There are two very different questions that both go by the name "how long does it take". The first is when the obligation for iron and steel comes into force: that date is not yet fixed. The second is how much time it takes to, once the obligation is in place, actually get a passport for a concrete product complete and published. That second process is where companies run into problems in practice, and that is what this article is about.
The average lead time for drawing up one passport is not fixed in the regulation and depends heavily on how well the underlying data are already in order. For a company that already maintains certificates, composition and origin in a structured way, it is a matter of weeks. For a company where that information is scattered across emails, PDFs and the memory of one employee, it can easily stretch to months — not because the technology is complicated, but because collecting it is.
What steps make up the lead time
There are roughly four phases. First, the collection of source data: composition, origin, test certificates and any declarations of conformity. Next, determining who in the chain has which role and thus which data must be provided — a question that in itself can cause delays if it is not clearly assigned within the own organization or between manufacturer, importer and trader. Then technical processing: the data are converted into the passport and linked to a QR data carrier. Finally, checking and publication, where it is verified that the passport is complete before it is linked to a product.
Of these four phases, the first is usually the longest, and the third is usually the shortest. Once the data are complete and structured, the technical step is often a matter of days. Anyone discussing this with a software supplier does well to explicitly ask about the processing time between data submission and passport publication, not just about the price per passport.
Where it gets stuck in practice
The most frequently mentioned delay is not within the own organization but in the supply chain. A steel trader who must supplement a passport with data from a foreign producer is dependent on how quickly that producer responds and whether that data already exist in a usable form. Test certificates that do exist but are not digitally available cause similar delays. The same applies to products that go through multiple links: every link that does not have clarity about its own role is a link where the process can stall. What a role in the chain precisely entails and who carries which responsibility is therefore a question that must be answered earlier in the process than only at the final step.
A second source of delay is internal: if no one has been explicitly made responsible for providing and keeping the data current, the task disappears between procurement, quality and administration. That is not a legal problem but an organizational one, and it is precisely the point at which companies that start in time build up an advantage over companies that wait until the obligation is definitive.
A third source is the choice of system in which the data will be stored. A spreadsheet works for a handful of products, but becomes untenable once you are dealing with dozens or hundreds of product variants, each with their own certificates and traceability data. Anyone wishing to accelerate this process would be well advised to look early at how information is recorded and where it comes from, so that when later connecting to a passport system, you do not have to figure everything out again from scratch. how the data for a passport is built up provides a picture of this.
What this means for planning
Because the statutory entry date is not yet fixed, there is no hard deadline to set the turnaround time against. That is precisely a reason to map out your own turnaround time now: which data are missing, which suppliers respond slowly, and which internal step has not yet been assigned. Anyone who does this early will not have to improvise once the obligation becomes concrete.
A good starting point is an overview of your own situation: which products it affects, which data are already available and which still need to be obtained. In the knowledge base with explanations by topic it is explained which data are typically needed per product group, and with the free quick-scan that in a few questions gives a first indication it becomes clear where the greatest time savings can be made. For concrete questions about roles, deadlines and data that frequently come up in practice, the frequently asked questions page is a handy starting point.