Which alloying elements must I report?

No fixed list of alloying elements yet

Which alloying elements will ultimately have to be reported in the digital product passport for iron and steel is not yet determined. Regulation (EU) 2024/1781 itself sets out the framework for what a product passport in general must be able to contain, but the specific content per product group — including the question of which elements such as chromium, nickel, molybdenum or copper must be reported, and from which concentration level that becomes relevant — will be set out in a separate, product-specific delegated act. For iron and steel, that delegated act does not yet exist. This does not mean there is nothing to say: the regulation does indicate that material composition is among the possible information requirements, and as soon as the delegated act for this product group is published, that list will be updated here.

For iron and steel products, not for other metals

This question applies specifically to semi-finished products of iron and steel — the remit of this platform. Other metal groups, such as aluminium or copper, fall under their own product-specific process within the ESPR and may be addressed at a different time and with different content. Also important: Articles 5 to 7 of the ESPR address the general system of ecodesign and information requirements for products in general, not a ready-made list of substances for steel. Those looking for a concrete list of elements and threshold values for a specific steel grade will therefore not find it in the regulation itself, but will have to wait for the elaboration that still needs to be developed for this product group.

Determined only after the first delegated act

There is no fixed date. What is certain is the phasing that the European Commission has outlined for the ESPR: in the work plan for 2025-2030, the first delegated act is expected in 2026, with obligations taking effect eighteen months later. Whether and when this happens specifically for iron and steel, and which elements will be included, is not yet supported by a delegated act. Until that delegated act exists, there are no mandatory reporting requirements for alloying elements in the digital product passport under the ESPR. As soon as the text of the delegated act for this product group is published, the date and content will be updated here.

What can be done now

Anyone who wants to engage with this subject now should start with their own documentation. Manufacturers and importers of iron and steel products typically already record the chemical composition of a batch because customers and standards require it now. Those existing data will probably form the basis for what goes into the digital product passport later, even though the exact set of mandatory elements is not yet fixed. It is therefore worthwhile to check which composition data are already being recorded systematically and whether they are stored in a way that can later be easily linked to a product passport. Furthermore, it is advisable to keep an eye on the publication of the delegated act for iron and steel, as it will determine both the content (which elements, which threshold values) and the timing of the obligation. Until that time, there is no reason to anticipate a specific list that does not yet exist.

The basis: Articles 5 to 7 and Article 10 ESPR

That the precise content still needs to be determined follows directly from the structure of the regulation. Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe the ecodesign requirements and the manner in which performance and information requirements for product groups are established: these are worked out per product group, not written out in the regulation itself. Article 10 of the same regulation then determines what a digital product passport must contain, and in doing so refers to the information arising from the applicable delegated act for the relevant product group. For alloying elements in iron and steel, this means that the obligation becomes concrete only once that product-specific act is in place — the ESPR itself merely establishes the framework and the system.

Those who wish to make preparations now are well advised to keep their own material documentation in order and to monitor this page for the update once the delegated act for iron and steel has been published — the concrete list of elements and the date on which the obligation comes into force will appear here.

What this is based on

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

Provide composition information correctly and completely

Article 7 of the ESPR (Regulation (EU) 2024/1781) identifies material composition as information that may be relevant for a product group. For steel and iron, this means in practice that the alloying elements which determine the properties of the material — such as chromium, nickel, molybdenum, manganese or vanadium — must be traceable into the product passport. Which elements exactly are reported and in what form (percentage, range, minimum/maximum) will be developed per product group in the delegated act which has not yet been published. A company with 10 to 100 employees that purchases or processes semi-finished products is well advised to already find out now from which point in the chain these data come: from the manufacturer, from the importer, or from its own smelting or alloying process.

Align with existing standards

Alloying elements are usually already reported on the basis of a steel standard — an EN standard for example determines which elements within which margin may be present for a particular steel grade. Article 7 requests information that makes it possible to assess the performance and composition of the product; in practice this is often the same information that already appears on a certificate. How that standard and the associated composition are precisely recorded is described on the page on how steel grade and standard are recorded in the product passport.

Traceability to the source of the data

Article 10 of the ESPR sets out requirements for the way in which information is entered in the digital product passport: it must be linked to a specific product or product group and be accessible via the data carrier (the QR code). For a company, this means that the statement of alloying elements must not be separate from the rest of the batch data — the composition must be linked to the correct melt, coil or batch. A company that itself mixes, processes or further alloys material is well advised to check how that link does or does not already exist in its own administration.

Know what is already on a certificate versus what the passport requires

An inspection certificate 3.1 often already contains a chemical analysis with alloying elements. This does not mean that the passport automatically adopts the same format: the passport is a separate digital object with its own requirements for structure and accessibility according to Article 10. How a 3.1 certificate relates to the passport, and where the data do and do not overlap one-to-one, is explained on the page on how an inspection certificate 3.1 relates to the digital product passport.

Where things go wrong in practice

A metal processor buys steel from multiple suppliers and mixes this for its own semi-finished products. The alloying composition of the end product then becomes an average or a new value, but the source data of the original batches become detached from each other in the administration. At the moment when a passport must be compiled, it is no longer possible to trace which part came from which supplier.

A trading company resells steel without processing it itself, and assumes that the manufacturer's data automatically "travel along". In practice, it turns out that the certificate is passed on, but that no one checks whether the stated alloying elements match the standard listed on the packing slip.

A construction company receives material with a certificate showing a broadly composed alloy (for example a range rather than an exact value), and does not know whether the passport expects an exact value, a range, or both. Without clarity from the delegated act, this is now being filled in with assumptions, which leads to inconsistencies once the requirements are actually established.

A company considers the precise alloy ratio as a trade secret, because that ratio is the result of its own process development. The question of whether and how such a composition must be disclosed in the passport is only raised late in the process, while that question could better be answered in advance — see the explanation about whether commercially sensitive data about steel must be made public.

An importer receives material from outside the EU with a chemical analysis in a format other than that customary within EU standards, and is uncertain whether this format is suitable for the passport or must first be converted.

What you can document

The chemical analysis per batch, melt or lot, as received from the manufacturer or importer — including the standard on which it is based.
An overview of which alloying elements are standard in the steel grades that the company processes or trades, and in which range.
The link between inspection certificates 3.1 and the specific batches that the company purchases and sells, so that composition and origin remain together.
An internal arrangement regarding who within the company is responsible for forwarding composition data to the next link in the chain.
Documentation of any own processing (mixing, alloying, heat treatment) that changes the original composition, with a note of the moment at which this occurs.
A note on which data are considered commercially sensitive and why, so that this distinction is already made before a passport must be compiled.

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.