Does the digital product passport also apply to my company if I only process steel?
Whether your company itself will have obligations regarding the digital product passport does not depend on the question of whether you process steel, but on what happens to that steel after your processing. If you saw, cut or bend a plate or profile and sell the result as a component that will be further processed, you will in many cases remain within the role that was already established earlier in the chain. If your processing transforms the semi-finished product into a new, independently marketable product, it may mean that you yourself are seen as the manufacturer of that new product.
The short answer is therefore: it is not about the action itself, but about the question of whether your processing creates a new product that is placed separately on the market. The regulation works with roles such as manufacturer, importer and distributor, and that role determines who must provide which information. If you would like to calmly work through this for your own situation, can provide you with a first indication in a few questions of where your company roughly stands.
What the regulation means by a new product
The core of the regulation lies in the moment when a product "is placed on the market". A manufacturer of steel plate places that semi-finished product on the market and provides the product information with it. If you buy that plate, saw it to size and pass on exactly the same plate, only shorter, to your customer, the chances are good that you remain within the existing chain information. However, if you build a balcony railing, a staircase or a structural element from that same plate that is sold as an independent product, a new product has been created. Whoever places that new product on the market first may take on the role of manufacturer, with the associated obligations.
This distinction is not developed in the same way in all sectors, and the precise demarcation between "processing" and "making a new product" follows from the product category that the European Commission establishes by delegated act. For steel and iron, this elaboration has not yet been published. What is already known about it is explained in the knowledge base sorted by topic.
When processing does bring obligations with it
There are a few situations where processing more often leads to an obligation of its own. As soon as you combine components into a composite product, as soon as you give the material a different technical function than what it was originally intended for, or as soon as you sell the product under your own brand or name, your own role as a manufacturer becomes more likely. Conversely: purely mechanical processing without changing the nature of the product — sawing to size, drilling, deburring — is more often seen in the guidance on the regulation as "processing within the chain", without automatically bringing a new passport obligation with it.
This is a classification that can differ from case to case and which is ultimately assessed by the supervisory authority or, in case of doubt, by a court. For your own situation, this is not an assessment that can be made on the basis of a general article; for that, the official text or a lawyer is the right point of contact.
What you can do in the meantime
Even without a delegated act for steel and iron having been published yet, it is worthwhile for metal processors and construction companies to map out now which processing operations you carry out as standard and whether these result in a new, independent product. That overview will help later, when the obligation becomes concrete, to quickly determine which role applies to which part of your assortment. In practical terms, that means: checking which semi-finished products you purchase, what documentation is already supplied with them, and which products you yourself place on the market as end products. How that process works in practice once the passport becomes mandatory is described on the page about where the information in the passport comes from.
What is not yet established
The obligations for iron and steel follow from the action plan of the Ecodesign for Sustainable Products Regulation (ESPR). The first delegated act for this product group is currently expected around 2026, with obligations that come into effect some months later. As long as that act has not been published, it is not certain how the distribution of roles between manufacturer, processor and distributor will be defined precisely for steel products. Once that text is available, it will be incorporated here.
Do you have questions about how these kinds of distinctions are assessed in practice, or would you like first a broader picture of the obligations that may apply to your company? Do the free quick-scan or browse through the topics in the knowledge bank; frequently occurring cases of doubt are also on the page with answers to questions other companies have already asked.