What do I do with steel inventory that is already in place when the rules take effect?
Nothing applies yet, because steel does not yet have its own requirements
Steel inventory that is already in place does not currently need to comply with any ecodesign or product passport requirement. This is because those requirements for iron and steel do not yet exist. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: it governs how the EU will set requirements for products, but does not itself set any concrete requirements per product group. Those requirements will only come with a delegated act that is drawn up specifically for iron and steel, and that does not yet exist. As long as that act does not exist, there is nothing that existing inventory would need to comply with — there is simply no standard yet against which to test.
For whom this matters, and for whom (not yet)
This question is relevant for steel traders, metal processors and construction companies that have semi-finished iron and steel products in stock or purchase them. The answer above applies to the situation as it is now: before a delegated act for iron and steel has been adopted. It does not automatically apply to product groups for which a delegated act already exists or is at an advanced stage; for those, their own transitional rules may apply that are not discussed here. It also does not apply to obligations that are separate from the ESPR, such as CE marking or other product legislation for steel — those continue to apply as they are now, regardless of where the ESPR is in its process.
There is no fixed entry date; but there is a fixed route
There is no established date yet on which specific requirements for iron and steel will take effect. What is established is the route to get there. Under Article 18 of the ESPR, the Commission draws up a work plan in which product groups are prioritized for a delegated act, on the basis of criteria such as environmental impact and potential for improvement. Only when such a delegated act for iron and steel has been adopted and published do concrete requirements and a date on which those requirements will apply arise. Until then, nothing changes in what must be done with existing inventory, simply because there is no rule that says anything about it. As soon as that date is known, it will be mentioned here.
What this means for inventory, in practice
For those who now have steel inventory or are purchasing it, the ESPR itself requires no action. As soon as the delegated act for iron and steel does come, the first question turns on the moment of 'placing on the market': Article 1 of the ESPR links the requirements to products that are placed on the market or put into service, not to products that at that time are already sitting on a pallet, in a warehouse or on their way to a customer. What that concretely means for inventory that was produced or delivered before the date of application will be determined by the transitional provisions included in the delegated act itself. That text does not yet exist, and therefore cannot be summarized or predicted.
What can be foreseen in the meantime is this: the moment the delegated act for iron and steel is published is the moment to read the transitional provisions in it. From that moment on, it will also become clear whether, and if so from when, a digital product passport is needed to place a product on the market. This page will be updated as soon as that text is available.
The basis: Article 1 and Article 18 of the ESPR
That there is currently no concrete obligation follows from Article 1 of the ESPR (Regulation (EU) 2024/1781). That article describes the subject matter and scope of the regulation as a framework for setting ecodesign requirements for products placed on the market or put into service — not as a collection of requirements that already apply directly to steel under the regulation itself. Which product groups are addressed when follows from Article 18 of the ESPR: that article requires the Commission to draw up a work plan in which product groups are prioritised for a delegated act. For iron and steel, that process has not yet been completed, and there is therefore no text that addresses the treatment of existing stock.
What to do now
Anyone wishing to prepare for this in advance can best do two things: keep an eye on the publication of the delegated act for iron and steel, and in the meantime put their own inventory management in order — origin, composition and supplier details per batch of steel. This takes little effort now and ensures that the data needed for a product passport later will already be available when the requirements actually come into force.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 18 (prioritisation and planning)
- Regulation (EU) 2024/1781 (ESPR), Article 1 (subject matter and scope)
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
Know that transitional provisions are a blind spot in the current text
The ESPR itself regulates in Article 1 the subject matter and scope of the regulation: which products can fall under the system and that the concrete obligations per product group will be filled in via delegated acts. Article 18 describes how the Commission prioritises which product groups come first and according to which schedule that happens. Neither of these articles says anything about what happens to stock that was produced, imported or purchased before the entry into force date. This is not an omission of this platform, it is a gap in the text as it currently stands: the transitional provisions for existing stock become concrete only in the delegated act per product group, and that does not yet exist for iron and steel. For a company with 10 to 100 employees, this practically means that every statement about "stock that is already there may simply be sold" or "must also receive a passport" currently anticipates something that has not yet been determined.
Make a distinction between "placing on the market" and "holding in stock"
What can be derived from the systematic approach of the ESPR, however, is that obligations generally apply at the moment when a product is placed on the market or put into service, not at the moment of manufacture. This distinction is relevant for stock management: steel that is already in a warehouse but has not yet been sold or delivered is somewhere between "produced" and "placed on the market" in terms of status. Which of these two moments becomes decisive for the obligation to provide a passport will only become clear once the delegated act for steel is published. A company can internally already establish the distinction between batches purchased before and after a certain date, so that this cut is in place when the rules become clear.
Do not lose track of origin and composition of existing batches
Regardless of how the transitional provisions turn out, it is practically useful to know where the stock that is already there comes from, what composition and properties the supplier has stated, and what documentation was supplied with it. This is not an obligation that follows from Article 1 or Article 18, but a prerequisite for not ending up with a pile of undocumented steel later, when there is a passport obligation. Anyone wondering what can I do now while the rules are not yet finalcan find there an approach that aligns precisely with this point: file formation in anticipation of mandatory passports.
Monitor when the steel and iron product group actually comes into the schedule
Article 18 describes the prioritisation of product groups, and steel and iron are mentioned as candidates for one of the first delegated acts. As long as that act is not published, it is not established from when obligations will apply, and therefore also not whether and how existing stock receives an exception within this. A company that now holds or builds up stock would be well advised to follow the publication of that act rather than to already take measures on the basis of assumptions that may subsequently prove unnecessary or simply misdirected.
Where things go wrong in practice
A trading company decides as a precaution to accelerate the sale of all existing stock before a suspected entry into force date, based on a date that is not yet official. If that date subsequently shifts, the haste turns out to have been unnecessary and margins may have been sacrificed for nothing.
Another company assumes that stock purchased before the entry into force date is automatically excluded from the passport obligation, without a text existing to confirm this. If the delegated act then takes the moment of first sale to the end user as the point of reference instead of the moment of purchase, that same stock will still fall under the obligation.
A third situation: a metal processor mixes old and new batches of steel in one storage location without maintaining a distinction based on source or purchase date. As soon as an obligation comes into effect, it is no longer possible to determine which part of the inventory falls under the transitional provisions and which part does not, resulting in the entire batch having to be treated as "new" for precautionary reasons.
A fourth: a company with multiple locations records inventory at each location differently, so there is no central overview of what is where and since when. If someone asks how do I arrange the product passport if I have multiple locations, they encounter a problem that already arises before the product passport requirement itself: without central inventory registration, there will be nothing to fall back on later.
A fifth situation: a company passively waits until the obligation officially takes effect and then has no file whatsoever on the composition of the inventory it has been holding for years, while the original supplier no longer exists or no longer responds. The data needed to compile a product passport retroactively are then no longer retrievable.
What you can document
- An overview per inventory batch: purchase date, supplier, composition and any certificates provided with delivery.
- A physical or administrative separation between inventory purchased before and after a fixed reference date, so that a future cut in the transitional provisions does not need to be determined retroactively.
- A file per supplier with contact details and technical documentation that would be needed to, if it comes to that, compile a product passport retroactively.
- An internal agreement on who within the company monitors the publication of the delegated act for steel and when action will follow.
- A note on older batches if the original supplier is no longer traceable, so that this risk is known in advance rather than only during an inspection. For more information about what is involved, read what does a supervisor ask during an inspection on steel.
This documentation replaces no legal obligation, as none yet exists for existing inventory. It is a way of not standing empty-handed once the delegated act for iron and steel provides clarity on the status of inventory that is already there.
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.