What happens to the product passport when I process steel into a different product?

What you must concretely do

Steel rarely reaches the end user in the form in which it leaves the factory. A plate is cut, rolled, welded, coated or combined with other materials to create a new product. For companies taking this step, this raises a practical question: does the passport of the purchased steel remain valid, or does a new obligation arise as soon as a different product is created? This article describes what follows from the ESPR on this matter.

What is expected of you

Passing data from the passport of the base material through the supply chain

Article 38 of the ESPR concerns the obligations of actors in the supply chain. The purpose of this is that whoever receives a product with a passport and processes it into something else must not simply allow the relevant information to disappear. For a metal processor, this means in practice: the composition, origin and other characteristics of the purchased steel remain relevant for the new product, even if the form has completely changed. A construction company that purchases plates and makes a beam or frame from them essentially passes on the properties of the base material to what it ultimately delivers. Which data exactly must you request to be able to do this correctly? This is described on the page on what data you request from your steel supplier.

Assessing whether the further processed product requires its own passport

Not every intermediate product automatically receives its own passport — this depends on whether the end product itself falls under a product group for which a passport has been made mandatory via a delegated act. For a company with 10 to 100 employees that further processes semi-finished products, this means that a distinction must be made between "I am processing steel that already has a passport" and "I am making a new product for which a new passport obligation may arise". This distinction is not always immediately clear, and the rules on this are established separately for each product group. More about how this mechanism works can be found on the page on what a delegated act is and why it determines what you must do.

Taking along or replacing the unique identification code

Article 12 of the ESPR regulates the unique identification code that is assigned to a product. In the case of further processing, the question arises whether the code of the base material can still be used, or whether the new product receives its own code. For practical purposes, it is relevant that a code is linked to a product as placed on the market — a major processing operation that results in a different product thus naturally suggests itself as a reason for a new code, whereas a minor processing operation (such as cutting to size without substantial change) is less naturally treated as such. No sharp boundary has yet been defined here; this makes combining source data from multiple deliveries a point of attention, as also described on the page on how you combine data from different suppliers in one passport.

Maintaining traceability of origin

Even if the form of the material changes, the question of where the original steel comes from remains relevant — especially when part of the raw material has been imported from outside the EU. For companies that work with multiple origins (partly EU steel, partly import) it is important to maintain traceability of origin per batch, even after processing. What is involved here when importing steel from outside the EU is explained on the page what the product passport means when importing from outside the European Union.

Where things go wrong in practice

Data is lost when batches are mixed. A processor buys steel from two suppliers, mixes the batches in production, and subsequently cannot indicate which part of the end product comes from which source. Without registration per batch, traceability is then no longer possible.

It is assumed that the passport "automatically travels along". Some companies assume that the product passport of the purchased steel simply remains valid for the end product, without checking whether the end product has its own passport obligation or whether the data requires a new translation.

Unclear about who must provide which information. In a long chain (manufacturer → trader → processor → end product) it is not always clear who passes on which part of the data. This leads to gaps that only become apparent when the passport for the end product has to be drawn up.

Coating, welding or alloying changes the composition, but this is not recorded. An operation that adds substances (coating, surface treatment, connection with other metals) alters the actual composition of the product. If that is not registered, the basis for later obtaining a correct passport is missing.

Reliance on verbal assurances from the supplier about origin. When the origin of the base material is not documented in writing, this cannot be substantiated in a later inspection. How you assess the accuracy of such data is described on the page on how to verify whether your supplier's data is correct.

What you can document

• Per purchased batch: the passport or the underlying data of the base material, including the unique identification code as referred to in Article 12 of the ESPR.
• A record of which batches have been combined or processed into which end product, so that traceability is maintained.
• Recording of operations that change the composition (coating, alloying, welding with other material) and the time at which these were carried out.
• Agreements with suppliers about which data are provided upon delivery, set out in the purchase contract — see the explanation on how you set out the supply of passport data in your purchase contract.
• An overview of which end products may themselves be subject to a passport obligation, to be reviewed as soon as a delegated act for the relevant product group has been published.
• Documentation of the origin of the material, including import data where relevant, so that this is available if a question is raised later.