What data is included in the steel product passport?

What you must concretely do

What is expected of you

The ESPR itself does not lay down which data elements must be included in a passport on a product-by-product basis. Article 10 of Regulation (EU) 2024/1781 describes the requirements that the passport as a system must meet; Articles 5 to 7 describe the categories of performance and information requirements that form the basis for what ultimately goes into it. For steel, the specific content is only established in a delegated act per product group. What can already be said now is: which types of information are named in the legal text as building blocks, and how a steel company can prepare for them.

Product identification and material composition

A passport must make the product traceable to a specific batch or production line. For steel, this means in practice: the steel grade, the applied standard, and the precise composition of alloying elements. A company with 10 to 100 employees that trades semi-finished products does well to structure this upon receipt of the material, rather than reconstructing it only at delivery. How you arrange this is described under how do I establish steel grade and standard in the product passport? and under which alloying elements must I report?.

Environmental performance data

Article 5 mentions, among other things, climate change and resource use as categories on which performance requirements can be set. For steel, it stands to reason that CO2 emissions per tonne will be a recurring data point, together with the scrap share in the melt. These are not separate figures filled in afterwards — they result from the production process and must therefore be recorded during production, not estimated afterwards. See how do I demonstrate CO2 emissions per tonne of steel? and how do I establish the scrap share in the melt?.

Origin of raw materials

Traceability of raw materials recurs as a topic within the information requirements of Article 7. For steel, this particularly concerns the origin of iron ore and the origin of any scrap used. A medium-sized company that does not itself process ore but does purchase semi-finished products is dependent here on what the manufacturer or importer supplies at the top of the chain — that data cannot be invented if the supplier does not pass it on. More on this under do I need to record where the iron ore comes from in the passport.

Durability and end of life

Article 5 also mentions durability, reusability and recyclability as categories. Steel is fundamentally well recyclable, but "demonstrating" that is different from claiming it. What is looked at is what has actually been recorded about the process, not a general statement about the properties of the material as such. See how do I demonstrate that my steel is recyclable for the passport.

Verification and origin of data

Article 10 sets requirements for the reliability of data in the passport: they must be traceable to a source and, where relevant, to a measurement method. For steel companies already working with inspection certificates, there is a connection point here: the 3.1 certificate already contains much of the material-technical data that also belongs in the passport, but the two documents are not interchangeable. See how does an inspection certificate 3.1 relate to the product passport?.

Where things go wrong in practice

A few situations that come up with some regularity among metal processors and construction companies preparing for the passport:

Data are reconstructed after the fact. Production data on scrap share or energy consumption per melt are not recorded at the time of production, but only when a customer asks for a passport. By that time, part of the underlying data is already no longer retrievable, or only approximately.

Certificate and passport are confused. An inspection certificate 3.1 is supplied on the assumption that it contains the same kind of information as a passport. Both documents overlap in part, but the certificate is not built on the requirements of Article 10 and does not automatically cover the environmental performance elements that the ESPR intends.

Origin data stop at the company's own level. A trader or processor records what has happened in their own business, but has no data on the origin of ore or scrap further back in the chain. As soon as that information is requested in the passport, a link is missing that can no longer be reconstructed without the supplier's cooperation.

Composition is recorded too coarsely. A steel grade is noted as a type designation, without recording the underlying alloying elements per weight percentage separately. As soon as more precise data is needed than the standard type designation, that information is not available separately.

Measurement method is not recorded alongside the value. A CO2 value per tonne of steel is recorded without stating the method by which it was calculated. A figure without a method is of limited value for a passport, because the reliability of the value cannot be assessed.

What you can document

• Per production batch: steel grade, applicable standard and complete alloying composition.
• Origin of raw materials: share of scrap in the melt, and where known, origin of the ore used.
• Environmental data per batch or production line: CO2 emissions per tonne, energy consumption, and the method by which these have been determined — see also according to which method should I measure the values for the passport?.
• Supporting documents: inspection certificates, test reports and internal production records, linked to the batch to which they relate.
• Agreements with suppliers on which data they provide and in what form, so that origin and composition data do not get stuck at their own link in the chain.
• An internal overview of which data are already available and which are still missing, in preparation for the moment when the delegated act for steel establishes the definitive list.

We compile templates for subscribers to structure this data per batch, so that the transition to the passport becomes a matter of providing data rather than reconstructing it.