The short answer
If you import steel from outside the EU, for the future digital product passport you essentially need the same documents as a manufacturer within the EU: technical data on composition and properties, origin data, and data on who is responsible for what. The difference lies in one detail that most often goes wrong in imports: the manufacturer is outside the Union, yet the passport must still be traceable to him. This means that as an importer you must collect documents that are normally supplied by the manufacturer himself, and you must check them for completeness before the batch moves further down the chain.
The regulation distinguishes roles in the chain, and whoever places a product from outside the EU on the market may have a different position than a trader who resells batches already purchased within the EU. Which role applies to your business depends on the precise facts of your situation; that is something to discuss with a lawyer or the competent supervisory authority, not something that is determined in this article. However, it is possible to describe which documents are typically needed to be able to assess whether everything is complete.
The trade documents that already exist
With every import of steel there are already documents that record the origin and the route of the batch: the commercial invoice, the packing list, the certificate of origin and the import documents that belong with customs. These documents do not form the product passport itself, but they are the first layer by which a batch of steel can be traced to a shipment and a supplier. For the passport, they are mainly important because they form the bridge between what has actually arrived and what must technically be known about that batch.
The technical certificate: what matters most
The document that carries the most weight in iron and steel is the material certificate, in practice often called the 3.1 certificate after the EN 10204 standard. It contains the chemical composition, the mechanical properties and the heat number or charge by which a batch can be traced to the production unit it came from. For steel produced within the EU, this certificate is usually available in a trusted format. For imports from outside the EU, this is not always the case: the certificate may be drawn up in a different format, may have missing fields, or may not align one-to-one with the charge that was actually delivered.
This is the detail that plays the biggest role in this subject. If something is missing from the certificate, or if the link between certificate and physical batch does not match, this can often be solved with a phone call at a manufacturer within the EU. At a manufacturer outside the EU, the same gap can take considerably more time to repair, simply because the lines are longer. Anyone who arranges this check in advance prevents a batch from only appearing to lack substantiation when the passport is being compiled.
Conformity and manufacturer data
Where steel falls under product safety rules that already exist, such as rules for construction products, there is usually also a conformity or performance declaration that goes with it. This declaration is also a document that the manufacturer supplies, and which must be checked just as carefully on import for presence and whether it relates to the correct batch. In addition, it is important that the name and address of the manufacturer, and not just the intermediary, are recorded somewhere in the file. The regulation requires traceability to the person who made the product, even if that person is located outside the EU.
Your data as an importer
In addition to the documents about the product itself, your file must contain a fixed set of data about your own company: name, address and the information that identifies your company as a legal entity. This is not something you need to invent separately; it is the same basic information that is also requested for a business account. Read more about how a product passport is compiled in practice and which building blocks are involved in the knowledge base with explanations per topic.
How you can already see where the gaps are
Because the final obligation has not yet been determined, there is no need to have a complete file today. However, it is useful to know now which documents are available for your purchased batches and which are missing, especially when importing from outside the EU where reshipment takes more time. With a few questions you can see where your file currently stands, and on the page about how information is created you can read how we process supplied documents into a product passport. Answers to frequently asked questions about roles and documents are collected on the page with frequently asked questions.
Do you want to know how your own import flows compare to what is already known about the product passport? Take the free quick-scan or browse through the topics in the knowledge base; both will give you a concrete picture within half an hour, without having to commit to anything immediately.