Who is the 'supplier' when it comes to the digital product passport for iron and steel? The regulation places that role with the party that first places a product on the market within the European Union, or that sells it under its own name. In practice, that is usually the manufacturer, and in the case of imports from outside the EU, the importer. Anyone who merely resells steel, stores it or processes it into another product is generally not a supplier in this sense — although that depends on the precise role a company plays in the chain.
This distinction is not merely a matter of terminology. The obligation to compile and maintain the passport lies with the supplier, not automatically with the party that supplies you the steel. A steel merchant that purchases material from a European producer and resells it is usually not a supplier; a company that itself imports material from outside the EU may be. For those purchasing, it is therefore useful to know where a supplier stands precisely in the chain.
What the regulation means by 'supplier'
The Ecodesign Regulation for Sustainable Products (ESPR) works with a number of fixed roles in the chain: the manufacturer, the importer, the authorised representative and the distributor. The heaviest obligations are linked to the manufacturer and the importer, including having the product passport compiled. The distributor — often the party that resells material without manufacturing or importing it itself — has a lighter role, focused on checking whether the passport is present, not on creating it.
Whether a company is a manufacturer, importer or distributor depends on what it actually does with the product, not on the name the company gives itself. A trader that places material on the market under its own brand or its own item number may thereby come closer to the role of manufacturer than it expects. That is precisely the detail that in practice gives rise to most questions.
Manufacturer, importer and the role of the trader
For iron and steel, the chain often runs through multiple links: producer, importer, steel merchant, processor, and ultimately the installer or contractor that incorporates or assembles the material. Not every link receives the same obligation. The regulation is designed so that the passport is compiled once, by the party that has the most insight into the origin and composition of the material, and then travels with the rest of the chain.
This means that an installation company or construction company that purchases steel from a Dutch merchant usually does not need to compile its own passport — the passport should then already be with the delivered material. Anyone who themselves imports material, for example directly from a producer outside the EU, may come into the role of importer and thereby come closer to the obligation. the concepts of manufacturer, importer and distributor listed indicates for each role which obligations are associated with it.
Why this matters for you as a steel purchaser
For companies that process or resell steel, the first practical question is not 'must I create my own passport myself', but 'what role do I have in this specific chain'. That can differ per product and per supplier: the same company can be a distributor for one semi-finished product and an importer for another, depending on where the material comes from and under what name it is resold.
Because that question plays out differently in each situation, it is not an issue that can be answered with a general rule of thumb. With ask a few questions to map out your own situation provides a first indication of where a company stands in the chain, without any judgment being attached to a company's own legal position.
What if you process and resell yourself
A separate case is the company that purchases steel, processes it — for example by sawing, welding or coating — and resells it as a new product. Whether such processing means that a company is regarded as a manufacturer of a new product is a question that the regulation itself answers based on the nature of the processing, not on how a company describes itself. This is precisely the kind of question where a lawyer or the competent supervisory authority can provide clarification for the specific situation; a general article cannot replace that.
What is not yet established
The obligation to provide a digital product passport only applies after the European Commission has published a delegated act for iron and steel. According to the ESPR work plan, this is expected around 2026, with a transition period of approximately eighteen months thereafter. Until that publication, the exact implementation date is not fixed, and details about the role of 'economic operator' for this product group may be further specified. As soon as the text is published, it will be updated here.
For the current status and the location in the official text, a frequently asked questions overview about the digital product passport a good starting point. Those who want to see how ferropas.eu processes an economic operator's data into a digital product passport will find that on an explanation of where the information comes from.
Are you curious about what role your company plays in the iron and steel supply chain? The free quick-scan provides a first indication in a few minutes, and the knowledge base sets out the concepts for each situation.