Which steel sector products fall under the ESPR?

Semi-finished products of iron and steel are in principle covered by the ESPR

Plates, profiles, tubes, bars, wire and other semi-finished products of iron and steel are in principle covered by the ESPR, because the regulation applies to physical products placed on the market or put into use — and this concept explicitly includes components and intermediate products (Article 1 and Article 2 of the ESPR, Regulation (EU) 2024/1781). This does not mean that concrete obligations already apply to steel. The ESPR is a framework regulation: it determines which types of products fall within its scope, but the actual requirements — such as a digital product passport, minimum recycling content or sustainability requirements — are established separately for each product group. For iron and steel, that step has not yet been taken. The answer to "does it fall under it" can therefore be read in two layers: within the scope of application, yes; under a concrete obligation, not yet.

What counts as a product and what does not

The ESPR is aimed at those who place physical goods on the European market: manufacturers, importers and, by extension, parties that further process or resell these products. "Product" means any physical object placed on the market or put into use, including components and intermediate products (Article 2). A steel plate that still has to be processed into a construction component therefore counts as a product within the meaning of the regulation, even though it is not an end product for a consumer.

A number of categories are explicitly excluded from the scope: food, animal feed, medicines, living plants and animals, products of human origin, and products of plants or animals directly related to their future reproduction (Article 1). None of these exceptions affects the steel sector. For iron and steel as a material category, there is therefore no generic exemption — the question of whether something falls under it is for this sector more a matter of "when" than "if".

No fixed date yet for iron and steel

When the concrete obligations for iron and steel will take effect is not yet determined. The ESPR itself is already in force as a framework, but the substantive requirements per product group come through separate, later-to-be-established regulations. For iron and steel, no such regulation has yet been published. Until then, there are no obligations for this product group under the ESPR — the scope is clear, but the implementation is not.

As soon as a concrete regulation is published for iron and steel, that regulation itself will determine when the obligations take effect and what data a product passport must contain. This platform monitors that publication and updates the date as soon as it becomes known.

What this means for those working in the steel sector

The first step is to check whether a product is physically placed on the market or put into use — for semi-finished products of iron and steel this is almost always the case, and the product thereby falls within the scope of Article 1. The second step is to check whether one of the exemptions in Article 1 applies; for steel and iron this is in practice not relevant. The third step is to check whether a specific regulation for iron and steel has already been published that sets out the requirements — at present, this is not yet the case. As long as this remains so, no concrete action under the ESPR is required, but it is worthwhile to already take an inventory of what data on the origin, composition and processing of a product are already available, because a future product passport will rely on that data. Once the specific regulation is in place, it will determine the next steps: what data are needed, in what form, and from what point in time.

The basis: Article 1 and Article 2 of the ESPR

That semi-finished products of iron and steel fall within the scope of the ESPR follows from the combination of Article 1, which establishes the subject matter and scope of the regulation including the list of excluded categories, and Article 2, which defines the concept of "product" as any physical object placed on the market or put into service, including parts and intermediate products. Both articles can be consulted via the official text of Regulation (EU) 2024/1781 in the EUR-Lex register.

If you want to prepare now, it is best to start by putting your own product data in order — origin, composition, processing — so that it can later be easily included in a product passport, and keep an eye on this page for when a concrete regulation for iron and steel is published.

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

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. This means that Article 1 sets out the scope in broad terms — almost all physical products coming onto the EU market can in principle fall within it — but the regulation itself does not yet specify which product groups must actually have a product passport. For the steel sector, this is currently the core issue: the law that makes it possible already exists, but which types of steel products are precisely required is not yet determined in it.

Checking whether a product "qualifies" under Article 1

Article 1 of the ESPR describes the subject matter and scope of the regulation: physical goods placed on the market or put into service. For a steel trader or metal processor with 10 to 100 employees, this means in particular that its own product catalogue can be mapped: which semi-finished products are traded, in what form (sheet, tube, profile, bar), and to whom are they supplied. That overview is not a legal obligation in itself, but rather the practical first step to quickly see later which product groups are relevant to what appears in the delegated acts.

Recognising the definitions from Article 2 in one's own business operations

Article 2 of the ESPR provides definitions of terms such as "product", "economic operator" and "placing on the market". These definitions will later determine whether a company is classified as a manufacturer, importer or distributor — and that role in turn determines who is responsible for providing passport data. A trading company that only resells steel without processing generally has a different position than a processor who converts semi-finished products into a new product. It is useful to recognise this role distribution now, so that there is no confusion when obligations become concrete.

Awaiting the delegated act for one's own product group

Because the ESPR itself does not specify product groups, this is done via a delegated act. For steel and iron semi-finished products, it has not yet been established when and in what form this will happen. What a company can do here is not to anticipate substantively requirements that do not yet exist, but rather to follow when its own product category is included. See also the question on this when does the product passport become mandatory for steel.

Making a distinction between semi-finished product and end product

A recurring point is that the status of a product can change as it is further processed. Steel that leaves the factory as a sheet is different from the component that is later made from it at a construction company. Anyone who does not have this distinction clear runs the risk of placing obligations with the wrong party in the chain. This subject is further elaborated in the question does the product passport apply to semi-finished products of steel.

Where things go wrong in practice

A company assumes that "the ESPR does not yet apply" and stops all preparation, while the framework regulation already determines who is considered an economic operator once a delegated act comes into force.
A steel trader assumes that only manufacturers have to do something, and overlooks the fact that importers and distributors also have a role once their product group is designated.
A metal processor treats a processed semi-finished product as "ordinary material" without investigating whether the processing places the product in a different category.
A company confuses the general ESPR obligations with the specific requirements that are established per product group, and thinks that concrete data requirements already apply when they only arise with the delegated act.
A company with a small team leaves the matter alone because "this is anyway only for large manufacturers", without checking whether the company's own size actually matters for applicability.

What you can document

An overview of the products the company trades or processes, including the form (plate, tube, profile, bar) and degree of processing for each product.
A note on the company's own role in the supply chain (manufacturer, importer, distributor or processor) based on the definitions in Article 2 of the ESPR.
A standing arrangement to periodically check whether a delegated act has been published that affects the company's own product group.
Contact details and agreements with suppliers regarding who manages which data on the origin and composition of the steel, in anticipation of the requirement. which data will be included in the steel product passport.
A brief internal explanation for employees on the difference between the ESPR as a framework regulation and the product-specific requirements that must still follow from it, possibly based on the requirement. what the ESPR changes for the steel sector.

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.