When does this conversation become relevant for you?
Short answer: only when two things coincide. First, it must be established that the digital product passport for the iron or steel product you sell, process or import will actually become mandatory on the date set by the European Commission. Second, you must know what role you fulfil in the chain: are you the party that must have the passport drawn up, or do you primarily supply data to another party that does so. As long as one of the two remains unclear, your conversation with your software supplier need be no more than an initial exploration.
That does not mean you cannot do anything. In fact, many companies discover during an initial conversation with their ERP or inventory software supplier how their current system handles source data, certificates and batch numbers. That information is useful now, even if the obligation itself is not yet established.
What is not yet established, and what is
The ESPR, the European regulation that sets the framework for product passports, works with a roadmap for the period 2025-2030. For iron and steel, the first delegated act, the document in which the specific requirements for this product group will be set out, is expected in 2026. Following publication, there is usually a transition period of approximately eighteen months before the obligations enter into force. On that basis, 2028 is often mentioned as a target date, but that date is not yet fixed. Once the delegated act has been published, the exact date will be stated here.
As long as that act is not in place, it is also not possible to say with certainty which data fields will be mandatory, and therefore not exactly what you will need from your software supplier. That is one of the reasons to distinguish between exploring and establishing.
Exploring is possible now, establishing is not yet
An exploratory conversation with your software supplier is about questions such as: where are the current data on source and composition stored, who manages it, and can the system accommodate an additional link or export format once it is needed. This kind of questions takes little time and already provides insight into your own administration.
Establishing, i.e. adapting a contract, purchasing a module or having a link built that is specifically tailored to the digital product passport, gains more value once the delegated act is known. Only then will it become clear which fields are mandatory and in what format data must be supplied. Companies that now make major investments based on assumptions run the risk that the ultimate requirements will differ in some respects.
Who this affects sooner than others
The order in which companies will have this conversation largely depends on the role they fulfil in the chain. A manufacturer or importer designated as a supplier bears the responsibility for assembling the passport and needs a complete picture of what their own systems can do sooner. A distributor or processor that mainly passes on data is sooner dependent on what that supplier provides. Which role applies to your company is described in the regulation itself; the knowledge base with explanation per role in the chain sets the definitions alongside each other.
The scope of your current software landscape also plays a part. A company that already works with a modern ERP system in which source and certificate data are structured and recorded has a shorter way to go than a company that currently keeps this data on paper or in separate spreadsheets.
How you can already get clarity for yourself on whether it affects you
To determine whether, and when, this conversation becomes urgent for your business, it is particularly important to know which product you trade, in which role, and how your data is currently organised. in a few questions you will see where your business stands at this moment, without this immediately entailing any obligations.
Would you like to know in advance how the data chain will be structured, which part of it lies with a software supplier and which part with ferropas.eu? on this page you will find where the information for the passport comes from. This makes the conversation with your own supplier more concrete, even while the final requirements have not yet been published.
For the question of whether your specific situation falls under the obligation, and as of when, the text of the regulation and the explanation from the competent supervisory authority are decisive; a lawyer can translate those to your own business. On the page with frequently asked questions the questions we most frequently receive about timing and role distribution are set out in more detail.
Do the free scan
Would you like to know, without obligations, where you stand for your own products, and whether this conversation is already urgent for you or can still wait? Do the free quick-scan or browse through the topics in the knowledge base; both are freely accessible, even without an account.