What is my role in the iron and steel chain under the digital product passport?
The regulation works with a classification of roles that it assigns to the supply chain: manufacturer, importer, authorised representative and distributor. Each role is assigned a different task regarding the digital product passport — who has the data compiled, who checks it when steel is brought in from a country outside the EU, and who must primarily ensure that an existing passport is included when the product is sold on. Which role applies to your company depends on what you do with the iron or steel before it reaches the next link in the chain.
For many companies in steel trading and metal processing, that is not a straightforward question. One and the same company can act as a distributor in one transaction — it buys and sells steel without substantially changing it — and as a manufacturer in another transaction, for example when the steel is processed so thoroughly that, in the eyes of the regulation, a new product is created. This classification is therefore not a fixed label per company, but something that is reconsidered for each product or each chain.
The roles distinguished by the regulation
The manufacturer is the person who produces the product, or has it produced under their own name, and places it on the market for the first time. The importer is the party that brings steel from outside the EU onto the European market for the first time; that position naturally entails more inspection tasks, because there is no supervisory authority outside the EU that has already checked the passport. The authorised representative is a party within the EU that acts on behalf of a manufacturer outside the EU, with a written mandate to do so. The distributor, finally, is any link that buys and sells steel without being a manufacturer, importer or authorised representative — think of a wholesaler or a trader holding stock.
Why the role determines what is expected of you
The manufacturer and the importer typically bear the heaviest burden: they ensure that the passport is created, with the correct data on the origin, composition and properties of the steel. The distributor has a lighter, but not optional task: to check that the passport is present before the product is sold on, and not to let it disappear into their own administration. Precisely for that reason, it is worthwhile to examine for each product line which role you fulfil, rather than assuming one label for the entire company. In the knowledge base with the elaboration per role this is further broken down per situation.
When processing changes your role
The point where this causes the most friction in practice is processing. Cutting to size, drilling, welding, galvanising or coating can in certain circumstances mean that a trader no longer qualifies as a distributor, but as a manufacturer of a new product — with the associated task of having a passport compiled yourself instead of passing on the supplier's passport. Where exactly that line is drawn is set out in the regulation itself and is further specified in the delegated acts per product group; this is not an assessment that this article can make for you. Companies that are uncertain about their own processing steps are well advised to discuss this with a lawyer or the competent supervisory authority, and in the meantime to see in a few questions approximately where their situation stands.
One company, multiple roles
It is common for a company to perform multiple roles simultaneously: distributor for one product range, importer for another, and sometimes manufacturer for a third line with its own processing. The regulation does not force a single choice; it looks at each product and each transaction. In practice, this means that the administration surrounding the passport — who supplies the data, who keeps it, who passes it on — can differ per product line. Frequently asked questions on this topic, with the nuances that apply to each situation, are compiled on the page with frequently asked questions.
How you determine this for your own company
A useful starting point is not the question "what am I", but "what do I do with this specific steel, and where do I get it from". If the steel comes from a manufacturer within the EU and you do not change it, that points towards distributor. If you source it yourself from a country outside the EU, that points towards importer. If you process it in such a way that a new product is created, then manufacturer is a realistic scenario. Where that data comes from and how it reaches the passport, you can read on the page on how the information is prepared. For most companies, this is not a one-time exercise but something to revisit whenever the product range or suppliers change.
Would you like to see an initial direction for your own company? The free quick-scan gives you an indication of your role and what goes with it in a few questions, without needing an account.