When does the product passport become mandatory for steel?

The delegated act is planned for the end of 2026; after that, the ESPR guarantees at least 18 months of transition. Obligations therefore apply from mid-2028 at the earliest — the exact date and the final product scope are set by the final act.

Which products are affected?

The draft targets intermediates: at minimum hot-rolled coil, galvanised cold-rolled coil, wire rod, electrical sheet and stainless steel. Whether steel-rich end products will be included is currently being examined in the impact assessment.

We import steel from third countries — what's coming for us?

As the importer you carry the manufacturer's passport duties: passports for the delivered heats or batches (as proposed by the EU studies), the data duties and the backup copy with an independent service provider. Passenta structures batch data and evidence so you are disclosure-ready per delivery.

What does CBAM have to do with it?

CBAM already requires emissions data for steel imports into the EU — the same data that will later end up in the product passport. Captured once in a structured way, it serves both requirements without duplicate work.

We are a downstream processor (wire drawing, tubes, forging, foundry) — does this affect us?

As things stand, the direct duty only hits whoever places an intermediate in scope on the market — cold rollers and galvanisers with galvanised cold-rolled coil, for example, would be covered. Everyone else becomes their customers' data supplier: automotive, construction and machinery demand the values for their own evidence. Passenta makes you disclosure-ready in both roles.

Iron & steel industry solution

The product passport for iron & steel — for producers and importers.

Iron and steel are the first product group for which the EU is drafting an ecodesign act with a product passport. Passenta brings heat and mill-certificate data, carbon and recycled-content values into one verifiable product record per batch — before the obligation arrives.

Request trial access View pricing

EU data residency · no IT department required · ready in minutes

The key facts for your industry

What is established today from the official EU documents (Commission, JRC preparatory study, consultation) — honestly classified, without invented deadlines:

Steel is the first ESPR product group

Iron and steel get the first ecodesign act under the new ESPR. The public consultation closed on 12 August 2026; adoption is planned for the end of 2026.

Obligations from mid-2028 at the earliest

The ESPR guarantees at least 18 months of transition after the act enters into force. With adoption at the end of 2026, that means: obligations from mid-2028 at the earliest — the exact date is set by the final act.

Intermediate products in scope

The passport is planned for steel intermediates — at minimum hot-rolled coil, galvanised cold-rolled coil, wire rod, electrical sheet and stainless steel. Whoever places such products on the EU market would be obliged.

Importers carry the manufacturer duties

For steel from third countries, the passport duty sits with the EU importer — including the duty to keep a backup copy with an independent service provider (Art. 10(4) ESPR). Distributors must verify that a valid passport exists.

One passport per heat, not per catalogue article

The EU studies foresee the passport at batch level — with the heat number from the mill certificate (EN 10168) as identifier. Your mill already produces this data; it just needs to be structured.

Carbon, recycled content and substances

Planned data points: the carbon footprint with performance classes (aligned with ETS and CBAM data), the recycled content, and declarations on substances hindering recycling such as lead, copper and tin.

Status: August 2026. The delegated act has not yet been adopted — information summarised to the best of our knowledge from the official EU documents; no legal advice.

Producer or importer — what's coming for you

For producers

Steel and electric-arc mills, stainless producers, cold rollers and galvanisers: whoever places the intermediates in scope on the market will need their own passports — per heat or batch, as proposed by the EU studies.
Your mill-certificate, ETS and EPD data are the foundation: captured once in a structured way, they serve the product passport, CBAM requests and customer evidence at the same time.
Buyers in automotive, construction and machinery are already requesting this data — long before the obligation.

For importers & distributors

Importers of third-country steel take over the manufacturer's passport duties — for every product placed on the market, per delivered heat or batch as proposed by the EU studies.
That includes the backup copy with an independent service provider, so the passport stays available even if the manufacturer fails.
Distributors have a verification duty: before making products available, a valid, accessible passport must exist.

What Passenta takes off your plate

No IT projects, no consultant workshops: you work in a guided interface built for batches and evidence.

Batch passports instead of folder archives

One product record per heat or batch: mill certificates, inspection documents and origin data sit structured on the product — findable instead of filed away.

Carbon and recycled content credibly evidenced

Emission values and recycled content sit on the product with evidence and validity dates; the gap report shows what's missing before a customer or authority notices.

Signed and tamper-proof

Every published passport is cryptographically signed and versioned — publicly verifiable, tampering is detected.

QR code and GS1 Digital Link

Batch-level marking for labels, delivery notes or accompanying documents — including statistics on who opens the passport and when.

Involve suppliers easily

Scrap, alloy and precursor suppliers contribute via link — in all 24 official EU languages (English otherwise), without an account.

Answer customer requests in minutes

Disclosure packages for buyer questionnaires from automotive, construction and machinery instead of Excel battles — the same data serves CBAM and the product passport.

Frequently asked questions

When does the product passport become mandatory for steel?: The delegated act is planned for the end of 2026; after that, the ESPR guarantees at least 18 months of transition. Obligations therefore apply from mid-2028 at the earliest — the exact date and the final product scope are set by the final act.
Which products are affected?: The draft targets intermediates: at minimum hot-rolled coil, galvanised cold-rolled coil, wire rod, electrical sheet and stainless steel. Whether steel-rich end products will be included is currently being examined in the impact assessment.
We import steel from third countries — what's coming for us?: As the importer you carry the manufacturer's passport duties: passports for the delivered heats or batches (as proposed by the EU studies), the data duties and the backup copy with an independent service provider. Passenta structures batch data and evidence so you are disclosure-ready per delivery.
What does CBAM have to do with it?: CBAM already requires emissions data for steel imports into the EU — the same data that will later end up in the product passport. Captured once in a structured way, it serves both requirements without duplicate work.
We are a downstream processor (wire drawing, tubes, forging, foundry) — does this affect us?: As things stand, the direct duty only hits whoever places an intermediate in scope on the market — cold rollers and galvanisers with galvanised cold-rolled coil, for example, would be covered. Everyone else becomes their customers' data supplier: automotive, construction and machinery demand the values for their own evidence. Passenta makes you disclosure-ready in both roles.

Ready before the obligation arrives?

Build your data foundation now — request trial access or view the pricing.

Request trial access View pricing