Short answer
Supervision of the digital product passport will change this year mainly on paper, not yet in practice at your company. The Ecodesign for Sustainable Products Regulation (ESPR) is already in force as a framework regulation, but the specific rules for iron and steel — the so-called delegated act — have not yet been published. As long as that is not the case, there is also no concrete obligation for steel to enforce. What will happen this year is that the European Commission and the Member States build the underlying structure: who is competent where, how notifications flow, and which authority in the Netherlands will take on the role of market surveillance.
For a director, HR manager or office manager, this mainly means that there is no concrete enforcement date yet to put in the agenda. However, it is useful to know what steps have already been taken, so that you are not caught off guard once the delegated act for iron and steel does appear.
What is already fixed in the regulation
The ESPR itself sets out the general framework: what a product passport must look like, who is designated as a market operator, and that Member States must designate a competent authority for market surveillance. The latter is not a new principle — the Netherlands has long had supervisory bodies for product safety, for example around CE marking. The expectation within the policy process is that for the digital product passport it will be aligned with existing structures for market surveillance, but a definitive designation specifically for iron and steel has not yet been published. Who exactly that will be, and with what powers, will only be determined once the official designation is there.
The Commission's work plan provides for a first delegated act in 2026, with obligations following roughly eighteen months later. That is a plan, not a guaranteed date. As long as the delegated act for iron and steel is not published, no one can say with certainty when enforcement will become concrete for your sector.
What is moving this year
Behind the scenes, more is happening than the date on the agenda suggests. At EU level, work is underway on the register in which product passports must be entered, and on technical standards for how data is exchanged between parties in the supply chain. National supervisory authorities are monitoring that process, among other things to determine what expertise and capacity will be needed once the obligation takes effect. For your company, therefore, nothing changes this year in what you must provide, but there is a real possibility that the requirements for data formats and links will become clearer. That is relevant for your conversation with your software supplier, even though the enforcement date is not yet fixed.
In addition, some industry organisations and larger buyers in the steel supply chain are already moving ahead, anticipating the expected obligation. This can lead to a client or supply chain partner asking for data earlier than the law strictly requires. This is not a legal obligation under the regulation itself, but something to take into account in existing contracts.
How to follow this without having to keep up with it daily
For most SMEs it is not practical to follow the European legislative process itself. It is more convenient to check at a set time whether anything has changed, for example via an overview per topic that is maintained. This shows per topic what is currently established and what is still being developed, with the source in the official text included.
Do you want to know what this specifically means for your position in the supply chain, for example as a manufacturer, importer or processor of steel? Then the quick-scan with a few short questions a first indication is provided. For frequently asked questions, such as who is responsible for what, there is an overview of frequently asked questions.
What this does not mean
The absence of a fixed enforcement date does not mean there is nothing to do. It mainly means that the sequence is different from legislation that is already fully elaborated: first comes the delegated act, then the designation of supervisory authorities, and only then concrete inspection. For the correct assessment of your own situation, and for questions about how a supervisory authority in your sector operates precisely, a legal advisor or the competent supervisory authority is the appropriate party. You can read more about how we collect and maintain information on the page about our working method.
Would you like to sharpen this topic for your own business without spending half a day on it? Take the free quick-scan or read the other topics in the knowledge base — both give you an honest picture of where you stand in a few minutes.