What can I already do while the rules are not yet final?

Data collection can already begin

What can already be done now is to put in order the data that will be needed later: material composition, origin, processing steps and the information that suppliers already provide. The obligation to maintain a digital product passport for iron and steel does not yet exist, but the underlying information — what a semi-finished product contains, where it comes from and through which links it has passed — is information that a steel trader, metal processor or construction company often already partly keeps, in certificates, purchase orders and quality files. Recording that information now centrally and traceable, instead of scattered across mailboxes and loose documents, is a step that is useful regardless of the final rules and that will make drawing up a passport easier later.

For whom this is relevant now

This is relevant for companies that produce, import, trade or process iron or steel, or semi-finished products thereof, and which will therefore later have to supply data as a manufacturer, importer or other actor in the supply chain for a product passport. This is not a legal obligation: for this product group there is not yet a delegated act that determines which data are mandatory, in what form, and from what moment. So this is preparation, not compliance with an existing rule. This also does not apply to other product groups that may fall under the ESPR — batteries, textiles, furniture, electronics — which each have their own timeline and their own delegated act or have already received one, separate from what applies here for iron and steel. And it does not apply to companies that exclusively process end products in which the steel is already processed by a third party; the data obligation lies primarily with the actors who place the semi-finished product on the market or process it.

No fixed date for steel yet

There is no date yet set for iron and steel when obligations come into force. What is established is the general work plan of the ESPR for the period 2025-2030: it mentions a moment in 2026 for the first delegated acts, followed by a period of eighteen months before obligations actually come into effect. Whether and when iron and steel will have their turn in that schedule, and what content that act will then have exactly, has not yet been published. Until that publication, there is no obligation for this product group to have a digital product passport, and there is also no established list of data that must be included in it. As soon as the delegated act for iron and steel is published, the date will be added to this platform.

How to approach the preparation

The sequence that is most obvious in this sector begins with an inventory: what data on composition, origin and processing already exist, where do they lie, and in what form — on paper, in a PDF, or already in a system. After that it is useful to look at which suppliers and customers in the chain already exchange data and how, because a passport will later consist of the sum of information from multiple actors in the same supply chain. A third step is to appoint someone within the organisation who follows this subject and who knows where the company's own data come from if asked for later. Finally, it helps to start talking early with suppliers and customers about what data they already record, so that later it does not turn out that information is missing that actually already existed, but was never recorded centrally. Those who take these steps now will mainly have to supply data later instead of having to search for it.

Legal basis: article 18 and article 38

That data on the supply chain will play a role in the future follows from Article 38 of the ESPR (Regulation (EU) 2024/1781), which describes requirements for actors in the supply chain when providing information for the product passport. That for product groups such as iron and steel a prioritization and planning takes place first before concrete obligations arise, follows from Article 18 of the same regulation, which tasks the Commission with prioritizing product groups and drawing up a work plan for them. Both articles show that the obligation is being established step by step: first prioritization based on a work plan, then a delegated act per product group, and only then a concrete entry date and concrete data requirements.

If you want to get started with this now, it is best to start with a brief inventory of your own data on composition, origin and processing, check what information suppliers already provide as standard, and keep an eye on this page for when the delegated act for iron and steel is published and the date and data requirements are added here.

What this is based on

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

The delegated act for iron and steel does not yet exist, and therefore no date has been set. This does not mean there is nothing to do. The ESPR itself has been established since 2024, the direction of the obligations is known, and companies that prepare now will not lag behind later. This section describes what can practically happen before the first delegated act for steel is published.

What is expected of you

Knowing whether the product will fall under the scheme

The ESPR operates with a prioritisation system: the European Commission determines via Article 18 of the ESPR (Regulation (EU) 2024/1781) for which product groups delegated acts come first, based on among other things environmental impact and market volume. Iron and steel are on that list, but the precise product description — which semi-finished products, which alloys, which dimensions — follows only from the act itself. For a company with 10 to 100 employees, this means in practice: checking which part of the assortment could fall under "iron and steel" as a product group, and having that overview ready as soon as the act is published. If anyone is unsure whether a specific product counts or not, a more detailed explanation can be found at whether the digital product passport applies to a particular type of steel.

Knowing where your own information comes from now

Article 38 of the ESPR (Regulation (EU) 2024/1781) establishes that actors in the supply chain — manufacturers, importers, but also traders and distributors — may be required to pass on product information to subsequent parties in the chain. This does not yet apply concretely to steel, but the principle is clear: whoever must submit a passport later will need underlying data from certificates, composition, origin and processing. For a mid-sized company, this means it is now possible to find out what data its own suppliers record, and what data is missing. Companies with multiple locations are well advised to coordinate that inventory centrally; how this works in practice is described under how to arrange the product passport with multiple locations.

Having a realistic picture of time and costs

Without a fixed date, tight planning cannot be done, but a rough estimate of the effort can be. Compiling a passport, managing the data during the hosting period and purchasing QR data carriers are cost items that can already be budgeted now on the basis of the current product catalogue. An overview of the cost structure can be found under what a product passport for steel costs approximately.

Where things go wrong in practice

A number of situations occur more often among companies that wait until the rules are final:

Putting everything on hold. Because the date is not yet set, the entire preparation is postponed — including matters that are independent of the exact entry date, such as getting certificates and origin data in order.
No visibility into your own supplier chain. When the act is released, it turns out that crucial data (composition, melting process, country of origin) has not been systematically recorded by suppliers further down the chain, and then catching up is time-consuming.
Underestimating the internal side. Planning is done for systems and data, but not for people: no one in the company will later know how to request a passport, check it or link it to a shipment.
Thinking that a pilot can only happen when the law is definitive. Some companies wait to test until the obligation takes effect, while a trial setup now already provides insight into what is missing.
Making inventory decisions without justification. Out of caution, marking down stock, accelerating sales or destroying it, without a concrete obligation underlying this.

What you can document

Even without a fixed entry date, a number of things can already be put down on paper now, so that the transition will be faster later:

A product overview of your own assortment of iron and steel products, with a note of which categories are presumed to fall under the future product group.
A supplier inventoryof which supplier supplies which underlying data (certificates, composition, origin) and in what form.
An internal point of contact, someone who follows the developments around the delegated act and coordinates the internal preparation.
A test setup for a limited part of the assortment, to establish which data are missing before this must be done under time pressure. More on this is set out at whether a test version of a product passport can already be made.
A training plan for employees who will work with the passport in the future — from order processing to warehouse. See also how to train staff in working with the product passport.
Alignment with industry initiatives, insofar as these already exist, so that your own preparation aligns with what is considered standard practice within the sector. An overview of this is set out at whether there is already a sector standard for the steel product passport.

What at this moment is still not fixed — the exact product description, the entry into force date, the precise data requirements — does not belong in an internal document as an established fact. This follows from the delegated act itself, once the European Commission publishes it.

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.