The digital product passport for iron and steel stems from a European regulation, and a regulation applies directly and literally in all member states. There is therefore no Dutch or German transposition required, as would be the case with a directive: the requirements for the passport, the data it must contain and the way the QR code provides access are the same rule everywhere in the European Union.
What does differ per country is who supervises it and how that supervision works in practice. Each member state appoints its own market surveillance authority, with its own way of working, its own priorities and its own language in which you communicate with that authority. For a company that purchases or sells steel within the EU, this does not mean the passport is different, but it does mean that the route to it looks slightly different per country.
One text, no eighteen translations of the rule itself
Because it is a regulation and not a directive, no member state needs to transpose the content into national legislation. This is a deliberate choice by the European legislator: with a product that moves freely across the internal market, one wants to prevent one member state from imposing stricter or different requirements than another. A steel profile that is imported in Rotterdam and processed in Poland thus falls under the same passport requirements as a profile that remains in the Netherlands.
This does not mean there is nothing national involved at all. Member states can make their own implementing rules on how they organise supervision, which authority handles notifications and how fines or corrective measures are determined. That implementation side is indeed national, even though the core obligation is European. Exactly who supervises what and which competent market surveillance authority in the Netherlands this will be is not yet laid down in detail at this time; the first delegated act for iron and steel is expected at the earliest in 2026.
Who supervises differs per country
Market surveillance of product legislation has traditionally fallen to national authorities, and the new regulation does not change that. In the Netherlands, this type of supervision usually falls to authorities that already have experience with product safety and CE marking; in other member states it may be a different service, with a different working method and a different pace. For a company that only operates in the Netherlands, this is primarily a matter of knowing which desk you need to contact. For a company that supplies steel to customers in multiple EU countries, it can make a practical difference which authority handles a query or inspection.
Added to this is the fact that the intensity and approach of supervision can differ from country to country, simply because each authority has its own capacity and its own priorities. This says nothing about how strict the rule itself is — that is fixed in the European text — but it does say something about how supervision looks in practice. Companies that purchase or supply internationally are therefore well advised to check with their lawyer or the competent market surveillance authority in the country in question how things work there exactly.
Language, customs and practical differences in cross-border trade
Even if the content of the passport is the same everywhere, there are practical differences in cross-border trade. Think of the language in which accompanying documentation for an authority must be available, customs procedures when importing steel from outside the EU, and the way a port or border customs office arranges supervision of the passport in practice. These matters do not affect the content of the passport, but they do affect the process around it, and that process is organised per country.
For companies exporting steel to countries outside the EU, another point is relevant: the regulation governs placing on the market within the European Union. What exactly applies once a product leaves the EU is a different question, which is not answered by this regulation. If you have doubts about this for a concrete delivery route, it is advisable to discuss this with a legal expert or with customs.
What this means for a passport you are already preparing
For today's practice, this mainly means that the content of the digital product passport does not need to be adapted per country: the same data, the same QR data carrier, the same ten years of availability, regardless of which Member State the steel is ultimately processed in. What you should take into account is that the route to a competent authority, and the language and process surrounding it, may differ per country once you do business internationally.
On the knowledge base with explanations per topic we will elaborate on these kinds of differences as soon as the delegated act and the national implementing rules are known. If you are unsure whether your situation has a cross-border aspect that deserves attention, you can map this out with a few questions. For background on how we obtain our information, please read how we maintain data and sources, and frequently asked questions on this topic can be found compiled on one page.
Do you have half an hour and want to know whether and how this topic applies to your company? Take the free quick scan or read through the knowledge base at your own pace — both cost you nothing and provide an immediate concrete indication.