do I need to record where the iron ore comes from in the passport

What you must concretely do

What is expected of you

The ESPR itself mentions in Articles 5 to 7 a series of categories on which product requirements can be based, such as durability, reuse, recyclability and CO2 footprint. Origin of raw materials is mentioned there as a possible point of attention in performance and information requirements, but which data for steel become concretely mandatory remains fixed only once the delegated act for this product group is published. What that means in practice is that a company with 10 to 100 employees cannot yet know with certainty whether "where does this iron ore come from" will become a mandatory field in the passport later.

Product-specific implementation via a delegated act

Article 10 of the ESPR describes what a digital product passport must generally be able to do: it must make data accessible in a standardized manner, linked to a unique identification of the product. Which data exactly that is for iron and steel will be filled in per product group. For a trading company or processor, this means that the question about ore origin can only be answered once it becomes known what that product-specific act prescribes for steel. On which data will be in the steel product passport? there is an overview of what is currently known about the expected content.

Distinction between ore origin and scrap origin

In the discussion around steel and circularity, a distinction is often made between primary raw material (ores) and secondary raw material (scrap). For the share of scrap in a melting batch, there is already more practical experience with recording, because this relates to the CO2 calculation of a product. A company now thinking about origin registration can more easily align with the way how do I establish the scrap share in the melt? describes that, even though that is different data than the origin of ores.

Origin as part of a broader CO2 or chain claim

Even if the origin of ore itself does not return as a separate, mandatory field, that information can become relevant as support for another claim, such as the CO2 emissions per ton of steel. A manufacturer demonstrating which emissions are associated with a particular batch of steel must typically say something about the raw materials used and the process. That process is described on how do I demonstrate CO2 emissions per tonne of steel?. For a medium-sized enterprise, this means that in practice, origin data is often already recorded somewhere in the chain, even without the law currently imposing an explicit, separate obligation to do so.

Where things go wrong in practice

A common first situation: a buyer asks the supplier for a statement on the origin of the ore, while no established form or obligation for this yet exists. This creates a document that is well-intentioned, but does not align with what the passport will actually require later.

A second situation: companies confuse the origin of the ore with the origin of the semi-finished product itself (the country where processing took place). These are two different data points, with different consequences — the second one relates, for example, to CBAM obligations on import, as described on what does CBAM mean for steel imports?, while the origin of the ore is a different data point that does not automatically coincide with it.

A third situation arises when a manufacturer considers origin data on ore as commercially sensitive and does not wish to share it with the trading partner compiling the passport. This touches on a broader question that is separate from the ESPR timeline, namely which data must be disclosed publicly and which must not; this assessment is described on must I disclose commercially sensitive data about my steel publicly?.

A fourth situation: a processor incorrectly assumes that because the standard and steel grade are already established, the origin of the raw material is thereby also implicitly settled. Standard specification and origin specification are two separate matters, even if they are sometimes brought together in a single certificate.

A fifth, more subtle situation: a company now records origin information in a form that does not align with the standardised, digital structure that Article 10 of the ESPR requires for the passport, meaning that this information will later need to be reprocessed.

What you can document

• Correspondence with the manufacturer or importer in which the origin of used raw materials is requested, even without an established form for this yet existing.
• Internal notes on which suppliers already routinely provide origin data and which do not, so that this is transparent once the product-specific delegated act is published.
• Documentation that is already kept for the scrap share in the melt, because that recording is often reusable in terms of its structure for other chain data.
• Substantiation used for CO2 claims per ton of steel, insofar as this already contains something on raw material origin.
• The existing inspection certificate 3.1, which sometimes already includes information on material origin; how this certificate relates to the future passport is described on how does an inspection certificate 3.1 relate to the product passport?.
• An overview of who within your own organisation or chain should have access to origin data once it becomes mandatory; see also who may view which data from the product passport?.

Once the delegated act for iron and steel is published, this will be supplemented with or, if so, how the origin of ore as a separate data point must be included in the passport.