What does the product passport mean if I import steel from outside the EU?
As an importer, you become responsible for the passport yourself
Anyone who imports steel from outside the EU and places it on the European market takes on a specific role under the ESPR — not that of a pass-through party, but that of a responsible party. The ESPR (Regulation (EU) 2024/1781) establishes in Article 29 that importers must verify whether a product for which a digital product passport is mandatory actually has that passport, and that the data in it is correct. Furthermore, Article 15 grants customs authorities the power to check during import whether the passport is present and accessible. For steel traders and metal processors sourcing raw materials or semi-finished products from outside the EU, this means that the product's origin is irrelevant to the question of whether a passport must exist — that obligation follows from the product category, not from where it was manufactured. However, the role changes: whoever imports bears the responsibility that normally rests with the manufacturer.
Who this applies to and who it does not
This obligation specifically affects the party that places the product on the European market for the first time from a country outside the EU — the importer as defined in the ESPR. A steel trader who buys material from a supplier already established within the EU is not an importer in this sense and falls under different provisions (those of the distributor), even if the steel originally comes from outside Europe. The distinction thus lies in who brings the product onto the EU market, not in where the steel was ever melted or rolled.
Equally important is the delimitation by product category: the obligations from Articles 29 and 15 apply only to products covered by a delegated act that makes the digital product passport mandatory for that specific product group. For iron and steel, that act does not yet exist. As long as it does not, there is formally no passport requirement for these products upon import — the Articles already describe how it will work in the future, but the "when it becomes applicable" has not yet been determined for this product group.
No fixed date yet, but a firm framework in place
There is no date yet for when the passport requirement for iron and steel comes into force. What is certain is how the ESPR works: the obligation for a product group arises only at the moment when the European Commission adopts a delegated act for that group, and that act then also contains the date from which market participants must comply with it. For steel, that act does not yet exist. In the Commission's work plan for the period 2025-2030, a first delegated act is expected in 2026, with a period of eighteen months thereafter before the obligations take effect — but this is a plan, not a fixed date for iron and steel specifically. Until an act is published and takes effect, no passport requirement applies to this product group upon import. As soon as that act exists, the date will be stated here.
What an importer can prepare for now
If you import steel from outside the EU, it is advisable to start now by inventorying which data will eventually need to be included in a product passport — material origin, composition, and the information that the manufacturer or supplier outside the EU already records. This is work that will have to be done once the obligation takes effect anyway, and it is simpler to get this data flow in order now than only after publication of the delegated act. A second point is the relationship with the foreign supplier: checking whether that party is able to deliver the underlying data in full and on time is something an importer can verify independently, regardless of the exact start date. Thirdly, it is wise to follow when the Commission publishes the delegated act for iron and steel — from that moment it will be clear which data are mandatory and from when. Ferropas.eu monitors this development and will update this page as soon as an act is available.
The legal basis: Article 15 and Article 29 of the ESPR
The role of the importer in the digital product passport follows from Article 29 of the ESPR (Regulation (EU) 2024/1781), which describes the obligations of importers with regard to products for which a passport is mandatory. The customs authority's inspection powers at import follow from Article 15 of the same regulation, which governs how customs authorities can include the product passport in border controls. Both articles are general provisions from the ESPR framework regulation; they only become concretely applicable to a specific product group once the corresponding delegated act for that group has been adopted.
What you can do now
Map out which data on the origin and composition of imported steel are already available from your foreign supplier, and discuss with that supplier whether and how these data can be provided once necessary. Monitor the publication of the delegated act for iron and steel, and return to this page — once the date is known, it will be stated here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 15 (customs controls relating to the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 29 (obligations of importers)
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
Purchasing steel or a steel semi-finished product from a supplier outside the EU is a different position than purchasing from a European supplier. Whoever imports is, according to the ESPR (Regulation (EU) 2024/1781), the party that places the product requirements on the EU market — and this also affects the digital product passport. This article goes through what an importer is expected to do, where things go wrong in practice, and what can already be put down on paper now.
What is expected of you
Ensure that the passport is in place before the product enters the EU
Article 29 of the ESPR describes the obligations of importers, and one of them is that a product is only placed on the EU market once the applicable requirements have been met — with the digital product passport as part of that as soon as it applies to the product category in question. For a company with 10 to 100 employees that purchases steel outside the EU, this practically means that the question "is there a passport, and is it complete?" becomes a question that must be answered before shipment, not after. That is a different order than many importers are used to: when purchasing within the EU, a passport can sometimes still be supplemented afterwards in consultation with the supplier, but when importing from outside the EU, the responsibility for a complete passport lies with the moment of import itself.
Check whether the passport corresponds to the imported product
A passport that exists, but does not belong to the correct consignment, batch or composition, does not meet the purpose of the regulation. For an importer, this means that an incoming passport is not only checked for presence, but also for correspondence with the goods actually delivered. With a manufacturer with varying production locations or when purchasing through an intermediary, that is no formality — it is precisely where differences arise between what is written on paper and what is in the ship or container. How do I verify that my supplier's data is correct? describes how that check can be arranged in practice.
Take into account customs controls on the passport
Article 15 of the ESPR describes that customs authorities can carry out controls related to the digital product passport upon import. For an importing company, this means that the passport is not only an obligation towards the end user, but also something with which customs can work at the border. A shipment without an accessible or readable passport is thus a shipment that can raise questions during customs clearance — with all the consequences for processing time that come with it. This makes it practically important to know not only that there is a passport, but also whether the QR data carrier functions and the passport is accessible when needed.
Know exactly what must be stated, even if the supplier outside the EU is not familiar with the ESPR itself
A supplier outside the EU is not bound by the ESPR and often has no internal process to provide passport data in the form that is needed. This practically shifts part of the work to the importer: they must themselves know what data is required, actively request it, and assess whether what comes back is usable. Which data must I request from my steel supplier? sets out what that request involves.
Where things go wrong in practice
The supplier sends certificates, but not passport data. A manufacturer outside the EU typically supplies material certificates (for example a 3.1 certificate), but this is not automatically the same as the data set that a digital product passport requires. The certificate comes along, the passport is missing, and this is often only discovered during the first check.
Reliance is placed on a QR code that does not work or is not up to date. A data carrier that was created at the time of shipment, but whose underlying data has never been updated or whose hosting has since stopped, delivers an empty or incorrect page upon arrival. For customs and for the end user, this is indistinguishable from "no passport".
Intermediaries leave a gap in traceability. When importing via a trader or intermediary, the product passport is sometimes compiled based on data that has already been passed on once, without it being clear whether the original manufacturer is the source. If there is then verification, it is no longer possible to trace who provided which data.
Relying on the supplier's reputation instead of the data itself. A long business relationship or a well-known name is not a substitute for a verifiable product passport. How do I know if data from my foreign supplier is correct addresses what does provide guidance in this regard.
Confidentiality is used as an excuse not to provide data. Some suppliers outside the EU do not want to share composition data for reasons of competition. That is a legitimate interest, but not a valid reason to leave the product passport empty — can I agree on an NDA and still comply with the passport shows that there are other options than simply omitting data.
What you can document
- A list of which data per shipment are required, tailored to the type of steel product, so that this does not need to be worked out again for each purchase.
- Contractual agreements with the foreign supplier regarding the supply of product passport data before shipment — see how do I record the supply of product passport data in my purchase contract for how to set this up.
- A fixed verification point upon receipt at which the product passport is checked against the physical shipment, with a documented result of that verification.
- A file per supplier with previously supplied data, so that discrepancies between shipments stand out.
- A documented procedure for what happens if a shipment arrives without a usable product passport, including who decides on this internally.
For companies that combine steel from multiple foreign suppliers into one delivery or one product, an additional question arises: how do I combine data from different suppliers in one passport goes further into this.
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.