What is changing in your business practices this year already?
For iron and steel, the digital product passport is not yet mandatory this year. No delegated act has yet been published that sets out when and for which product groups within iron and steel the obligation will apply. Yet changes are already happening in the practices of many businesses this year, and this is not in the law itself but in how suppliers, software companies and industry associations are preparing.
The European Commission's work programme for the ESPR (the Ecodesign Regulation under which the product passport falls) names 2026 as the year in which the first delegated act is expected. Obligations typically follow around eighteen months after publication of such an act. That is an expectation, not a fixed date. What is noticeably changing this year is that the preparation phase is moving into a more concrete phase: there will be draft texts, consultations and initial decisions on which data will have to be included in the passport.
No obligation yet, but a timeline drawing closer
The reason this topic feels more relevant this year than last year is not that something has come into force. It is that the timeline is getting closer. Once the first delegated act appears, it will be established for which product groups within iron and steel the clock starts ticking, and how much time businesses have to be ready. Until that publication, everything said about this remains an expectation based on the published work programme.
That does not mean you can do nothing. It mainly means that the order is reversed compared to much other legislation: normally you wait until a law comes into force and then you adapt your processes. Here the expected obligation has been known for longer, but the precise content is not yet known. Those who know this can use the waiting time.
What is already noticeably changing in practice this year
Three things are noticeably shifting this year, even without anything becoming mandatory. First, more and more customers in the steel supply chain, particularly larger construction companies and OEMs, are asking their suppliers whether they are already working on the product passport. This is not yet happening as a contractual requirement, but as a question in the purchasing relationship. Second, software suppliers and industry associations are beginning to publish concrete datasets which they expect will be needed: material origin, composition, CO2-related data and certificates. Third, there is growing clarity about who in a supply chain is considered a supplier and who is a distributor, which has implications for who must provide which data.
None of these three developments is an obligation. But they are a signal that the sector is preparing for a timeline that, if expectations are correct, will take its first fixed form in 2026.
Who this affects and who can still wait
Whether this means something in the short term for your business depends heavily on your position in the chain. A manufacturer or importer of steel semi-finished products is at the forefront, because the role of supplier is most obvious for these parties. A processing business that purchases and works steel will mainly notice the change through questions that clients and suppliers start asking. A business that only takes inventory and makes no changes to the product can still calmly follow developments this year without taking action.
The difference between these positions is precisely why a general statement about "what is changing this year" has little value without looking at your own situation. in a few questions see which role fits your business gives an initial direction for this, without you having to open a file immediately.
What you can prepare now
Without being obliged to do so, you can still get three things in order this year. Make sure you know which data on origin, composition and processing of your steel you are already recording now and where those data are stored. Ask your software supplier or current ERP provider whether they are following developments around the product passport, and what that would mean for your system. And follow the publication of the first delegated act, because that determines the actual date and scope, not the expectations circulating now.
How these three steps come together in practice is described in more detail in the knowledge base sorted by topic, where for each situation it is indicated what is and is not yet established.
Where you can follow this type of changes
Because the timeline can still shift this year, it is more useful to follow the source than a single article. We keep track of the work programme and the publication of delegated acts and update the information on ferropas.eu as soon as something is established. You can read how that information is compiled and what it is based on at the page that explains where our information comes from. Frequently asked questions about the scope and the roles in the chain are bundled at the page with frequently asked questions.
Do you have half an hour and want to know whether this topic already requires something from you this year? The free quick-scan provides an initial indication, and the knowledge base helps you further on the aspects that apply to your company.