what should I do if the QR code on my steel is damaged

What you must concretely do

What is expected of you

The carrier must keep the passport reliably accessible

Article 11 of the ESPR (Regulation (EU) 2024/1781) sets out requirements for the technical design and operation of the digital product passport, including the data carrier that provides access to the data. A QR code on a steel product or the associated packaging, label or delivery document must be able to continue to provide that access throughout the entire period in which the product is in circulation. For a company with 10 to 100 employees, this means above all a practical concern: steel passes through hands that are not gentle — it is stacked, sawn, welded, stored outdoors, blasted. A sticker or burnt-in code that becomes illegible after a few months does not meet the principle that the data carrier works during the period of use. This is not a matter of "apply a new sticker as quickly as possible", but of choosing in advance a carrier and placement that can withstand the expected use of that specific semi-finished product.

The unique identification code remains the key, even without scanning

Article 12 of the ESPR regulates the unique identification code that is linked to the product and the passport. This code is in principle not exclusively dependent on the QR image itself: the code is information that can also be traced in other ways, for example via batch or order details, a delivery note or the supplier's records. For the practice of a metal processor or steel trader, this means it is sensible not to rely solely on the readability of the code on the product, but also to keep a trail in your own order administration by which a batch or lot of steel remains linked to the correct passport, even when the code on the material itself is no longer readable.

Labelling and recognizability of the passport

Article 16 of the ESPR deals with labels and Article 17 with counterfeit labels. These articles are particularly relevant when, in addition to the QR code, a physical label bearing product information is applied. In practical terms, this means that a company cannot simply replace a damaged label with its own homemade label: the origin and accuracy of what appears on the label remains important, and a replacement label that does not align with what was originally issued can cause confusion or give an incorrect impression about the product's status.

Where things go wrong in practice

The code is applied in a location that cannot withstand the process. A QR sticker on a strip of steel that will later be shot-blasted, galvanized, or heat-treated often does not survive that process. If the placement of the code is not coordinated with the further processing that the semi-finished product must still undergo at the customer's facility, damage is more a matter of when than if.

There is no alternative access route if the code becomes unreadable. When only the physical QR code provides access and no link is established between order line, batch number, and passport, an employee with a damaged code is left empty-handed: there is then no other way to determine which passport belongs to which batch.

During internal processing, the code is lost without anyone noticing. Steel that is cut, remelted into smaller parts, or otherwise processed sometimes loses the carrier without this being consciously recorded. If afterwards no one checks whether the new units can still be traced back to the original passport, a gap in the chain emerges that only comes to light during a later inspection.

A damaged code is replaced with a self-made QR, without it being clear whether it points to the correct, current data. Improvising with your own sticker or your own code seems like a quick solution, but if that code does not correctly redirect to the existing passport, there is a risk that a new, incorrect label is effectively created — with all the sensitivity that Article 17 attaches to counterfeit labels.

There is no agreement with the supplier regarding a replacement carrier. Some companies receive steel with a QR code from the manufacturer or importer, but have no idea who to contact if that code is already damaged upon receipt. The result is delay, and delay upon receipt is harder to remedy than inspection upon dispatch.

What you can document

• An internal instruction on where and how the QR carrier is applied to different types of steel products, tailored to the processing that the material must still undergo.
• A record that links batch or order number to the passport, so that a batch of steel remains traceable even without a readable code.
• A fixed procedure for the moment of receipt: check whether the supplied code is readable, and what to do if it is not, including who should be notified.
• Agreements with suppliers regarding a replacement or supplementary carrier in case of damage, documented in the purchasing terms or in a separate annex to the contract.
• An overview of who within the company is responsible for managing passport data, so that a damaged code does not remain unaddressed until someone happens to come across it.

For companies that do not yet have these agreements in writing, it is worthwhile first to look at how do I approach the steel product passport step by step, in which the order of these choices is explained. It is also useful to determine what a supervisory authority asks for during an inspection of steel, because the documentation of traceability is often precisely the aspect that is scrutinized. Companies that already wish to experience how a QR carrier performs in practice may also consider whether already having a test version of the product passport made offers opportunities to test carrier placement and material choice before this is applied on a larger scale.