When you purchase raw steel and process it into a different product, for example by welding, bending, galvanizing or combining it with other materials, the basic list usually consists of your supplier's material certificate with the chemical composition and mechanical properties, the origin data of the raw material, your own record of the processing carried out, any environmental or CO2 data insofar as already known, and the unique identification by which the end product can be traced back to the batch of steel used.
The detail that is most relevant in this situation is whether your processing is so substantial that under the regulation you qualify as a supplier of a new product rather than as a link in the chain that passes on the existing passport. If that is the case, it is not sufficient merely to add a note to your supplier's passport; in practice, you compile your own complete dataset. If the processing is more limited, the existing list with additions may be sufficient. Which of the two situations applies is not determined in general terms and depends on the facts of your case; the regulation itself and the competent authority provide clarification on this, not this article.
Which documents are standard across situations
In almost every processing situation you will see the same core elements recurring. Your supplier's certificate, often referred to as a 3.1 or 3.2 certificate, forms the basis for the chemical and mechanical properties of the raw material. In addition, there is the origin of that batch of steel, your own process data on what happened to the material, and where available the environmental data associated with both the production of the raw steel and your own processing step. The unique identification code closes the loop: with it, the end product can be traced back to the batch from which it was made. Which documents are precisely needed in your case and how they relate to your role in the chain will vary from situation to situation; the knowledge base with topics selected for each situation sets the variants side by side.
Why the extent of processing is decisive
The regulation distinguishes between a party that resells a product unchanged and a party that makes a different product from it. In the case of substantial processing, for example when steel is combined with other materials to form a composite component, it is clear that a new product is created with its own passport. In the case of lighter processing, such as cutting to size without material change of properties, the original dataset may have already done much of the work. This distinction thus determines not only how many documents you collect, but also who is formally responsible for their accuracy. A first indication of where your situation falls in that distribution is provided by a few questions that show where you roughly stand.
What if the underlying documents are missing
In practice, it happens that a supplier of raw steel does not supply all the data you need to complete your own dataset. This is something to arrange in advance, for example in the purchasing terms or supply contract, and not something to resolve afterwards when the passport should already have been ready. A missing item from a supplier directly affects your own ability to compile the passport completely and correctly.
How you organize this without it becoming a project in itself
For many SMEs, the practical question is not which documents theoretically exist, but how to collect, retain and link them to the QR code that unlocks the passport. Ferropas.eu compiles the passport based on the data you and your supplier provide, hosts the file for the required period and delivers the data carrier; an overview of where that information comes from exactly shows how that process fits together.
The exact date on which these obligations take effect has not yet been established. The European Commission's work plan provides for a first delegated act in 2026, with obligations that will then have a lead time; as soon as that act is published, this will be updated here. To assess your own situation, in particular the question of whether your processing counts as the creation of a new product, it is advisable to consult the official text or involve a lawyer or the competent supervisory authority.
Do you want a quick indication of what is relevant for your business without having to open a file for it? Do the free quick-scan or browse through the topics in the collection of frequently asked questions to see which situation comes closest to yours.