For iron and steel, there are no concrete changes expected in the practice of your business this year, but there is something important on paper: the European Commission is working on the first delegated act that specifically concerns iron and steel. This is the document in which it will be truly established which data must be included in the digital product passport, for which products exactly, and from which moment onwards. Until that act is in place, the implementation date remains an expectation and not an established fact.
For those to whom it matters: everyone who produces, imports or processes iron and steel and can at any time be considered a supplier within the meaning of the regulation. For steel traders and metal processors who mainly purchase from others, this is primarily a time to follow developments, not to respond now. Those who produce or import themselves would do well to keep an eye on the planning, because the time between publication of the act and the moment when obligations take effect is relatively short.
What exactly is a delegated act
The regulation that makes the digital product passport possible, the ESPR, is a framework. It sets out the main lines: that a passport will be created, who is responsible for it, and what rights supervisory authorities and purchasers receive. The details for each product group, including iron and steel, are implemented through separate delegated acts. Only in that act is it specified which data are mandatory, which standards apply and what the passport will look like in concrete terms for this product group. Without that act, there is a law that says that a passport will be created, but not yet how.
The Commission's work plan for the period 2025-2030 lists iron and steel as one of the product groups for which a first delegated act is being prepared, with 2026 as the year in which publication is expected. Thereafter, a period of eighteen months usually applies before the obligations actually take effect. This means that a publication in 2026 could lead to obligations sometime in 2028, which aligns with the expectation already mentioned on this site for some time. Important to remember: this is a plan, not a commitment. Work plans change, and the final text may differ in some respects from what is currently being prepared.
What you can do this year
Even without a final text, it can be useful to map out now which products your company brings to the market, which roles each party in the chain plays and which data on origin, composition and processing are already available. This work does not need to wait for the delegated act, because the basic data that a passport will need later do not fundamentally differ from the data that are already recorded now for other purposes, such as in purchase contracts or quality certificates. If you bring structure to this now, you won't have to do it in a short timeframe later.
It is also the time to check whether your own software supplier is already thinking about how data will have to be submitted in a standardised passport in future. This conversation can already be held now, even though the exact dataset is not yet fixed. In the knowledge base sorted by topic you will find an overview of the concepts and obligations known so far, with a direct reference to the official text on EUR-Lex.
How to follow this for your own situation
Because the date and precise content are not yet established, the risk of wrong preparation is mainly that people set things in stone too early based on a text that can still change, or conversely start too late because 2028 seems far away. A middle way is: map out your own situation now, and only take concrete steps once the delegated act has been published. With a few questions you can see where your company stands now gives an initial indication, without there being any obligation attached to it.
For those who want to know how this information is compiled and where the planning data comes from, the page how we compile the information which sources are followed and how often they are checked. Questions that frequently come up about timing and applicability are bundled in the answers to frequently asked questions.
Whether the digital product passport applies to your specific products and role in the supply chain, and exactly when, is a question that can only be answered with certainty once the delegated act is in place. For your own situation, a lawyer or the competent supervisory authority remains the appropriate point of contact. If you want to keep track of what is changing in the meantime, feel free to take the free quick-scan or go through the topics in the knowledge bank.