how do I combine my CBAM reporting with the product passport
CBAM and the product passport exist alongside each other, not in place of each other
CBAM reporting and the digital product passport are two separate obligations that may happen to concern the same batch of steel, but they regulate something different and stem from different legislation. CBAM (Regulation (EU) 2023/956) concerns the carbon emissions released during the production of iron and steel outside the EU, and requires importers to report on this and, in future, also to purchase CBAM certificates. The product passport comes from the ESPR (Regulation (EU) 2024/1781) and concerns the product information of the semi-finished product itself: composition, origin, performance, and in future also environmental information. Both can exist independently of each other; there is no legal link stating that a CBAM report automatically forms part of the passport, or vice versa.
Who this affects, and who it does not
CBAM affects in the first place the importer who brings iron and steel from outside the EU into the market — that is the party bearing the reporting obligation and, in future, the certificate obligation. Anyone in the Netherlands who only resells steel that has already been produced within the EU, or that has been imported via another link in the chain, generally has no separate CBAM obligation. The product passport is distributed differently: it affects the manufacturer or importer who places the product on the EU market, but distributors and traders also play a role in passing on and verifying the passport. Anyone uncertain which role they fall under will find a detailed overview at who is responsible for the steel product passport and under am I an importer or manufacturer according to the ESPR. It is important to keep in mind: CBAM says nothing about what must be included in the product passport, and the product passport says nothing about CBAM certificates. Anyone who mixes the two obligations risks thinking they are complying with something that is in fact a different dossier.
CBAM is already running, the product passport comes later
CBAM is already in force: the reporting obligation under Regulation (EU) 2023/956 has been running since the transition period laid down in that regulation. The product passport for iron and steel does not yet have a fixed implementation date. The ESPR itself is the framework regulation; the specific requirements for iron and steel will come in a delegated act that still needs to be published. On this platform it is anticipated that around 2028 this obligation will come into force, but that is an estimate based on the work programme 2025-2030, which mentions a first delegated act in 2026 with obligations taking effect eighteen months later. As long as that act has not been published, there is no firm date, and it will only be mentioned here once it is known. Until that time, CBAM is therefore already running as a separate obligation, while the product passport is still being prepared.
How to keep this separate in practice
If you have to deal with both — or will have to — it is advisable to keep the two files separate in administration rather than trying to fit them into one system. CBAM reporting is about emissions data per shipment and per country of origin, often supplied by the manufacturer outside the EU; that data belongs in the CBAM reporting tool and the administration set up for it. The product passport is about product data that belong to the specific semi-finished product and that are made accessible via a QR code or comparable carrier for the entire chain. In practice, this means: first check whether there is a CBAM obligation (in the case of imports from outside the EU) and keep that reporting in order according to your own timeline, regardless of what happens with the passport. Then, as soon as the delegated act for iron and steel is published, you can see what data are already available — a CBAM file contains, for example, information about the country of production and the production process, which may also be relevant for the passport. This is not a legal obligation to share data between the two systems, but in practice it can save overlap in the investigative work. Whoever sets up the product passport via a service that combines the data of manufacturer or importer and hosts it can use the same underlying source data without CBAM and passport becoming administratively intertwined. For those who want to commit personnel or capacity to this, an overview of the choice between doing it yourself and outsourcing is available at hiring personnel or outsourcing.
Where this follows from: two separate regulations
The basis for CBAM lies in Regulation (EU) 2023/956, which establishes the reporting and, in future, certification obligation for iron and steel (and other goods) for importers. The basis for the product passport lies in Regulation (EU) 2024/1781 (ESPR), in which Article 39 governs the test, measurement and calculation methods used to determine product data — that article touches on how data for the passport are determined, but it does not establish a link with the CBAM methodology. Both regulations do not refer to each other on the point of data exchange, which confirms that these are two separate obligations that happen to affect the same flow of goods.
Who is already working with CBAM reporting can continue to conduct that administration separately as it is currently set up, and can tackle the preparation for the product passport separately as soon as there is more clarity on the delegated act for iron and steel — in particular on who in your own chain will have what role in future, from manufacturer to distributor or trader.
What this is based on
- Regulation (EU) 2023/956 (Carbon Border Adjustment Mechanism, CBAM)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
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
CBAM and the digital product passport look alike because they both ask for data on the origin and composition of steel. But they are two different regulations with a different purpose, a different legal basis and different data. Whoever mixes them up runs the risk of doing double work or — worse — thinking that one replaces the other.
What is expected of you
CBAM reporting is a customs and climate obligation, not product information
CBAM, governed by Regulation (EU) 2023/956, is about the carbon emissions released in the production of iron and steel outside the EU. The reporting is linked to the import: whoever imports steel reports on the embedded emissions of that specific shipment. This is different from the product passport, which keeps data about a product available throughout its entire lifecycle — also years after the sale. For a company with 10 to 100 employees that imports steel, this means in practice that two separate administrations run alongside each other: an emissions administration for customs, and a product administration for the passport.
The product passport requires different data than CBAM
The product passport under the ESPR (Regulation (EU) 2024/1781) concerns material composition, origin, repair and recycling information — not primarily CO2 emissions per shipment. Article 39 of that regulation describes how test, measurement and calculation methods for the data in the passport shall be established via delegated or implementing acts, per product group. For steel, it has not yet been published which methods these will be exactly. This means that a company cannot simply copy its CBAM figures to the passport: the calculation method, the scope and the level of detail may differ, even if ultimately they are about CO2.
Overlapping data can serve as a building block
The fact that the two regulations are not identical does not mean that the data are unrelated. Emissions data that have already been collected for CBAM — on the production process, the energy source used, the country of origin — are often the same underlying data that are also relevant for the passport. From a practical perspective, it makes sense to request that data once at the source (the manufacturer) and record it in a way that is reusable for both purposes, rather than requesting it twice separately.
The responsibility does not automatically lie with the same party
Under CBAM, the declarant upon import is responsible for reporting. For the product passport, responsibility lies primarily with the manufacturer, and upon import from outside the EU part of it shifts to the importer. Who exactly that is in a given situation is described on the page about who is responsible for the product passport for steelresponsibility for the product passport for steel
Where things go wrong in practice
An importer thinks that the CBAM report already being submitted to customs is also sufficient as a basis for the product passport, and therefore postpones setting up a separate passport process. When the obligation for steel takes effect, there is then no time left to request data from the manufacturer after all.
A company asks the foreign manufacturer for "the CBAM data" and receives an emissions figure per tonne of steel, without underlying information on composition, production process or country of origin — data that are required for the passport but do not appear in the CBAM report itself.
Two departments within the same company independently request the same kind of data from the same supplier, leading to confusion about which figures are the "official" ones when the manufacturer provides slightly different figures on two occasions.
A trader who does not import themselves, but resells steel that has already entered the EU with CBAM data, incorrectly assumes that those data also satisfy their own passport obligations. Which obligations apply to an intermediate party are described on the page about the obligations of a distributor or trader of steel.
A company assumes that because the CBAM regulation has already been in place for longer and is well established, the product passport is a matter of "just adding the same thing" — and thereby underestimates the time needed to collect new data from the manufacturer, especially when that manufacturer is located outside the European Union.
What you can document
- An overview of which data are already being collected for CBAM reporting, and which of these may potentially be reusable for the product passport.
- An internal agreement on which department or function is responsible for CBAM reporting and which for the product passport, including a fixed contact moment between the two.
- A file per manufacturer or supplier with the data received for CBAM, stored separately from the data specifically requested for the passport.
- A documented agreement with the manufacturer regarding the calculation method used for any emission data, so that it can later be determined whether that method aligns with what Article 39 of the ESPR for steel will prescribe once that is known.
- A record of the date on which data were received and from whom, so that if there is a later question about the accuracy of figures, it is clear where the data came from — relevant for those wondering who is liable if incorrect data appear in the product passport.
Once the delegated act for steel under the ESPR has been published and the calculation methods for emission and material data are established, this section will be supplemented with how CBAM data and passport data relate to each other precisely.
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, verified by a human on 2026-09-05. Is anything incorrect? Let us know — corrections are given priority.