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What changes in your conversation with your software supplier this year?

The regulation itself is not changing this year, but your conversation with your ERP or software supplier is: from orientation to concrete questions about fields, integrations and planning.

What changes in your conversation with your software supplier this year?

This year there is no change in legal obligation: the delegated act that sets out the technical details of the digital product passport for iron and steel has not yet been published. What is changing is the phase your conversation with your software supplier is in. Where that conversation previously focused on what a product passport actually is, this year it increasingly focuses on something more concrete: which data fields will be needed, how they connect to your current system, and what planning goes with that.

For those it applies to: especially for companies that are updating their ERP system, inventory management or document management this year anyway. If your supplier releases a new version this year, it is worthwhile to ask how that version relates to the product passport, even if you do not yet know whether and when you will have to comply with it.

From introduction to planning

A conversation with a software supplier usually happens in steps. First there is the question of what the digital product passport entails and whether it affects your company. Many companies have already had that conversation. The step that more companies will take this year is the planning question: when does which part of the system need to be ready, and who is responsible for it. Software suppliers active in the steel sector follow the work plan of the European Commission and adjust their own development routes accordingly. This makes it a good time to ask how your supplier is tracking that development and what that means for your contract.

What comes up concretely this year

In practice, the conversation this year more often concerns the origin of data than the passport itself. A software supplier wants to know what data you already record about a batch of steel, in which system that happens, and whether that data is stored at product level or order level. This distinction determines how much work an integration with a future passport will cost. It also increasingly raises the question of who within your company will be responsible for keeping that data up to date, and whether that is a task that belongs to your current software or to a separate system. Those who want to prepare for this will find in the knowledge base with topics per situation an overview of which concepts belong to this and what they mean in practice.

What is not yet established

It is important to distinguish between what a supplier tells you this year about their own plans and what the regulation itself already prescribes. The first delegated act for iron and steel has not yet been published; the date on which the obligations come into force is therefore not yet fixed. A software supplier can already offer functionality that anticipates the passport, but that is a commercial choice of that supplier, not a legal obligation. For the official state of affairs and the text of the regulation, the published text itself remains the authoritative source, not the announcement of a software supplier.

What you can prepare now

Without anticipating obligations that are not yet established, it is worthwhile this year to take inventory of what data about your steel products already exists somewhere and in which systems. That is work that is useful anyway, even if the ultimate obligation turns out to be different from what is currently expected. With a few questions, you can yourself see where your company roughly standswithout that entailing an obligation. Those who want to know how such a passport will be created and what role a platform like ferropas.eu plays in it can read that on the page where the information for the passport comes from.

Does this remain the same topic all year?

Because the delegated act has not yet been published, the content of the conversation with your software supplier may shift during the year. Once a concrete timeline becomes known, the conversation will change again: from preparation to planning with a fixed date. For your own situation, and for the question of what agreements in a contract with a software supplier are sensible, a lawyer or the competent supervisory authority remains the appropriate contact point.

Do you want to conduct a good conversation with your software supplier this year yourself, without needing to be a legal expert right away? Take the free quick-scan or browse through the frequently asked questions about the digital product passport to see which topics are relevant for your company.

This article is general information and not legal advice.