What is a digital product passport for steel?

What you must concretely do

What is expected of you

A digital product passport is, in short, a digital file attached to a specific product that contains data about what it contains, where it comes from, and how it can be further processed or recycled. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes that the passport is accessible via a data carrier — in practice usually a QR code — and that it links data to a unique product, a product group or a product model. Article 10 of the same regulation sets out the technical requirements that the passport must meet: it must display data correctly, completely and up-to-date, remain accessible for a certain period, and be set up in such a way that different parties in the chain can enter or read data in it.

For steel and other metals this is not yet concretely specified — that specification comes per product group via a delegated act, as is also explained on the page on what a delegated act is and why it determines what must happen. What the ESPR does establish, however, are the basic principles that such a passport must comply with in the future. For a steel trader or metal processor, these principles can be translated into three points.

One passport per product, not per company

The passport is attached to a product or product model, not to an undertaking as a whole. For a company that trades in or processes semi-finished iron or steel products, this means that in its administration there must be a link between a physical batch of steel and the corresponding digital file. For sheet steel, profiles or tubes that pass through the premises in various compositions and dimensions, this requires a different method of registration than the customary batch or order numbers alone.

The data carrier must be on or with the product

Article 9 calls for a physical data carrier — the QR code — that unlocks the passport. For steel that moves from manufacturer to trader to processor, this means that code must follow the product, even if it is cut, repackaged, or combined with other batches. Anyone reselling plate steel in smaller coils must practically find a way to provide the data carrier (or a reference to it) with the part being delivered.

Data must remain current and accessible

Article 10sets requirements for the accuracy and accessibility of data over time. For a company with ten to one hundred employees, this is often not a matter of complexity, but of discipline: someone must be responsible for keeping the file up to date, and that work does not stop at the point of sale. How often exactly that must happen depends on what the future delegated act for steel will prescribe — see also the page on how current the data in the passport must be.

Where things go wrong in practice

The data carrier becomes detached from the product. When coils are cut or batches from different deliveries are combined, it is often unclear which QR code belongs to which piece of steel. Without a fixed procedure for this, a gap arises between physical inventory and digital records.

It is assumed that the passport is the same as an existing certificate. A 3.1 certificate or material certificate often already contains much technical data, but is not a digital product passport within the meaning of the ESPR. The two can share data, but they are not automatically interchangeable — especially because the passport requires a fixed technical form and accessibility that a PDF certificate does not have.

A small company thinks it will be spared. Whether an undertaking of limited size falls under the obligations cannot be answered with a simple rule and differs per situation — see the explanation on the page whether the product passport also applies to small companies. Assuming that company size automatically provides an exemption is an assumption that does not necessarily hold.

There is a wait for the obligation to become concrete, without mapping out the own supply chain. Because the exact date and content still have to be determined — see when the passport becomes mandatory for steel — some companies are postponing all preparation. But inventorying which products, suppliers and customers are in the chain is work that is separate from the exact date and can be done now.

Confidential information is put into the product passport without consideration. Not all data that is available somewhere should automatically be public in the product passport. Which party may view which data and what is considered business-sensitive in that regard is a separate question — addressed on the pages about which data from the product passport may be viewed by whom and whether business-sensitive data about steel must be publicly available.

What you can document

• An overview of which product groups and semi-finished products the company trades or processes, as a basis to later determine which delegated act applies.
• A method for linking data carriers to batches of steel, including what happens when material is cut, repackaged or combined.
• Agreements with suppliers on which data they supply and in what format, so that this data can later be processed into a product passport.
• An indication of who within the company is responsible for keeping product data current.
• An overview of which data is considered business-sensitive and which is intended for public or restricted access.
• Documentation on the origin and composition of the steel, such as existing material certificates, as a supplement to — not replacement of — the future product passport.

Those who already have these points in order will be better positioned once it becomes clear which data the sector must specifically supply — see also the page on which data will be included in the steel product passport.