The most common mistake when purchasing steel with the digital product passport in mind is that companies wait to record origin and composition data until the obligation actually takes effect. At the moment the passport becomes mandatory, it turns out that no one can trace which batch, which melt, or which supplier a particular delivery came from.
That is not a matter of unwillingness. Steel purchasing often takes place through long-standing relationships, verbal agreements, and delivery notes that are no longer kept after a few years. As long as there was no legal obligation to retain that data, no one had reason to do so. The problem only arises when the data is needed retroactively, and by then the batch has often already been processed, resold, or delivered years ago.
Why this is difficult to restore afterwards
A product passport is built on data that comes from the manufacturer or importer: composition, origin, and the path the material has taken. That data is created at the moment of production and first sale, not at the moment a passport becomes mandatory. Those who only begin recording once the obligation takes effect will miss everything that was purchased and processed before that.
The regulation itself determines from which point a passport is mandatory for new products placed on the market. For existing stock and previously purchased material, it is different, and that is precisely where uncertainty arises. Companies that think about this now do not avoid the obligation itself, but rather prevent the situation where they later have empty hands for material already in the warehouse.
What goes wrong in practice with the purchasing agreement
The mistake often lies not in bad faith on the part of the supplier, but in a missing agreement. Purchasing terms regulate price, delivery time, and quality certificates, but rarely explicitly who is responsible for providing passport data once it becomes necessary. Without that agreement, there is no incentive at delivery to maintain origin data in a structured manner.
This becomes more acute the more links there are between manufacturer and end user. A trader who resells steel is dependent on what the upstream supplier provides for their own purchases. Those who do not record which role a batch plays in that chain run the risk that data disappears along the way without anyone noticing. the roles in the chain at a glance shows how that responsibility is distributed in the regulation.
What you can already record now, without jumping ahead to the deadline
The obligation itself does not yet have a fixed date: the ESPR work plan foresees a first delegated act in 2026, with obligations that will take considerable time after that. That does not mean waiting is the safest choice. What does help is to already keep track of which data you normally receive anyway: certificates of origin, melt numbers, supplier declarations. You are already keeping that data for quality assurance; it takes little extra effort to archive it consistently per delivery rather than per project.
A good first step is to check where your company currently receives data that may be relevant later, and where it is still missing. in a few questions see where you currently stand gives an initial direction there, without you needing to be familiar with the subject matter beforehand.
The conversation with the supplier: the agreement that is often missing
With new purchasing contracts, it makes sense to discuss now who supplies which data once it becomes necessary, and in what form. That does not need to be a legally airtight clause; a concrete agreement on which documents belong with which delivery already prevents much of the later search. Suppliers who will themselves be subject to the regulation are usually not surprised when you raise the subject.
This arrangement is separate from existing quality certificates and inspection certificates, which are often already required under other regulations. The product passport adds a structured, digital layer to those, but does not replace them. For questions specific to your purchasing contracts or supplier relationships, a lawyer or the competent supervisory authority is the appropriate contact; this article describes only the general picture.
Not the only lack of clarity
This error does not stand alone. Other frequently asked questions, about documents, lead times and who exactly is responsible, recur in the most frequently asked questions about the product passport. Those who want to know where the data on ferropas.eu comes from and how it is compiled will find that in the page about our working method.
Would you like to know where your company currently stands in relation to this obligation? The free quick-scan provides a first indication in a few minutes, without you needing an account.