Digital product passport for iron and steel: when does it apply?
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
Not yet. Iron and steel are the first group in the working plan under the ESPR, Regulation (EU) 2024/1781, with 2026 as provisional year of adoption. On 11 November 2026 EUR-Lex showed no such delegated act. It applies as a rule no earlier than 18 months after entry into force (Art. 4(4)); the duty follows from it (Art. 9(1)).
Art. 4(4), 9(1) and 18(5)(a) ESPR
Legal basis: steel as an intermediate product
Article 18(5)(a) ESPR names iron and steel first. The working plan COM(2025) 187 lists them as an intermediate product with 2026 as the provisional year. On its product passport page, the Commission gives the fourth quarter of 2026 as the expected date. That is an expectation, not a date in the law.
The plan describes what is special about intermediate products: a rule for steel also affects every final product made of steel. Two options are therefore being examined: setting information requirements only, or including selected final products with a high steel content. Neither has been decided. According to the plan, the ESPR measures are to complement the green steel label announced in the Clean Industrial Deal.
Timeline with status
| Step | Date | Status | Provision |
|---|---|---|---|
| ESPR in force | 18 July 2024 | binding | Art. 80 Regulation (EU) 2024/1781 |
| Harmonised standards for identifiers, data carriers, interfaces (in force) | 15 July 2026 | binding | Implementing Decision (EU) 2026/1736 |
| Commission’s digital product passport registry (deadline) | 19 July 2026 | binding | Art. 13(1) ESPR, Implementing Regulation (EU) 2026/1778 |
| Delegated act for iron and steel | 2026, according to the Commission Q4 2026 | indicative | COM(2025) 187; Commission |
| Passport duty for steel | as a rule no earlier than 18 months after the act enters into force | planned | Art. 4(4) ESPR |
Which data is fixed
None yet. For steel, the plan sees potential in climate change, energy consumption, water and air. Which information follows from that for the passport will only be in the act. The general list in Annex III ESPR includes product identifier, GTIN or equivalent identifier, commodity code, compliance documentation and details of the manufacturer and the importer, for importers with the EORI number.
What you can do today
- Decide at which level you hold data: per grade, per heat, per delivery. Art. 9(2)(d) ESPR allows model, batch or item level.
- Keep inspection certificates and compliance documents per batch retrievable.
- Ask your customers which information they expect for their final products.
- If you process steel into final products, watch whether the act includes final products.
- Watch the Official Journal. On 11 November 2026 no act had been published.
How ProofPass helps
The product passport module gives every product a permanent address and a QR code and keeps certificates with versions. The deadline tracker follows the status. Aluminium is the second intermediate product in the plan, see product passport for aluminium.
Further reading
- The product passport module: permanent address, QR code and documents per product
- The basics in the guide Digital product passport: deadlines and product groups
- Every date per product group in the deadline tracker
- All industries at a glance: product passport by industry
Frequently asked questions
Is the steel passport coming at the end of 2026?
According to the Commission’s product passport page, the act is expected in the fourth quarter of 2026. That would be its adoption, not the start of the duty. The duty follows as a rule no earlier than 18 months after entry into force (Art. 4(4) ESPR). On 11 November 2026 there was no act on EUR-Lex.
Does the steel passport affect distributors?
Under Art. 10(3) ESPR, dealers receive the data carrier or a link from the economic operator placing the product on the market. Further duties of other actors are set by the act.
Does the passport apply to steel from outside the EU?
The ESPR applies to products placed on the EU market, including imports. Under the ESPR, customs receive the unique registration identifier (Art. 15(1)).
With ProofPass
ProofPass does not provide a product passport under an ESPR act today, because there is none yet for this group. You get a permanent address per product, a QR code, a GS1 Digital Link address from your GTIN if you want one, and an archive of every document version. That is the groundwork a later passport needs. Which fields it requires is decided by the act alone.
The terms and legal notices are in German, and the German version is binding.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR), Official Journal (read on 11 November 2026)
- European Commission: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 of 16 April 2025 (read on 11 November 2026)
- European Commission: digital product passport for iron and steel
- Implementing Decision (EU) 2026/1736 (harmonised standards for digital product passports), OJ of 15 July 2026 (read on 11 November 2026)
- Implementing Regulation (EU) 2026/1778 (digital product passport registry), OJ of 17 July 2026
As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.