doubt about your own role, see also am I importer or manufacturer according to the ESPR?.
- A retention plan for the data that must be able to be shown upon a supervisory request.
- A note on who within the company keeps track of this process, and whether this is handled internally or outsourced — a consideration that is further elaborated on do I need extra staff for the product passport or can I outsource it.
These records are not a legal obligation in themselves, but make it easier to demonstrate that the control duties under articles 30 and 31 of the ESPR are met structurally, rather than incidentally.
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.