Whether the digital product passport also applies to steel that you already have in stock depends on the moment that steel was put on the market, not on the moment you sell or process it. Product legislation such as the ESPR Regulation usually works with that turning point: from the date of obligation, newly placed-on-the-market steel must comply with the requirements. For steel that was already placed on the market before that, comparable regulations usually do not provide for retroactive obligations, but the precise transitional rules for iron and steel have not yet been published.
This means concretely that you cannot say with certainty at this moment whether your current stock will fall under the scheme or not. The delegated act that establishes this still needs to be published. What you can do now is to identify which part of your assortment falls within the scope of iron and steel and what role you play in it, so you are not caught off guard once the date and the transition period are known.
Why this question is arising now
Companies that purchase raw materials or semi-finished products often work with inventories that remain for months or even years before they are processed or resold. An installation company with steel profiles in the warehouse, a trader with batches of sheet steel, a construction company with offcuts: in all those cases it is legitimate to ask whether a passport will have to be created retroactively for something that has been in possession for years. That question is understandable, but cannot be answered with certainty at this moment, because the regulation itself has not yet been worked out for this product category.
What the regulation appears to use as a turning point
In the broader ESPR Regulation and in comparable European product rules, the moment of "placing on the market" is often used: the first moment a product is made available on the European market. Obligations that take effect later then generally apply to products that are placed on the market after that date. Product that was already sold or delivered earlier remains outside the new obligation in many comparable regulations. This is a general pattern in product legislation, not a fixed fact for iron and steel specifically. The delegated act for this product category still needs to confirm this, with its own dates and possibly its own exceptions.
To be able to follow this pattern properly, it is useful to learn to read the regulation itself once the text is available. If you want to understand now how such a text is structured and where the key concepts are located, you will find an overview in the knowledge base with explanations by topic.
What this could mean for your inventory
If a transitional arrangement is created, it is likely that it will address two questions separately: the moment a product was first placed on the market, and the moment that product is resold or processed again. A trader who resells steel that was already with him before the date of obligation may be in a different position than a manufacturer who produces new steel after that date. The question of whether you act as a manufacturer, importer or distributor can also play a role in how a transitional arrangement is applied. That distinction is described in the regulation itself, not in this article, and may differ depending on your role in the chain.
Because this can differ per company and per product stream, it is useful to examine for your own assortment which part falls within the scope of iron and steel and which part does not. With a few targeted questions you get a first indication of this; this could be done for example via the product scan that gives an indication in a few steps.
What you can do now, without waiting for the final text
Even without the delegated act already in place, it makes sense to start inventorying which steel products you have in stock, who you received them from, and what information goes with them: certificates, composition, origin. You will need that information anyway once a product passport is compiled, regardless of whether that applies to existing or new stock. This way you build a basis that you can build on later, instead of having to reconstruct everything afterwards.
Frequently asked practical questions about scope and transition moments are also tracked separately, each with a brief explanation and a reference to the location in the official text once it is known; you will find these under the frequently asked questions about the product passport. For those who want to know how ferropas.eu compiles the information on this site and which sources underlie it, this is described on the page about how the information on ferropas.eu is compiled.
For the situation of your own company and your own stock, it remains advisable to consult a lawyer if in doubt or to contact the competent supervisory authority, especially once the delegated act has been published and the transition periods become known.
Would you like to get an idea of which part of your assortment will be relevant in future? Do the free quick-scan or browse through the topics in the knowledge base to see what is already known for your type of business.