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Which data must I request from my steel supplier?

Basic data on origin, composition and conformity

A supplier of steel or iron semi-finished products is asked to provide the data needed to compile a digital product passport: where the material comes from, what it is composed of, and which conformity documents are associated with it. In practice, this means data on the manufacturer or importer, precise product identification (type, alloy, dimensions, batch or lot number), the origin of raw materials, and any existing certificates such as material certificates or inspection reports. These data form the basis on which a passport is built; without input from the supplier, there is simply nothing to put in the passport.

Who this applies to and who it does not

This question is relevant for companies that purchase steel or iron semi-finished products and become responsible for the product further down the chain — for example, a metal processor who processes and resells the material, or a construction company that processes it into an end product. This concerns the information obligation between actors in the supply chain, not the question of who ultimately must have the passport drawn up or published. These two things overlap but are not the same: the supplier provides data, but this does not automatically mean that the supplier is also the one who produces or hosts the passport itself.

This also applies only to product categories for which the delegated act under the ESPR actually sets requirements. Steel and iron are on the list of sectors that the European Commission has identified as a priority, but the specific substantive requirements — which data exactly, at what level of detail — are only established once that act is in place. Until then, this is a preparatory question, not a mandatory question.

When this becomes mandatory, and what applies until then

There is no fixed date yet for when requesting this data becomes a legal obligation. According to the ESPR work plan for the period 2025-2030, the first delegated act relevant to this sector is expected in 2026, with obligations entering into force eighteen months thereafter. Once that act is published, the exact date will be determined and will be stated here.

Until then, there is no legal obligation to collect this data. What can already be done: identify which suppliers in the chain can provide the necessary data, and which of them already keep that data in a structured manner versus which do not. This will save time once the obligation does come into effect.

How to approach this, step by step

The first step is to identify which suppliers are in the chain for the steel or iron being purchased, and which of them is the original manufacturer or importer — this is the party that has the source data, even if the material comes in through an intermediary. Next, ask whether that manufacturer or importer already records data on material composition, origin and any existing certification, and in what form this occurs (paper, PDF, structured data).

After that, it is useful to ask whether the supplier is willing to share this data with a third party that compiles and hosts the passport — this is a practical arrangement that is separate from the legal obligation, but it does determine how smoothly the process will run later. Finally, it is worthwhile to ask about batch numbers or lot identification per delivery, because a passport is typically drawn up per product or per batch and not as a single general declaration for the entire assortment of a supplier.

Those who tackle this now do not have to reconstruct data in a short time later that was actually available at the source.

This is based on: Article 38 and Article 10 ESPR

Article 38 of the ESPR (Regulation (EU) 2024/1781) describes the requirements applicable to actors in the supply chain, namely the obligation to communicate relevant product information to the party further down the chain who is responsible for the product. Article 10 of the same regulation describes what data a digital product passport must contain. Together, these articles determine what information is needed and where it must come from — however, the precise content requirements for steel and iron will only follow from the product-specific delegated act that has not yet been published.

What to do now

If you are already purchasing steel or iron semi-finished products, you can start by asking your own suppliers who the manufacturer or importer is, what data that party is already recording, and whether parts of it are negotiable with a third party. Once the delegated act for this sector is published, the precise list of mandatory data will be 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

What is expected of you

A product passport for steel is not completed by a single party alone. The information comes from different places in the chain: the steel producer, the importer, possibly an intermediary, and ultimately the party that compiles and hosts the passport. Article 38 of the ESPR (Regulation (EU) 2024/1781) stipulates that actors in the supply chain must provide the information needed to comply with product requirements. What this concretely means for a steel trader or metal processor with 10 to 100 employees breaks down into a few separate obligations.

Determining exactly what must be requested

Before anything is requested from a supplier, it must be clear which data the passport will need later. Article 10 of the ESPR describes the requirements for the content of the digital product passport in general terms; the exact data set for steel and iron will be further specified per product group. For a company of this size, this means that a questionnaire cannot simply be sent to the supplier blindly — it must first be determined internally (or with the help of a template) which categories of information are relevant: origin of raw materials, composition, process data, recycling percentages, and the like. On What is a digital product passport for steel? is an overview of what a passport basically contains.

Actually requesting data from the supplier

Once it is clear which data are needed, the practical work follows: actually obtaining that data from the supplier. For a company with a small procurement team, this is often the biggest hurdle, because it usually involves not one supplier but a changing number, with varying willingness to share data. A fixed questionnaire sent with each order, or included as a fixed part of the request for quotation, prevents this from being reinvented with each purchase.

Checking whether the supplied data are complete and usable

Requesting data is not the same as receiving usable data. A supplier may send a response that is incomplete, in a different format, or does not match what the passport needs. For a company of this size, it is practical to set this up as a separate control point, separate from the normal receipt inspection of the goods. On How do I verify that my supplier's data is correct? is how this control can be implemented in practice.

Recording data so that they remain traceable

The data requested from the supplier must be findable at some point — for example, when a customer or supervisor asks where a particular piece of data in the passport comes from. This means that it is not sufficient to receive an email with an attachment and store it somewhere; there must remain a link between the batch, order, and the data itself.

Where things go wrong in practice

The questionnaire is sent too late. Data is often only requested when the passport already needs to be compiled, while the supplier has long since moved on to the next order. Historical data are then more difficult to reconstruct.

Reliance is placed on a verbal commitment. A supplier agrees verbally or in a conversation that "the data will come", without this being documented anywhere. When push comes to shove, there is nothing to fall back on.

The data do come, but not in a matching form. A supplier sends a certificate or technical datasheet that is correct in itself, but does not have the format needed to process in the passport. This causes delays because everything must be requested again.

Multiple suppliers provide data on the same part of the product. For composite semi-finished products, steel sometimes comes from multiple batches, and this raises the question of how that data form one coherent whole. On how do I combine data from different suppliers in one passport this issue is elaborated further.

A supplier outside the EU does not respond according to the same rhythm or format. When importing steel from outside the EU, additional questions arise regarding the origin and reliability of the supplied data, which do not arise in the same way with a European supplier. See also What does the product passport mean if I import steel from outside the EU?

What you can document

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.