As a steel manufacturer, preparing for the digital product passport primarily involves documents that you presumably already have: the material certificate, test reports on chemical composition and mechanical properties, the heat or batch numbers that make it possible to trace a product back to the production batch, and the existing declarations of conformity that are already mandatory under product safety rules. The passport does not fundamentally add new measurements to these, but does require that this data be made available digitally, in structured form, and findable per product.
What is still not fixed is the precise list of mandatory data fields. This will result from a delegated act that the European Commission still has to publish for iron and steel; the work plan mentions 2026 as a target date, with obligations that come into force at a later date. Until that text is available, you can already map out which documents you produce as a manufacturer and where they are stored — that work is never wasted, regardless of the precise end date.
The certificate that already exists becomes the heart of the passport
In iron and steel, one document plays a larger role than in many other products: the material certificate according to EN 10204. That certificate already exists in various forms, from a simple declaration of conformity to a certificate with independently verified test results, and it has been the way for decades in which a manufacturer demonstrates that a batch of steel meets the agreed specification. The digital product passport builds on that practice: the data that now go along with each shipment on paper or as a separate pdf file must in future be traceable via the QR code attached to the product.
This makes the heat or batch number a detail that weighs more heavily in this context than in other roles in the chain. A distributor or importer processes certificates that already exist; a manufacturer is the party that draws up the certificate for the first time and is therefore responsible for the link between the physical product and the correct data. An error in that link affects not only your own administration, but everyone further down the chain who relies on your data. In the knowledge base you will find a detailed explanation for each concept, including what the regulation precisely means by a supply chain actor and what data belongs with it.
What already falls under product safety, and what is added
Many of the documents needed for the passport already exist from other legislation. CE marking, the declaration of conformity for construction products, and requirements for technical documentation are not new obligations — the digital product passport does not change what you must be able to demonstrate, but rather how and where that information must be found. Supervisory authorities already look at traceability and documentation under existing product safety rules; the passport adds a digital, uniformly findable layer to that, linked to a QR data carrier on the product itself.
This means that a manufacturer whose own quality documentation is already in order has a head start with the passport. It does not mean that there is no additional work involved: the data must be in a form that is machine-readable and available for ten years, and that often requires different storage than an archive of separate pdf files.
What you can do now
Without knowing the definitive data fields yet, it is already worthwhile to conduct an inventory: which certificates do you draw up per product line, how are they currently stored, and can they be linked to a specific batch number or only to a product category. This inventory is the starting point for any conversation with a software supplier about the digital product passport, and it requires no legal expertise — only an overview of your own administration. With the product scan you get in a few questions a first indication of how far your current documentation already meets what the digital product passport will require.
What is not yet established
The exact list of mandatory documents and data fields for iron and steel has not yet been published. Until the delegated act is in place, any list that goes further than the existing product safety documentation is an assumption, not an obligation. On this page you can read where our information comes from and how we keep it up to date once the official text appears. For your own company's situation, a lawyer or the competent supervisory authority remains the appropriate party to consult.
If you have questions that go beyond this overview, you may find an answer in the collection of questions that other manufacturers ask us possibly already an answer. If you first want to know where your company stands concretely, do the free quick-scan or browse through the topics in the knowledge base.