When does the product passport become mandatory for steel?

What you must concretely do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation: it establishes how rules are made, not what must be done from which date exactly. For steel and other products, this is elaborated per product group in a delegated act, as described in Article 4 and Article 8 of the ESPR. As long as that delegated act for steel does not exist, there is no legal obligation to provide a digital product passport. This makes the question "when" unanswered at the moment in the literal sense — but there is nevertheless something to be said about how that process proceeds and what a company can prepare for.

Following the planning in Article 18

Article 18 of the ESPR requires the European Commission to draw up a work plan stating which product groups are prioritised and in which order they will be elaborated. For a company with 10 to 100 employees, this means above all: monitoring the own product group within that work plan. Steel and iron semi-finished products are mentioned as an area of concern, but the precise content and the timing of the delegated act do not follow automatically from this. In practice, it comes down to a procurement or quality officer periodically checking the progress of the work plan, rather than waiting for a deadline to arrive.

Preparing without a legal obligation

There is no obligation to have a passport now, but there is practical value in working ahead. A company that trades or processes semi-finished steel products can already map out which data a manufacturer or importer normally already supplies (composition, origin, certificates) and where that data is currently kept. Anyone wishing to know whether this becomes relevant for their own product will read that afterwards on does the digital product passport apply to my steel?. This prevents everything from having to be set up from scratch later, after publication of the delegated act, within a shorter transitional period than would be desirable.

Making a distinction between the ESPR framework and product-specific rules

What the ESPR does already establish is the competence and the structure: which subjects a delegated act may regulate (Article 8), such as sustainability requirements, information obligations and the form of the passport itself. What the ESPR does not establish is the content for steel specifically. For a proper understanding of that distinction, it is useful to know what a delegated act is and why it determines what must happen. Without that distinction, there is often the impression that the ESPR already contains concrete dates and obligations for steel, whereas these only take effect after the delegated act.

Where things go wrong in practice

A common mistake is confusing the entry into force of the ESPR itself with the obligation for a specific product group. The regulation is a framework law; the actual obligation for steel only arises with a separate delegated act, which does not yet exist.

A second situation: companies that, following rumours about "2028", already base contracts or internal plans on that date, while that date is not yet fixed and depends on a delegated act that has yet to be published.

A third pitfall is assuming that "no delegated act" is equivalent to "never relevant". For those who trade in semi-finished steel products, there is a real chance that the product group will at some point be included in the work plan of Article 18 — the question is only when, not whether the subject will be ignored.

A fourth situation: the passport is treated as an IT matter that only becomes topical once the obligation takes effect, whereas the underlying data (origin, composition, processing history) often need to be recorded for longer for other purposes, such as CE marking or customer specifications. When those are looked at side by side, it is often discovered that the basis is already largely in place.

A fifth situation: confusing "end product" and "semi-finished product" when assessing your own position in the chain. For those uncertain whether the distinction is relevant to their own products, this is explained on does the product passport apply to semi-finished products of steel?

What you can document

• An overview of your own product groups and whether these fall under the definitions of the ESPR, to be read on which products of the steel sector fall under the ESPR
• An internal note with the status of the work plan according to Article 18, including a fixed date on which this will be reviewed (for example every quarter)
• A list of data that manufacturers or importers already supply as standard (composition, certificates, origin), so that it is clear what is already available and what is still missing
• A designation within the company of who is responsible for monitoring this legislation, so that monitoring does not depend on chance
• Agreements with suppliers on the provision of underlying data, even while there is still no legal obligation — this prevents delays once there is
• A reference in internal documents to the source of the information (the Commission's work plan, Article 18 of the ESPR), so that a later check is straightforward

As soon as the delegated act for steel is published, the date and content of this will appear on ferropas.eu, together with what that concretely means for your own position in the chain — including the answer to the question of what will actually be in the passport, as already described on which data will be included in the steel product passport.