The CE marking of steel says something about the safety and performance of the product itself: does it comply with the harmonised standards that apply to it, for example under the Construction Products Regulation. The digital product passport, which stems from the Ecodesign for Sustainable Products Regulation (ESPR), addresses something different: what information about origin, composition, CO2 footprint and possibilities for reuse is available to everyone in the supply chain. The two are separate from each other and do not replace each other.
The main difference lies in the purpose. CE marking is a declaration by the manufacturer that a product is safe enough to be placed on the market. The digital product passport is an information carrier: it makes product data findable and traceable, with the underlying aim of promoting a more circular approach to raw materials. For the same piece of steel, both obligations can apply, side by side, without one making the other redundant.
What CE marking regulates
CE marking has existed for longer and is linked to product safety. By affixing it, a manufacturer declares, often on the basis of a technical file and harmonised standards, that a product complies with the requirements that apply to that type of product. In the case of steel, this includes, for example, mechanical properties, composition within certain limits, and the way in which the product has been tested or assessed. This system operates under different legislation than the digital product passport and remains in force.
What the digital product passport adds
The digital product passport does not impose new safety requirements. However, it does require the disclosure of data that is currently often only available on paper, in a separate certificate, or not at all: from which batch the material comes, what is the share of recycled steel, and how can the product be returned to the supply chain at the end of its life. This information is linked to a QR code on or with the product. Which data are precisely mandatory and for which product groups is set out in the delegated acts drawn up by the European Commission for each product category; for iron and steel, this text is not yet available. In the knowledge base by topic we keep track of what is already established on this matter and what is not.
Why you should not confuse them
Because both obligations involve documenting the same product, there is a temptation to treat them as a single file. To some extent, this is also possible: data already included in a technical file for CE marking can sometimes also serve as a source for the digital product passport. However, these are separate obligations under separate legislation, with their own scope and their own enforcement. A valid CE marking says nothing about whether a digital product passport is also present, and vice versa. If someone treats the two as interchangeable, they risk one of the two files remaining incomplete.
What this means for practice
For a company that processes or resells steel, this mainly means there are two separate questions to answer: has the product been declared safe enough (CE), and will the associated product information soon be findable via a passport (DPP). Both processes require data from your supplier or manufacturer, and for both it is useful to know early on which data you already have and which are still missing. A brief check helps to clarify this for your own situation; with a few questions you can see roughly where you stand.
Who oversees this
CE marking and the digital product passport are not necessarily checked by the same competent authority, and the way supervision is arranged for the digital product passport is not yet fixed everywhere. For questions about your own situation, including which competent authority in the Netherlands is responsible for which aspect, the competent authority or a lawyer is the appropriate contact point; we maintain general guidance in the frequently asked questions about the passport.
Would you like to know how we compile the data for a passport and where it comes from? You can read that on the page about how it works. And if you first want to see how the digital product passport relates to the documentation you already have, take the free quick-scan or browse through the topics in the knowledge base.