Do I register steel per batch or per piece?

What you must concretely do

A coil, a bundle of bars or a pallet of sheet steel arrives as a single unit, but is often cut up, divided and resold in parts. The question of whether the digital product passport must then be created per batch or per piece is precisely where many steel traders and metal processors get stuck. The ESPR itself does not prescribe a fixed choice between "per batch" or "per piece" — the regulation works with the concept of product and unique identification code, and leaves the practical implementation to depend on how a product is traded and used.

What is expected of you

Make each product identifiable

Article 12 of the ESPR requires a unique identification code for the product to which the passport relates. For a company of average size, this above all means a choice to be made in advance: is the coil as a whole considered a "product", or is each cut-off part that is later sold separately considered its own product? That choice determines whether one code per batch suffices, or whether each cutting requires a new code and thus a new passport. Whoever reasons from their own sales process here — what is invoiced and delivered as a separate unit — usually arrives at a workable answer. Practical guidance on assigning that code is described on how do I give each product a unique identification code?

Ensure that the passport describes the correct level

Article 11 concerns the technical design and operation of the passport, and thereby indirectly also the question of which information belongs at which level. A passport drawn up at batch level describes properties that apply to the entire batch: composition, origin, general mechanical properties. As soon as a part of that batch receives its own processing — a coating, a specific heat treatment, a dimensional finishing — the question arises whether that part is still fully covered by the batch passport, or whether additional or separate information is needed. For companies that process materials themselves, this is a recurring decision point at each new processing step.

Safeguard the link between physical product and digital passport

As soon as a batch is split up, the QR code must go with it. When delivery is per batch, there is often one data carrier for the entire shipment; when delivery is per piece, each piece must be traceable back to the correct data. This directly relates to the question of how that code gets onto the material, which is addressed on how does the QR code for the product passport get onto my steel? and, for smaller or cut parts, on how do I get a QR code on a very small piece of steel? A company that decides to register at batch level but in practice sells per piece runs the risk that the code no longer matches what is actually delivered.

Where things go wrong in practice

A steel trader takes delivery of a coil with one passport and cuts it in their own warehouse into ten parts that are sold separately to ten different customers. Without adjustment, all ten deliveries refer to the same passport, while the customer reasonably expects the passport to match their specific piece of steel.

A construction company buys steel bars in bulk and processes part of it immediately, while another part remains in storage for months. When the remainder is reused or resold, it is no longer clear whether the original batch passport is still applicable, especially if a new delivery with a different composition has been added in the meantime.

A metal processor registers per production order in their own ERP system, but that order does not correspond one-to-one with the batch as delivered by the supplier. When linking the passport to internal systems, a mismatch then arises between batch thinking at the supplier and order thinking at the buyer — a problem that often only becomes visible when setting up a link, as discussed on can I link the product passport to my ERP or inventory system?

An importer registers a batch centrally in the European system, but splits the shipment on arrival to different customers without each part receiving its own traceable entry. This relates to the question of what exactly must be included in the central register, worked out on what is the register of digital product passports and what must I enter in it?

A company assumes that "per batch" is always cheaper and simpler, and chooses it without looking at its own sales process — with the result that it still has to split per unit afterwards, with all the additional administration that comes with it.

What you can document

• An internal agreement on the identification level: is the product passport created by default at batch or unit level, and under what circumstances does that differ.
• An overview of the company's own processing steps (cutting, coating, heat treatment) with the question for each step whether this requires a new, separate product passport or remains under the existing batch product passport.
• A procedure for the moment of splitting: who is responsible for creating a new code and applying a new data carrier to the split part.
• A fixed link between the batch or order numbers in the company's own ERP system and the identification codes from the product passport, so that batch and unit level do not become disconnected.
• Agreements with suppliers on the level at which they supply product passports, so that this aligns with the way the material is sold further down the chain.
• A note on the retention period and findability of product passports after splitting, in connection with the general question how long a product passport must remain available, described on how long must a product passport remain available?

Once the delegated act for iron and steel is published, it is expected to provide more clarity on the identification level that applies specifically to this product group. Until then, the safest route is to take the company's own sales and processing practice as the starting point, and base the choice between batch and unit on that.