Does the digital product passport apply to my steel?
The framework is broad, the passport requirement for steel not yet
The ESPR (Regulation (EU) 2024/1781) is set up as a framework regulation that is in principle applicable to virtually all physical products placed on the market or put into service in the EU — and semi-finished products of iron and steel fall within that scope in principle. But the fact that the framework can be applicable does not mean that there is now already an obligation to have a digital product passport. The digital product passport itself is an instrument that is only activated per product group: the European Commission must first adopt a separate delegated act specifically concerning iron and steel for this purpose. As long as that does not exist, the obligation for this product group does not yet exist, even though the ESPR provides the legal framework within which that will happen in due course.
Which products this applies to and which it does not
The ESPR focuses on physical goods placed on the market or put into service in the EU. Semi-finished products of iron and steel — plates, profiles, bars, tubes and similar products — are that kind of physical goods, and thus fall in principle within the scope of the regulation. Outside the scope of application are categories that the regulation itself excludes, such as food and animal feed, medicinal products, living plants, animals and micro-organisms, products of human origin, and vehicles insofar as they are already covered by specific other legislation. For steel traders, metal processors and construction companies, that distinction is mainly reassuringly clear: it concerns an exceptions list for quite different product categories, not something that touches on metal semi-finished products. So it is not the case that some types of steel would and others would not fall within the scope of the ESPR — the distinction that does matter is whether a delegated act with a digital product passport has already been adopted for the product group 'iron and steel'. That is a separate step, separate from the question of whether the product falls within the scope of application of the framework regulation.
The date is not yet fixed
There is no fixed date yet on which the digital product passport for iron and steel becomes mandatory. What is established is the way in which this will proceed: the Commission is working with a work plan for the period 2025-2030, which states that the first delegated acts under the ESPR are expected in 2026, and that concrete obligations typically only come into force eighteen months later. Whether and when iron and steel will be dealt with in that work plan, and what exact date follows from it, is not yet known. Until the moment the Commission publishes a delegated act for this product group, there is no obligation to have a digital product passport for semi-finished products of iron and steel. As soon as that act is in place, the date that follows from it will appear here.
What this means for steel trading
In practice, this amounts to a number of steps that must be taken in logical order. First, it is important to keep track of whether and when the Commission publishes a delegated act for iron and steel — that is the moment when a concrete obligation and a concrete date arise. Until that time, there is no legal obligation, but that does not preclude customers, chain partners or own sustainability objectives from already requesting data that would later be included in a product passport, such as origin, composition and recycled content. Organizing that data is therefore something that can be useful now, regardless of a legal obligation. Furthermore, it is wise to realize that the requirements for the passport itself — which data it must contain, how it will be made accessible via a QR code or similar data carrier, and how long it must remain available — are laid down in the delegated act for the specific product group. These requirements do not yet exist for iron and steel, which means that there is currently no final content of the passport that can be determined.
Where this is stated: Article 1 and Article 9 ESPR
The fact that the ESPR has a broad scope, with a limited list of exceptions, follows from Article 1 of the ESPR (Regulation (EU) 2024/1781), which describes the subject matter and scope of the regulation. The fact that the digital product passport is a separate instrument that is introduced via delegated acts for each product group follows from Article 9 of the same regulation, which regulates the system and requirements of the digital product passport.
What to do now
Those who already work with semi-finished iron and steel products can best keep track of the publication of a delegated act for this product group — it determines both the precise date and the precise content of the obligation. Until that time, it is no unnecessary luxury to get data on the origin, composition and processing of your own steel in order in advance, so that no backlog needs to be made up when the act is published.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 1 (subject matter and scope)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
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
The ESPR (Regulation (EU) 2024/1781) is a framework regulation. Article 1 makes clear that the regulation itself does not impose a passport obligation per product group, but outlines the framework within which that obligation is developed per product group. For steel and steel products, this means: the question "does it apply to my steel" cannot yet be answered with a simple yes or no at this moment, because the answer comes in a separate decision per product group. What a company is expected to do in the meantime breaks down into a few practical points.
Determining whether your product falls under a designated product group
Article 1 of the ESPR stipulates that the regulation applies to products that fall within the scope of application as defined by delegated acts. For a company with 10 to 100 employees, this means it is important to follow which product groups from the steel sector are designated first. Not every semi-finished product automatically comes into focus on the same date; some groups are addressed earlier than others. An overview of what can precisely fall under the ESPR is on the page on which products of the steel sector fall under the ESPR.
Understanding that "steel" is not a uniform category
Article 9 of the ESPR describes what a digital product passport must contain once it becomes mandatory for a product group, but says nothing about which steel products those are. Hot-rolled sheet steel, cold-rolled strip, profiles, tubes and reinforcing steel are not automatically an identical category for the legislator. A company that trades or processes multiple types of semi-finished products does well to examine per product line whether and when it comes into view, rather than assuming that "steel" as a whole falls under the regulation at one point in time.
Keeping the distinction between semi-finished product and finished product clear
For metal processors and construction companies, this is often the most difficult point: a sheet of steel that one company purchases as raw material is already a processed component for another company. The ESPR obligation can land at different points in the chain, and this also determines who assembles the passport and who merely passes it on. More on this is on the page on whether the product passport for semi-finished steel products applies.
Following when the obligation becomes concrete
Article 1 links the actual obligation to delegated acts that the European Commission establishes per product group. For an entrepreneur, this means that there is no fixed date to work towards now, but there is a moment to watch for: the publication of that act for the own product group. What a delegated act precisely is and why it is decisive for what a company is expected to do is explained on the page on what a delegated act is and why it determines what must happen.
Where things go wrong in practice
A first situation where things go wrong: a trading company assumes that because "steel" is mentioned in the media as an example sector of the ESPR, all steel products in its assortment are immediately subject to the regulation. This is too quick a translation of an announcement into an obligation that is established separately per product group.
A second situation: a construction company processes purchased profiles into a finished product and assumes that the obligation, if it comes, automatically lies with its own supplier. Whether that is the case depends on where in the chain the passport is assembled and what role a processing company is assigned in that — a question that turns out differently per product group.
A third situation: a metal processor with thirty employees thinks that the size of the company determines whether the regulation applies. However, the ESPR links the obligation to the product group, not primarily to company size, although there may be special provisions for smaller companies. This distinction is addressed on the page about whether the product passport also applies to small companies.
A fourth situation: a company passively waits until "the passport becomes mandatory for steel" without following which delegated acts are specifically being prepared for its own product group, and is thus caught off guard by a date that was actually known for some time in the trade press.
A fifth situation: internal departments — procurement, sales, quality assurance — each have a different understanding of whether the passport already applies, because no one has documented which product lines fall within an already designated product group and which do not. This leads to contradictory statements to customers.
What you can document
- An overview of all product lines and semi-finished steel products that the company trades or processes, with the question for each line whether it falls within an already designated or still-to-be-determined product group. See the page about for guidance which products of the steel sector fall under the ESPR.
- A note for each product line indicating who in the chain (supplier, own company, or customer) would be responsible for compiling the passport once it becomes mandatory for that group.
- A fixed review moment — for example every quarter — to check whether new delegated acts have been published that are relevant to your own product groups.
- An internal note on the difference between your own semi-finished products and end products, so that procurement and sales provide the same explanation to customers and suppliers. Support for this is provided by the page about what a digital product passport for steel is exactly.
- A brief summary for management of what the ESPR could mean for your own sector, so that a decision on preparation is not delayed until a date is already set. Background information for this is on the page about what the ESPR changes for the steel sector.
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.