How do I record steel type and standard in the product passport?

What you must concretely do

What is expected of you

The ESPR stipulates in Article 10 that a product passport contains the product information resulting from the applicable delegated act for that product group. For steel and iron semi-finished products, that act does not yet exist, but the logic of Article 10 already provides direction: the passport must unambiguously establish the product's identity, and steel grade and standard belong in most envisaged implementations. What this means in practice breaks down into a few recognizable obligations.

Unambiguously identify the product

A passport that says "steel" without grade and standard does not meet the idea behind Article 10: the data must describe the specific product, not the product category. For a company with 10 to 100 employees, this means that the standard designation (for example an EN standard) and the steel grade designation together form one fixed data pair that is filled in again for each batch, not established once for the entire assortment. At a trading company with multiple suppliers, there is a risk that this designation is noted differently per supplier — one states the standard, another only the trade name. This must be reduced to one consistent designation before the passport is compiled.

Record the source of the designation

The steel grade and standard do not come from nowhere: they typically appear on the inspection certificate or the accompanying documentation of the manufacturer. For a processing company, this means there must be a fixed place from which this data comes, and that place must remain traceable. How a test certificate 3.1 relates to the product passport is not a non-binding question in this regard: the certificate is often the only substantiation that a company itself cannot re-establish, because the metallurgical composition is not measured on the shop floor but at the manufacturer.

Maintain coherence with other data in the passport

Steel grade and standard are not separate from other fields. Which alloying elements must be reported depends on the steel grade that has been specified, and a discrepancy between those two fields is one of the most common sources of a passport that is substantively incorrect. An overview of which data will be included in the steel product passport shows that steel grade and standard are not isolated, but form the basis on which other fields are filled in or checked.

Traceability in processing and resale

A semi-finished product that is processed — cut, rolled, welded into a new component — sometimes changes shape but not necessarily steel grade. For companies that purchase and resell or process semi-finished products, this means that the standard designation of the original batch must remain recognizable in the passport of the processed product, even if the physical form no longer resembles what was purchased.

Where things go wrong in practice

A first recurring situation is the standard that is noted without version or year, while standards are periodically revised. "EN 10025" without further specification says less than the complete designation with part and year, and in an inspection that difference is relevant.

A second situation: the trade name of a steel grade (as a manufacturer with proprietary brand names) is used in the passport instead of the standardized designation. For internal administration that is convenient, for a passport that must be read by a chain of parties it is insufficient, because not every customer can trace the brand name back to the underlying standard.

A third situation arises with mixed batches: different coils or bars from the same order, but not from the same heat, with minor deviations that do not all fall under exactly the same standard designation. Is one standard then maintained for the entire batch while part of it falls just outside? That is a question that must be answered before shipment, not afterwards.

A fourth situation is the divergence of steel grade and standard during transit via an intermediary. The original designation by the manufacturer is not adopted accurately, or is simplified "for readability" — with the result that the designation in the passport no longer matches what is stated on the underlying certificate.

A fifth, more administrative situation: the standard is correctly recorded when the passport is created, but not updated when a standard is revised while the batch is still in stock. How current data in the passport must remain is a question that concerns not only composition or origin, but equally the standard designation itself; see the explanation on how current the data in the product passport must be.

What you can document

• A fixed internal notation system for steel grade and standard, including the version and year of the standard, so that each batch is described in the same way regardless of who provided the designation.
• A reference to the underlying inspection certificate per batch, so that the designation in the passport can be traced back to a verifiable document.
• An overview of the suppliers and the form in which they provide steel grade and standard (certificate, delivery note, own brand name), so that deviations between suppliers become visible before they end up in a passport.
• A work instruction for the situation of mixed batches: when a batch may and when a batch may not be combined under one joint standard designation.
• A control point at standard revisions, linked to the company's own stock administration, so that a designation that has since been revised is not carried over unchanged to a new passport.
• A documented agreement on the relationship between steel grade, standard and the reported alloying elements, so that these fields are always checked together during internal inspection and are not filled in separately from each other.