According to which method must I measure the values for the passport?

What you must concretely do

What is expected of you

The ESPR provides in Article 39 that values used for the product passport must be based on test, measurement or calculation methods that are reliable, accurate and reproducible. This is not a standalone requirement: Article 39 works together with Articles 5 to 7, which set out which performance and information requirements are established per product group. For steel and other iron products, those methods are filled in via delegated acts per product group — the specific method for steel is not yet in place.

The method must be reliable, accurate and reproducible

In practice, this means that a company of 10 to 100 employees cannot simply apply its own calculation method and present it as definitive. The regulation requires a method that another company, using the same raw material and the same process, would arrive at a comparable result with. For a metal processor who, for example, states the proportion of scrap in the melt, or calculates the CO2 emissions per tonne of steel, this is reason not to rely on an internal Excel model without substantiation, but on a method that aligns with what will be established in the delegated act. See also on this how you record the proportion of scrap in the melt and how you demonstrate the CO2 emissions per tonne of steel.

The method follows from the product group-specific implementing rules

Articles 5 to 7 of the ESPR determine that the requirements are worked out per product group, and Article 39 builds on this by determining that the associated measurement method is also established per product group — not generically for all products at once. For a steel trader or construction company, this means that the method established for, for example, furniture or electronics, is not automatically transferable to semi-finished iron and steel products. There is a wait for its own specification for this product group, and until then there is no legally prescribed calculation method to rely on.

Existing standards can serve as a basis, but are not automatically the ESPR method

Many companies already work with standards such as EN standards for steel grades, or with CO2 calculations according to existing sector agreements. Article 39 allows for alignment with recognised standards, but this only happens with certainty once the delegated act refers to a specific standard or test method. For a company that already works with a certificate according to EN 10204, it is worthwhile to consider how that certificate relates to the future passport — see how an inspection certificate 3.1 relates to the digital product passport. That certificate already demonstrates something now, but it is not yet certain whether it covers the same method that will be required for the passport later.

The method must be verifiable by third parties

A recurring element in Article 39 is that the method used provides the possibility of verification: a value in the passport must be traceable to the way it was determined. For a company of this size, this means that not only the result (a number) is recorded, but also how that number came about: which measuring equipment, which sample, which calculation formula. For information about who must check who is permitted to access those underlying data, read more at who may access which data from the product passport.

Where things go wrong in practice

A first situation that often comes up: a company uses an internal calculation method for CO2 emissions that was built for another purpose (for example, customer reporting), and applies that method one-to-one to the passport without checking whether it aligns with what the ESPR method will require later.

A second: a supplier of alloys supplies values without mentioning which test method was used, so the recipient receives a number that cannot be traced back. This also touches on the question which alloy elements must be reported — a reported percentage without method is difficult to verify.

A third situation: a company confuses the standard by which the steel grade is designated with the method by which a performance value (such as recyclability) has been determined. These are two different things — the standard says something about the type of steel, the method says something about how a property has been measured. To keep these apart, one can compare this with how steel grade and standard are established versus how recyclability is demonstrated.

A fourth: a company does not wait for the definitive method and publishes values based on an assumption, without making that assumption recognizable as such. As soon as the delegated act appears, this can lead to necessary adjustment of already published product passports.

A fifth: a company assumes that the measurement method for the product passport is the same as the method used for CBAM reporting. Both regulations have their own definitions and calculation methods; to compare these, more information on that other regulation can be found at what CBAM means for the import of steel.

What you can document

• An overview of which values are already being measured or calculated, and according to which method this is done (internal protocol, standard, certificate).
• The source reference for each value: which test report, which sample, which calculation formula forms the basis.
• A note for each value that has not yet been determined according to an established ESPR method, so that it can be easily found and adjusted later.
• Correspondence with suppliers about the method by which they have determined their values (for example alloying percentages or scrap content).
• A comparison between existing certificates (such as 3.1 inspection certificates) and the data that the product passport will request, so that it is clear which part is already covered and which part is still missing.
• A log of changes in measurement methods, so that in a later inspection it is clear which method was used at which time.