A steel distributor typically does not need documents to compile a digital product passport themselves — that task lies with the manufacturer or importer. What a distributor does need is proof that the passport exists before the product is resold, and their own administration showing where the material came from and to whom it was delivered. That distinction is the detail most often overlooked in this role.
The regulation distinguishes roles in the chain, and a distributor has different obligations than a manufacturer or importer. Whereas the manufacturer or importer builds the passport substantively, the distributor checks whether it is present and accessible. You must be able to demonstrate that check, and for that you need documents — not to make the passport, but to show that you have fulfilled your role in the chain.
What role a distributor plays in the chain
The term 'distributor' refers to a party that trades steel products without manufacturing them or importing them from outside the EU. Think of a steel merchant that purchases profiles, plates or tubes from a producer and resells them to a processor or contractor. That position entails a lighter, but not a casual obligation: to ascertain whether the product is already provided with a passport and a QR code, and not having to produce that yourself. Who exactly qualifies as a manufacturer, importer or distributor, and what that means for your company, is something you are best informed about via the official text or a lawyer. In the knowledge base with explanations per role this distinction is elaborated further.
The documents typically at issue
Upon receipt of the material, the first document is the delivery documentation from the manufacturer or importer, containing a reference to the passport or the unique identification code. In addition, there is usually a packing slip or invoice that links the batch or lot number to the delivered quantity, so that a specific batch of steel remains traceable to the corresponding passport. Upon resale, your own delivery slip is added, in which you record to which customer which batch has been delivered and whether the QR code or the passport has been passed on. For cross-border delivery within the EU, the transport documentation may also be relevant, as it demonstrates which batch has passed through which link in the chain at which point in time.
None of these documents replaces the passport itself. They form the administrative layer around it: the proof that you as a distributor did not need to make the passport, but did need to check and pass it on. Who exactly needs to supply what varies per situation, and that is one of the points where a brief scan with a first indication can provide guidance.
Why keeping records is just as important as collecting them
The detail that most often applies to distributors is not the question of which documents exist, but how long and how accessible they are kept. A passport is consulted over a long period, sometimes by parties further down the chain that you have never met. If your own administration does not align with the identification code of the passport, traceability still becomes a problem, even though you did not make the passport yourself. Supervisors look at that alignment during inspections: is it demonstrable that the product already had a passport upon receipt, and is it demonstrable to whom it was subsequently delivered. How that supervision is arranged in practice is up to the competent supervisor in the Netherlands and the EU, and this article makes no prediction about it.
A second reason to keep documents in good order is the change of software suppliers or internal systems. If a delivery note exists only in an old system that is no longer in use, the link with the product passport is effectively broken, even though that link once existed. In the overview of where the data comes from it is explained how such a link is maintained, even if systems change.
What this means in practice
For a distributor, the task is therefore primarily organizational: ensuring that purchase documents, batch numbers and delivery notes consistently refer to each other, and that this link can still be reconstructed years later. This requires no legal knowledge, but rather a fixed procedure when receiving and delivering material. Anyone in doubt as to whether a specific delivery falls under these obligations is well advised to have this checked by a lawyer or the competent supervisory authority, since the precise implementation may differ per product group and per phase of the rollout.
Curious how this works out for your own situation? Take the free quick-scan or browse through the answers to questions that steel traders often ask us to see which documents belong to your role in the supply chain.