When does the product passport affect your company?
Whether the digital product passport for iron and steel applies to your company depends on two things: the role you play in the product (do you manufacture, import or trade it, or do you only use it further down the chain) and whether the specific product you work with is already covered by a delegated act. For iron and steel, that act does not yet exist. The European Commission is working according to a work plan for the period 2025-2030, in which the first delegated acts are expected for 2026, with obligations taking effect eighteen months later. For iron and steel itself, ferropas.eu is working on a timeframe around 2028, but that date is not fixed and will only become concrete once the text is published.
This means that the question "does this apply to me" does not yet have a definitive answer, but it is certainly possible to prepare well for it. The regulation itself describes quite precisely what type of company will have what obligation once a product category is designated. If you already know where you stand in that classification, you won't have to improvise later.
For whom the passport is initially intended
The obligation to have a passport drawn up lies at its core with whoever places the product on the EU market: the manufacturer who produces steel or iron semi-finished products, or the importer who brings it in from a country outside the EU. That is the party that must provide the data on material, origin and composition, and is therefore responsible for its accuracy. In our knowledge base we explain how this role is precisely defined and what term the regulation uses for it.
If your company manufactures steel or iron semi-finished products itself, or imports them directly from a third country to sell them within the EU, that is the scenario in which the obligation is most likely to fall directly on you once the delegated act takes effect. This applies regardless of whether you are a trading company, a rolling mill or an importer of castings: the role you play carries more weight than the industry in which you operate.
When you are not yet directly involved
Some companies in the chain do not receive the obligation directly, but do experience its consequences. An installation company that purchases steel profiles from a wholesaler, or a construction company that processes sheet steel into a final product, is usually not a supplier within the meaning of the regulation. You process or use the material, you do not place it on the market as such. This does not mean it completely bypasses you: if your supplier then has to provide a passport, you will probably expect that this information is correct and usable, for example for your own purchasing file or for a client who asks for it.
An office organisation or a company that uses steel only as fastening material or tools usually also falls outside the circle of direct obligations. The question that then remains is not "must I create a passport", but "must I later be able to demonstrate that I can handle passports" — and that is a different, much smaller task.
What the regulation stipulates about timing
The regulation itself does not tie the obligation to a fixed calendar date for all products at the same time, but to the publication of a delegated act per product group. As long as that act does not exist for iron and steel, there is no legal obligation to have a passport drawn up right now. What does already exist is the work plan in which the Commission indicates what order it will follow and what timelines apply after that. On the page about where our information comes from read how we follow that schedule and update it as soon as an official text is available.
This distinction between "not yet mandatory" and "never mandatory" is important. For many companies in the steel chain, the question is not whether the product passport will ever apply, but when and in what form. Waiting until the date is set is a valid choice; finding out now where you stand saves effort once the obligation takes effect.
How you check this for your own company
Because the classification depends on your role, your product and the moment a delegated act appears, a general answer for "the steel sector" cannot be given. What does work is to systematically go through it for your own situation: what product leaves your company, in what form, and to whom. With a few questions see where you roughly stand you get a first, free indication of this, without this being a legal judgment on your specific case. For the underlying concepts and the precise location in the official text, you can consult the knowledge base with explanations per topic.
If after reading you still have a question that is not covered here, part of the frequently asked questions is collected on the page with frequently asked questions. For a judgment on your own business situation, a lawyer or the competent supervisory authority remains the right contact point; ferropas.eu describes the regulation, but does not judge individual cases.
Do you want to quickly know roughly where you stand, without immediately creating an account? Do the free quick-scan or browse through the topics in the knowledge base — both are a good starting point to clarify this question for your own company.