how do I demonstrate that my steel is recyclable for the passport

What you must concretely do

What is expected of you

Recyclability is one of the subjects for which the ESPR sets a requirement (the property must be demonstrable) without prescribing in detail how that demonstrability is to be fulfilled specifically for steel. Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) identifies recyclability as one of the product aspects on which ecodesign requirements can be set, and Article 10 provides that the underlying information must be accessible via the digital product passport. What that requires in practice from a steel trader or metal processor breaks down into a number of components.

Substantiating that the material is recyclable

For steel as a material category, recyclability is generally not a matter in doubt — steel has been recycled on a large scale via the scrap route for decades. What matters in the passport is not so much the question of whether steel is recyclable, but whether the composition of a specific product does not undermine that recyclability. Alloying elements, coatings and joining techniques can affect the separability of the material in the recycling phase. A company that assembles or processes semi-finished products is well advised to keep track of which alloying elements have been added and which surface treatments have been applied, because that data form the basis for a substantiated statement on recyclability.

Aligning with product rules still to be established

The concrete indicators, threshold values or test methods for recyclability of steel will be worked out per product group in delegated acts under the ESPR. As long as those product-specific rules have not been published, there is no established method to follow. A company with 10 to 100 employees therefore does not need to have a test report drawn up now for something for which the measurement method does not yet exist — but it is wise to structure their own product information so that it will fit the requested format later.

Measuring and calculating according to a recognised method

As soon as a method has been established, Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that test, measurement and calculation methods must be reliable, accurate and reproducible, and where possible aligned with harmonised standards. This means that an own assessment of recyclability — however reasonable — cannot simply serve as substantiation for the passport once a recognised method is available. More on how this obligation is generally fulfilled is set out in the question according to which method the values for the passport must be measured.

Traceability of the underlying data

The recyclability of steel depends partly on the origin and composition of the raw material: scrap entails different considerations than primary steel from the ore route. Companies that smelt or remelt themselves therefore benefit from a documented link between the scrap share in the melt and the final composition of the semi-finished product. See this point on how the scrap content in the melt is recorded. For companies that import steel, a different regime also applies: CBAM (Regulation (EU) 2023/956) sets requirements for the reporting of imported steel, separate from the recyclability question in the ESPR — the two regulations run parallel and should not be confused with each other.

Where things go wrong in practice

A few situations regularly occur in practice.

A processor uses a coating or welded joint that affects the separability of the material in the recycling phase, without recording this. At the moment the recyclability of the end product is questioned, it is no longer possible to reconstruct which processing contributed to it.

A trading company takes over a recyclability claim directly from the manufacturer without knowing which product variant the claim applies to precisely. For semi-finished products that are further processed after purchase, the original claim cannot simply be applied.

A company waits for the final product rules and records nothing in the meantime — with the result that data on alloying elements, coatings and scrap share are not systematically maintained once those rules come into force. Retrospective reconstruction is then considerably more difficult than recording as you go.

An importer treats CBAM reporting and ESPR information on recyclability as the same process, whereas these are two regulations with a different purpose: one is about carbon costs on import, the other about material properties in the passport. If you mix these up, you risk that neither dossier is complete.

A company substantiates recyclability with an own assessment instead of a method that aligns with what Article 39 of the ESPR (Regulation (EU) 2024/1781) requires, and must replace that substantiation later once a recognised method becomes effective.

What you can document

• An overview of the alloying elements and coatings per product variant, including the effect of these on separability in recycling, insofar as this is known.
• The link between steel grade and standard applied on the one hand and the recyclability claim on the other, so that a claim remains traceable to a specific product variant.
• Data on the scrap share in the melt, for companies that smelt or remelt themselves.
• Correspondence or documentation from the manufacturer or importer on which a recyclability claim is based, including the date and the product variant to which that claim applies.
• A note of which information is still missing as long as the product-specific rules for steel have not been established, so that upon publication of the delegated act it is quickly clear which data still need to be supplemented.
• A dossier in which CBAM-related documentation (Regulation (EU) 2023/956) remains separate from the ESPR substantiation, to prevent both dossiers from becoming mixed. More on this under what CBAM means for the import of steel.