is there already an industry standard for the steel product passport

What you must concretely do

Those who follow multiple trade organizations in the steel sector will notice that there is talk of standards, working groups and joint positions towards Brussels. That raises a logical question: is there already a trade standard for the steel product passport that a company can join? The answer at this moment is: not yet established. The ESPR (Regulation (EU) 2024/1781) lays the foundation for ecodesign and information requirements, but the concrete, product-specific implementation for steel comes through delegated acts that do not yet exist.

What is expected of you

Prioritization via Article 18

Article 18 of the ESPR regulates how the European Commission determines which product groups are first in line for delegated acts, and on the basis of which criteria this occurs. For a steel trader or metal processor, this means above all that the order and timing of regulations for iron and steel lie outside their own sphere of influence — and also outside that of a trade organization. A trade standard that anticipates this prioritization risks not aligning with what the Commission ultimately establishes. For a company with 10 to 100 employees, the practical conclusion is that following your own trade organization is useful for signals, but is not a substitute for the official text.

Requirements for actors in the supply chain (Article 38)

Article 38 describes which obligations may apply to parties in the supply chain, thus not only to the manufacturer but possibly also to importers, distributors and other links. This article is relevant for trade organizations because it is precisely the type of provision for which a joint position or shared interpretation would be useful — for example on who supplies what data within a chain from trader to processor to construction company. As long as the delegated act for steel has not been published, this remains a matter of preparing on the basis of the general text, not of an elaborated practical rule.

Test, measurement and calculation methods (Article 39)

Article 39 concerns the methods by which product properties must be tested, measured or calculated. This is precisely the kind of technical detail where a trade organization can play a role, because standardization bodies and sector associations often provide input for such methods. For an individual company, this means that the question "which measurement method applies to my steel product" is not yet answered, and that waiting for a published method is more sensible than devising an approach on your own.

Ecodesign, performance and information requirements (Articles 5 to 7)

Articles 5 through 7 form the core of what ecodesign entails and what types of requirements — performance requirements and information requirements — can be imposed. This is the framework within which a future standard for steel must fit. An industry organisation that is already working on a format for data exchange is thus doing so within the contours of these articles, but without the final specification for steel being in place yet. For an entrepreneur, the practical question is not so much "which standard applies", but does the digital product passport apply to my steel in general, and on what timeline it becomes concrete.

Where things go wrong in practice

A few situations regularly come up with companies that respond too early or too late to what an industry organisation communicates.

First: a company adopts a draft format from its own sector association as definitive, and sets up its internal systems accordingly. If the delegated act differs, that work must be redone.

Second: they wait entirely for the industry organisation to "say something", while their own data organisation — batch numbers, composition certificates, origin data — is not yet in order. That is useful work to do regardless of which standard comes, independently.

Third: different locations of the same company each follow their own regional industry organisation or contact person, resulting in different assumptions internally about what is coming. This is particularly relevant for companies wondering how do I arrange the product passport if I have multiple locations, and deserves a central approach rather than separate local interpretations.

Fourth: a company incorrectly assumes that following an industry consultation is sufficient to comply with an audit, whereas a supervisor actually looks at the official, published requirements and not at sector agreements. That distinction is precisely why it is useful to know in advance what does a supervisor ask during an inspection on steel, separate from what your own sector discusses internally.

Fifth: staff are trained on a working method based on a preliminary industry recommendation, without space being built in to adapt that training later once the final rules are known.

What you can document

Even without an established industry standard, there are a number of things to document, so that a company does not start from scratch once the rules become concrete.

• An overview of which industry organisation(s) are relevant for your own product range, and which contact person or newsletter is followed for updates.
• An internal note on which assumptions from industry communication are or are not marked as provisional, so that later you can explain what a decision was based on.
• A data overview of what origin, composition and processing data is already available, regardless of the ultimate format — this aligns with the question what can I do now while the rules are not yet final.
• A schedule for when a test version of your own product passport can be created, once there is sufficient clarity; see also whether can I already have a test version of my product passport made.
• A training schedule for staff that deliberately leaves room for adjustment, in line with the question how do I train my staff to work with the product passport.

Once a delegated act for iron and steel is published, and it thus becomes clear whether and how an industry standard fits into it, this will be supplemented here.