Does the passport need to be in a different language when you cross borders?
The regulation that makes the digital product passport mandatory does not prescribe one-to-one in which language the content must be. It primarily sets out which data must be included and how that data must be accessible via the QR code, not the language in which this happens. The precise implementation per product category, including iron and steel, follows from delegated acts that have yet to be published.
What already exists for some time, and what you are more likely to encounter in practice, are language requirements from other regulations that differ per Member State: think of instructions for use, safety information or documentation that comes with a delivery. Those differences already existed before the product passport and do not disappear automatically once the passport is in place. For the exact situation of your company and the country to which you supply, a lawyer or the competent supervisory authority in that country is the appropriate source.
What the regulation itself establishes, and what remains open
The regulation determines that data must be digitally available and that the QR code refers to it. It leaves to delegated acts how this will be worked out in detail per product category, and that is also the level at which language provisions could land, should the legislator include them. Until those acts are in place, it cannot be determined whether, and if so how, language is specifically regulated for iron and steel in them. Anyone wishing to review the text itself once it appears will find the source for each topic in the knowledge base with the source per topic.
What does not change in the meantime is that Member States already apply their own language rules in other areas. A number of countries, for example, require that accompanying documentation for a product be available in the national language, regardless of whether it is a passport, a certificate or instructions for use. Those kinds of rules fall outside the product passport regulation itself, but do count once you physically move steel to that country.
Where the differences become practically noticeable
For a company that supplies within the Netherlands, this subject is usually not a daily concern. Once you send material to another Member State, that picture changes. Customs and market controls in the receiving country look from their own framework at what belongs with a shipment, and that framework is not set up identically in every Member State. It is not only about the language of the passport itself, but also about the language of any accompanying papers that you are already sending with it.
Furthermore, it varies by country which supervisory authority is responsible and how that authority carries out inspections. That subject, who supervises where, is in itself an extensive issue and is addressed separately elsewhere on this platform. For this article, it is particularly relevant to realize that a different supervisory authority can also have a different practice regarding language, even if that is not stated anywhere literally in the product passport regulation itself.
What this means for the design of your passport
A practical question that follows from this: do you build one passport that works everywhere, or do you allow for language variants per market? As long as the delegated acts are not in place, there is no definitive answer to that. What can be assessed is which countries are relevant for your company and what language practice currently applies there for comparable documentation. Inventorying that takes little time and prevents you from being caught off guard at the first cross-border delivery.
When discussing this with a software supplier, it is an important topic to raise explicitly: can the system handle multiple language versions of the same passport data, and how is it recorded which version belongs to which delivery. If you do not yet know where to begin, a few questions will give you a first indication via the free product scan of the topics relevant to your situation, including the location in the official text.
Finally
The key point is that the product passport regulation itself is reticent about language, while existing national rules on accompanying documentation are not necessarily so. Mixing these two layers easily leads to incorrect assumptions. More background on how this information is structured and where it comes from is available on the page how the information on this platform is compiled, and frequently asked questions about cross-border delivery are compiled on the page with answers to frequently asked questions.
Do you need a first overview within half an hour of what is relevant for your company, without immediately creating an account? The free quick-scan provides a short answer per topic, a risk indication and the location in the official text, so you can assess yourself what further investigation deserves.