Does your company have establishments in multiple EU countries, or do you supply steel to customers in Germany, Belgium or further afield? Then a logical question arises: does the conversation with your software supplier change if the digital product passport also needs to work abroad? The short answer: the core of the regulation applies in the same way throughout the EU, but the implementation — how the passport is displayed, verified and possibly connected to national systems — can differ by country. That is precisely where you make concrete agreements with your supplier.
This article sets out what remains the same throughout the EU, where countries may differ, and what questions you can ask your software supplier about this. For the broader foundation of the passport we refer you to the knowledge base with all topics.
What remains the same throughout the EU
The underlying regulation for sustainable products is a European regulation. This means it applies directly in every Member State, without each country having to first make its own law from it. The core of the digital product passport — which data belongs in it, that it has a unique identification attached, and that it is accessible via a QR code — therefore applies in the same way everywhere. A steel product whose passport is correctly compiled for the Dutch market, in principle meets those same basic requirements when it goes to another Member State.
This is precisely why a conversation with your software supplier does not necessarily become more complicated as soon as you supply internationally. The basic obligation does not change at borders. What can differ is the way Member States organise supervision and practical details around language and systems.
Where countries may differ
Supervision and point of contact
Each Member State designates its own market surveillance authority. This means that an inspection in the Netherlands is handled by a different authority than an inspection in, for example, France or Poland. For you as a company, the content of the passport does not change, but it is important to know that the party requesting access may be different depending on the country.
Language and readability
Whether a passport must be displayed in multiple languages depends on where the product is sold and used. Some software suppliers build their system so that the same source data is automatically displayed in different languages, others provide Dutch-language output as standard only. You will only notice this difference if you ask about it.
Connection to national systems
It is currently unclear whether, and in what form, Member States will link additional national registers or customs systems to the European product passport. Where this does happen, it is up to your software supplier to ensure that the data is also available via that link. As long as the delegated act for iron and steel has not been published, this part has not yet been filled in.
What you ask your software supplier
A few questions are particularly relevant as soon as you supply across borders. Does the system support multiple languages from the same source data, or do you need to enter separately for each language? How does the system handle a supervisor from another country requesting access, and who is the point of contact for this with the supplier? Is the passport hosted centrally, or in a separate environment per country, and what does that mean for the ten years it must remain available? These questions belong in the same conversation in which you also discuss the basis of the passport with your supplier. How that data is exactly created and where it comes from, you can read on the page about how the information is compiled.
What is not yet established
The first delegated act for iron and steel is currently expected around 2026, with obligations to follow approximately eighteen months later. As long as that text is not available, it has not yet been determined how country-specific implementation will look in detail. For the question of how this will play out for your own company and your own export countries, it is advisable to make enquiries with a lawyer or with the competent authority in the country concerned.
Would you like to first take stock of where you stand now? Do the free quick-scan via in a few questions see where you stand, or browse through the topics in frequently asked questions about the product passport.