What does a product passport for steel cost?

What you must concretely do

A clear-cut answer to this question does not yet exist, and that is not an evasive answer but a factual state of affairs: the ESPR (Regulation (EU) 2024/1781) determines in Article 9 what a digital product passport must contain and how it must be accessible, but the regulation itself does not mention amounts. What a passport for steel will cost depends on delegated acts that are worked out per product group. For steel and other metals, that elaboration does not yet exist. What can be done here: explain which cost items a product passport is typically composed of, so that a company can prepare for this without relying on a non-existent figure.

What is expected of you

Collecting and structuring data

The basis of every product passport is data: composition, origin, processing steps, and where applicable environmental and safety information. For a company of 10 to 100 employees, this often means that data already existing in various places — in procurement systems, supplier certificates, quality files — must for the first time be systematically brought together. This is usually the largest part of the work, and also the largest uncertain cost item, because the scope depends on how fragmented that data currently is.

Making the passport technically exist

Article 9 of the ESPR requires that the passport is digitally accessible via a data carrier, typically a QR code, and that the information remains available for a certain period. This requires a technical provision: hosting, a link between product and data, and a way to get the QR code on the physical product or packaging. For a trading company with limited IT capacity, this is often the part that is outsourced, because building a system yourself and keeping it running for ten years is an investment that is disproportionate to the core activity.

Keeping the data current

A passport is not a snapshot. When a semi-finished product changes owner, is processed, or when new information becomes available, the passport must be able to reflect that. For companies working with varying batches and many variants, this is an ongoing item: not a one-off expense, but a recurring management burden.

Ensuring that the right party is responsible

Who compiles and manages the passport depends on the role in the chain — manufacturer, importer, or a party authorized to do so. For companies that sell or process steel, it is important to be clear about whether they themselves must have a passport drawn up, or whether this has already been done by an earlier link in the chain. Does the digital product passport apply to my steel? goes into that delimitation in more detail.

Where things go wrong in practice

Costs are estimated on the basis of other product groups. Figures on product passports for textiles or batteries have been circulating for some time. These cannot simply be transferred to steel, because the data structure and the complexity of the chain are different.

Only the technical side is budgeted, not the data effort. Companies request a quote for hosting and QR codes, but underestimate how much time it takes to compile composition, origin and processing data from various sources — often the largest part of the actual costs.

There is a wait until the obligation is established, after which everything must happen at once. When the date is indeed established, the time to structure data is often shorter than expected. What can already be built now is described in what can I already do while the rules are not yet final?

One passport is budgeted, while there are multiple variants or locations. Companies with multiple product lines or locations sometimes calculate with a price per passport without taking into account economies of scale or conversely additional coordination costs between locations. See how do I arrange the product passport if I have multiple locations for how that situation differs from a single location.

Damage to and replacement of the data carrier are not taken into account. A QR code on a steel semi-finished product that is sawed, welded or transported does not always make it to the end of the chain. The costs of replacement are often forgotten in initial estimates. What needs to be done about this can be read on what should I do if the QR code on my steel is damaged

What you can document

• An overview of existing data per product group: which data on composition, origin and processing are already available, and from whom (supplier, own production, certifying body).
• An inventory of the role in the chain: manufacturer, importer or trader, per product line, so that it is clear who will be responsible for having the product passport drawn up.
• Agreements with suppliers on the provision of passport data, so that these do not have to be requested individually afterwards.
• A test trajectory before the obligation takes effect, to see which data is missing and what a passport costs in practice to compile. See can I already have a test version of my product passport made
• An internal responsible person or process owner for the management of passports, including arrangements on who keeps the data up to date when there are changes in the chain.
• A training session for employees who will work with the QR code and the underlying data, so that knowledge does not remain with one person. More information on how do I train my staff to work with the product passport

As soon as the delegated act for steel is published and concrete requirements — and with it a more realistic cost estimate — become known, this will be supplemented here.