How does a 3.1 inspection certificate relate to the product passport?
A 3.1 certificate is base material, not a passport
An inspection certificate 3.1 is a quality document from the manufacturer on a specific batch of steel or iron; the digital product passport is something different and broader. The certificate confirms that a product meets the ordered specification, with the chemical composition and mechanical properties established by an inspector from the manufacturer itself. The product passport that the ESPR (Regulation (EU) 2024/1781) has in mind is a digital file that remains accessible throughout the entire life cycle of a product and consolidates information on origin, composition, repair, recyclability and more — intended for everyone in the chain, not only for the buyer of that one batch. The certificate is thus one of the possible sources with which such a passport can be filled, but the certificate itself is not a passport and does not replace it.
For whom this is relevant, and for whom it is not
This distinction applies to every party in the steel chain accustomed to working with inspection certificates — manufacturers, importers, steel traders and processors who supply material with a 3.1 or comparable certificate. For them, the question does not change whether they need a certificate (that remains a matter of the sales agreement and the applicable product standard), but what happens to the data from that certificate once the product passport becomes mandatory. This is not about the question of whether a 3.1 certificate is replaced by the passport, and neither is it about which inspection class (3.1, 3.2, or other) is required for an application — that remains determined by the product standard and the agreement between parties, not by the ESPR. The ESPR regulates the provision of information on the product, not which inspection is mandatory for which application.
No fixed date yet, but a fixed route
There is no date yet on which the product passport for iron and steel becomes mandatory. The ESPR itself is in force, but the concrete requirements per product group — including iron and steel — are developed per delegated act and only then does an obligation apply. Until that delegated act exists and the obligation takes effect, the 3.1 inspection certificate continues to function as it already does: as proof of delivery, based on the applicable product standard and the agreement between supplier and buyer. Once the date is fixed, it will be mentioned here.
How to use the certificate for the passport from now on
Anyone already working with 3.1 certificates should ensure that the data within them is kept accessible and digital, as they will probably form part of the source data for the passport. Concretely, this means: first keep the certificate itself in order as the product standard requires, as that remains the basis. Next, it is useful to look at which data from the certificate — composition, mechanical properties, origin of the batch, the test method used — is also relevant for the broader passport, and to record that not only on paper but also digitally and in a structured manner. After that, it is up to the party compiling the passport (for example a platform like this) to determine which certificate data end up in the passport and how that relates to the requirements that the delegated act will then set. For the trade and processor themselves, there is no change in the meantime to the obligation to request or receive a certificate — that remains as it is now regulated between parties.
The basis: Article 10 and Article 39 of the ESPR
That the digital product passport is a standalone, digital and lifetime information record — and thus something different from a certificate of analysis — follows from Article 10 of the ESPR, which sets out the requirements for the digital product passport: how it must be accessible, what kind of information it should contain and for whom. That the underlying test, measurement and calculation methods by which product properties are determined — as also happens when drawing up a certificate of analysis — are regulated separately, follows from Article 39 of the ESPR on test, measurement and calculation methods. Together, these two articles show that a certificate and a passport have different functions within the same system: the certificate demonstrates that and how properties have been measured, the passport unlocks that and other information for the entire lifetime of the product.
If you already work with 3.1 certificates, it is best to start by storing the certificate data digitally and in structured form per batch, so that they can be easily submitted later once the obligation for the digital product passport comes into effect — and meanwhile keep an eye on the announcement of the first delegated act for the precise requirements and the date.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
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
Certificate 3.1 continues to exist alongside the product passport
A test certificate 3.1 (according to NEN-EN 10204) is a document issued by an independent testing body or the manufacturer's own quality service on specific, traceable properties of a batch of steel: chemical composition, mechanical properties, heat number. The product passport resulting from the ESPR is different: a digital, continuously accessible file with data on the product during its life cycle, as described in Article 10 of the ESPR. One does not replace the other. For a company with 10 to 100 employees, this means that two information flows will run alongside each other: the certification that is already common in the steel trade, and the passport data that will be disclosed via a new digital channel. Both require their own file structure, even though the underlying data partly overlap.
The traceability of the values must be ensured
Article 39 of the ESPR stipulates that the test, measurement and calculation methods used to support product passport data must be reliable, accurate and reproducible. A certificate 3.1 is exactly such a substantiation: it is drawn up according to a recognised standard, by a party competent to do so. In practice, this means that a company receiving a certificate 3.1 from a supplier can use this certificate as evidence for a passport value — but this requires a conscious link. The certificate itself does not automatically appear in the passport; someone must record which passport value is based on which certificate. How exactly these measurement methods look is described on the page on the method by which the values for the product passport must be measured.
One product passport can be based on multiple batches
In practice, a batch of steel that a company sells often consists of multiple heat numbers or batches, each with its own certificate 3.1. The product passport, on the other hand, belongs to a product or a product group. This raises the question of how far traceability should extend: to the individual batch, or to an average or representative value for the lot. This is one of the points where the delegated act for steel still needs to provide guidance; at present, there is no established rule on how batch level and passport level relate to each other. For day-to-day practice, it is advisable to be able to demonstrate per batch which certificate is associated with it, even when the passport is later drawn up at a higher level of aggregation.
Certificate data and passport data serve different purposes
A certificate 3.1 is primarily intended to demonstrate that a batch of steel meets an ordered specification — it is a quality document between supplier and buyer. The product passport is broader: it also covers sustainability information, origin and recyclability, aimed at transparency throughout the chain and towards end-users. Which data the passport must precisely contain is described on the page on which data will be included in the steel product passport. For a mid-sized company, this means that certificate 3.1 cannot simply be "scaled up" to a passport — additional information is added that the certificate has never contained, such as data on CO2 emissions or the proportion of scrap in the melt.
Where things go wrong in practice
A trading company receives a certificate 3.1 from the manufacturer for a batch of sheet steel, but keeps this separate from the administration that will later be needed to supply passport data to a next buyer. When that buyer requests substantiation of a passport value, the correct certificate for the correct batch must be searched for manually.
A construction company assumes that a certificate 3.1 is automatically "sufficient" for the passport because it is a recognized inspection document. However, the certificate only substantiates the properties listed on it — mechanical and chemical values — not the sustainability data that the passport also requests.
A metal processor splits a batch of steel into smaller deliveries to different customers without consistently linking the corresponding certificate 3.1 to each partial delivery. When traceability is later requested, the connection between the partial delivery and the original certificate is missing.
A company stores certificates 3.1 only on paper or as loose PDFs in the purchasing manager's mailbox, without structured linking to the article number or batch number. When the passport and certificate file needs to be retrieved years later, it is no longer possible to reconstruct which certificate belonged to which delivery.
A supplier provides a certificate 3.1 in which an alloying element is mentioned, but not in the form that the passport expects. Without additional agreements on how the alloying elements to be reported are recorded, a gap arises between what the certificate shows and what the passport needs.
What you can document
- A cross-reference table between heat number or batch, the corresponding certificate 3.1, and the passport values based on it.
- A standard procedure for archiving certificates 3.1, including a link to the article or order number under which the batch was resold.
- An overview of which passport data can and cannot be derived from the certificate 3.1, so that it is clear which additional information must be collected separately — for example data relating to demonstrating the CO2 emissions per tonne of steel or to the recording of steel grade and standard.
- Agreements with suppliers on the form and completeness of the certificate 3.1, so that the data in it align with what the passport will require.
- A retention policy for certificates, aligned with the period during which the passport must remain active — see also the page on how often the data in the product passport must be updated.
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.