Iron and steel is a priority intermediate product group in the first ESPR working plan (COM(2025) 187, adopted 16 April 2025), with its delegated act indicatively scheduled for 2026, the earliest of any ESPR product group. As of July 2026 that act has not been adopted, so a steel passport today is preparatory, not a compliance obligation, but the data it will draw on (composition, recycled content, embodied carbon) is largely data steelmakers already produce for EPDs and CBAM.
This page reflects the rules as of 10 July 2026. Regulatory dates are dated and may change, confirm against the current instruments or with qualified advisers.
The Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781) is in force, but it does not itself require any product to carry a Digital Product Passport. Requirements arrive product group by product group through delegated acts, and the Commission's first working plan (COM(2025) 187, 16 April 2025) names the groups that go first: textiles, furniture, mattresses and tyres among final products, and iron & steel and aluminium as intermediate products.
Iron and steel carries the earliest indicative date in the plan, a delegated act indicatively in 2026, ahead of every other group. The Commission's Joint Research Centre is running the preparatory study for iron and steel products, and a draft proposal on steel DPP content went to stakeholder consultation in spring 2026.
As of July 2026, the delegated act has not been adopted. Until it is, there is no legal requirement for a steel product to carry a passport, and no adopted list of data fields. Once an act is adopted, ESPR delegated acts generally allow a transition period, typically at least 18 months, before requirements apply, which would put the first mandatory steel passports around 2028 at the earliest, though no date is fixed until the act is adopted.
The adopted rules will be whatever the delegated act says. But the JRC's preparatory work and the working plan's stated priorities point clearly at the categories of data an iron & steel passport is expected to carry:
All of this is expected content based on preparatory documents, not adopted law. The JRC draft is explicitly a consultation document and subject to change.
Iron and steel is one of only two intermediate product groups in the first working plan. That distinction matters: steel is rarely the final product a consumer scans. It becomes furniture frames, vehicle bodies, construction sections, white goods.
The practical consequence is that a steel producer's passport data is expected to flow downstream. When furniture, also in the first working plan, gets its own DPP requirements, a furniture maker will need material data from its steel supplier to populate its own passport. The same logic applies to any regulated downstream sector. A steelmaker that can hand structured, versioned product data to customers becomes the easy supplier to buy from; one that answers each request with a fresh PDF becomes the bottleneck in someone else's compliance chain.
This is why preparing steel product data now has value even before the delegated act lands: your customers' obligations generate demand for your data on their timetable, not yours.
Iron and steel producers selling into the EU are already inside a parallel carbon-data regime. The Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026: importers of iron and steel goods above the 50-tonne annual threshold must be authorised CBAM declarants, declare the embedded emissions in their imports, and surrender certificates priced against EU ETS allowances, with the first declaration due by 30 September 2027.
CBAM and the future steel DPP are separate instruments with separate legal bases, one is a border carbon price, the other a product information requirement. But they draw on overlapping data: per-tonne embedded emissions, production route, installation-level records. A producer that has built a reliable emissions-accounting pipeline for CBAM (or to supply CBAM data to EU importers) has already done much of the hardest data work a steel passport is expected to require. The sensible move is to treat them as one data pipeline with two outputs, not two projects.
Most European steelmakers already publish EPDs to EN 15804, and an EPD covers a large share of the environmental fields a steel DPP is expected to include, the carbon footprint above all, and often recycled content, though its explicit inclusion in EPDs today is voluntary.
What an EPD is not: a per-product, machine-readable, individually identifiable record. EPDs are typically declared at product-family level as static PDFs; a DPP under ESPR is expected to be batch- or item-level structured data behind a unique identifier and a data carrier (a QR code on or with the product), discoverable through the EU's DPP registry, which ESPR Article 13 required the Commission to set up by 19 July 2026. The gap between "we have EPDs" and "we can serve structured, identified, per-batch product data" is exactly the gap worth closing during the pre-adoption window.
To be clear about status: anything you publish today is a voluntary transparency passport, a genuinely useful thing for customers and downstream compliance, but not a legal compliance claim, because there are no adopted steel DPP rules yet.
The preparatory work that will not be wasted, whatever the final act says:
Passfolia tracks the iron & steel delegated act's status on the category page, adopted versus pending, with a public changelog and a verified-as-at date, so a passport built now has a compliance-ready structure: aligned to adopted rules where they exist, tracked where they don't.
No. The ESPR framework (Regulation (EU) 2024/1781) is in force, but passport obligations only apply once the iron & steel delegated act is adopted and its transition period runs out. As of July 2026 that act is not adopted; it is indicatively scheduled for 2026 in the first working plan (COM(2025) 187). Any steel passport published today is voluntary.
The working plan gives 2026 as the indicative adoption date for the delegated act, and ESPR delegated acts generally allow a transition of at least 18 months before requirements apply, so mandatory steel passports are plausibly around 2028, but no date is fixed until the act is adopted. Treat any firm year you read as an estimate.
EPDs are the single best head start; they cover the carbon footprint and much of the environmental data a steel DPP is expected to require. But an EPD is a family-level static document; a DPP is expected to be structured, machine-readable data per product or batch, behind a unique identifier and QR code. The work is converting what your EPDs already know into an identified, per-batch record.
They are separate instruments; CBAM (Regulation (EU) 2023/956) prices the embedded carbon of imports at the border from 1 January 2026, while the future DPP is a product information requirement under ESPR. But both need per-tonne embedded emissions and production-route data, so the emissions pipeline you build for one substantially serves the other.
Because steel is an intermediate product: downstream sectors in the same working plan, such as furniture, will need supplier material data to populate their own passports. Producers who can hand customers structured composition, recycled-content and carbon data become easier to buy from. It is a commercial advantage now and preparation for the delegated act later, but it is transparency, not compliance, until the rules are adopted.
The items with the longest lead time: per-heat/batch traceability linking mill certificates to products, verified recycled-content figures (pre- and post-consumer scrap, with the measurement basis documented), embodied-carbon data consistent with your EPDs and CBAM records, and substance/composition data from your own suppliers. Unique identifiers (GS1 Digital Link) can be layered on once the records exist.
Publish a passport today, free for your first three products, full schema, real QR codes.
Start free