A steel digital product passport (DPP) is not required yet. No ESPR delegated act for iron and steel has been adopted or published in draft. Adoption is indicated for (expected); the act would normally apply 18+ months after entry into force.
One binding rule already asks for passport-type data: covered steel imports need a mill test certificate (MTC) showing the heat number and melt-and-pour country; other documents can fill gaps. New to passports? Read what a digital product passport is.
It is written for mills, importers, stockholders, service centres and fabricators selling into the EU.
What is a steel digital product passport?
A steel digital product passport is a digital record for an iron or steel product, reached through a data carrier. JRC draft proposals identify it by heat number and cover identity, origin, substance-of-concern chemistry, carbon footprint and recycled content. It becomes mandatory only when the ESPR (EU Ecodesign for Sustainable Products Regulation) iron and steel delegated act applies.
What is decided and what is still a proposal?
Read this table before you plan any steel digital product passport work. Build on rows marked law; prepare for rows marked analysis without hard-coding them.
| Item | Status | Date | What you do |
|---|---|---|---|
| Iron and steel delegated act | Expected; draft not yet out for feedback | Adoption indicated for (expected) | Subscribe to initiative 17672 on Have Your Say; answer with the checklist below |
| Application of that act | Expected | Normally 18+ months after entry into force (exceptions possible), so not before 2028 | Pilot one product family before it applies |
| Call for evidence and public consultation | Closed | Read the published feedback; note your customers' positions | |
| JRC draft studies | Analysis, not Commission position | March–April 2026 | Keep every field configurable |
| Melt-and-pour evidence, Regulations (EU) 2026/1384 and 2026/1963 | Law (trade defence, not ESPR) | MTC required since ; standalone non-MTC evidence until | Check both fields on every MTC before the goods ship |
| CBAM, Regulation (EU) 2023/956, amended by 2025/2083 | Law | First declaration for 2026 imports by | Above 50 t a year: declarant status; ask mills for embedded emissions |
| CBAM downstream extension, COM(2025) 989 | Proposal, in negotiation | Proposed start (expected) | Check your CN codes against its list of about 180 |
| EN 10204, inspection documents | 2004 edition current | Revision started June 2026 | Ask mills which format follows |
Only two rows bind steel data today, melt and pour and CBAM, and neither is a steel digital product passport rule. Your preparation pays off there first.
Feedback checklist (owner: compliance lead). When the draft opens for comment, answer five points:
- Heat-number format and uniqueness: can every plant meet it? (heat-number audit)
- Scope option A–D: which works for you and your customers? (role section)
- Footprint level: per heat or per product number? (carbon bridge)
- Which fields must stay non-public? (data inventory)
- Inheritance: what must a processor copy, and what declare anew? (role section)
Which role do you play in the steel chain?
Your steel digital product passport duties will follow your ESPR role, not your job title. Classify each product flow, not each company: one stockholder can be a distributor for one flow and a manufacturer for another.
| Your flow | Likely ESPR role | Anchor | First action |
|---|---|---|---|
| EU mill | Manufacturer | Art. 2(42), 27 | Heat-number audit |
| Non-EU mill | Manufacturer; its EU importer must ensure the passport exists | Art. 27, 29 | Heat number and melt-and-pour country on every MTC |
| EU importer or trader | Importer: passport and back-up must exist | Art. 29(2)(c) | MTC check; CBAM status |
| Stockholder reselling unchanged | Distributor: check the passport link before resale | Art. 30(2)(a) | Keep the heat number on every piece |
| Stockholder selling under its own name or trademark | Manufacturer | Art. 34(a) | Decide if your name is worth the duties |
| Service centre: slitting, cut-to-length, coating | Manufacturer if it sells under its own name; otherwise only if it modifies in a way that affects compliance | Art. 2(42), 34(b) | Parent-child heat-number rule |
| Fabricator of final products | Depends on scope option A–D (FAQ below; working plan) | Not set | Record steel share and source heats |
Inheritance (JRC proposal). A processor selling under its own name inherits grade, heat number, recycled content and footprint, and declares surface treatment, dimensions and new substances of concern. The act would set the linking rules.
What data will a steel digital product passport likely need, and where does it live today?
The JRC's draft field list maps closely onto a mill certificate. Fill it in for one product family and you have a steel digital product passport gap analysis. Status, level and access are JRC proposals (tables 15–16 of its draft); "—" means none is set.
| Field (JRC proposal) | Status | Level | Access | Where it sits today | Owner |
|---|---|---|---|---|---|
| Heat number | Mandatory | Batch | Public | Melt shop, MTC | Quality |
| Product number and steel grade (e.g. EN 10027-2 number) | Proposed | Model | Public | ERP, MTC | Quality |
| CN/TARIC code | Proposed | Model | Public | Customs files | Customs |
| Operator and facility identifiers; technology route | Proposed | Operator | Public (contacts: see below) | ERP master data, plant records | Compliance |
| Origin, melt and pour, manufacturing date | Proposed | Batch | Public | MTC | Quality |
| Chemistry for substances of concern | Mandatory where relevant | Batch | Not settled: public (Table 15) or restricted (Table 16) | Lab, MTC | Lab |
| Other MTC parameters | Voluntary; a few identification and recyclability properties mandatory | Batch or item | Legitimate interest | MTC | Quality |
| Footprint, declared value | Proposed | Batch or model | Public | EPD, CBAM data | Environment |
| Footprint calculation inputs | Proposed | — | Legitimate interest | Energy, ETS/CBAM monitoring | Energy |
| Recycled content, % | Proposed | Batch or model | Public | Charge sheets | Melt shop |
| Pre-/post-consumer split | Proposed | — | Legitimate interest | Scrap purchases | Scrap buying |
| Purchase order | Proposed | Batch | Legitimate interest | ERP | Order desk |
| Links to other EU law (e.g. CBAM report ID) | Voluntary | Varies | Legitimate interest | Compliance files | Compliance |
| Footprint and recycled-content certificates | Proposed | — | Authority only | Verifier reports | Compliance |
When you copy it, add two columns, "Have it? (Y/N/partial)" and "Gap closed by (date)", and it becomes your tracker. The cross-sector method is step 2 of DPP implementation.
Contact details are the exception: ESPR Articles 27(6)(a) and 29(3)(a) make manufacturer and importer contacts public, whatever the JRC table says.
Most fields exist in-house already; the JRC places the traceability risk at company hand-overs. Your gap is usually exchange, not data.
Decide what you will not publish. The declared footprint is proposed as public; its inputs are not, as they can reveal energy use and costs. Your steel digital product passport refusal list: footprint inputs, chemistry beyond substances of concern, purchase orders, sourcing.
How do you make your heat numbers passport-ready?
The JRC proposes the heat number as the mandatory batch-level identifier of a steel digital product passport, with a coil serial only where customers already require one. The melt-and-pour rule already demands it on every import MTC.
ESPR Article 27(5) already requires a type, batch or serial number or other element allowing identification; the steel act will decide which level the passport uses (Article 9(2)(d)).
Heat-number audit, per plant (owner: quality). The JRC found steel identifiers are local, number ranges roll over or get reused, and no GS1-based scheme runs across the chain. Check:
- Can a heat number repeat after a rollover or reuse of a range?
- Does it carry a mill or plant code?
- Does it carry the year?
- Is it written identically in the melt shop system, lab, ERP, MTC and product tag, leading zeros included?
- Does it stay on every piece after cutting, slitting and bundling?
- If you plan to use GS1: is it at most 20 characters from the GS1 character set, so it fits AI (10)?
Fix this before a steel digital product passport depends on it. If 1 is yes and 2–3 are no, a plant-and-year prefix makes numbers unique without touching the melt shop counter.
The optional GS1 route. With GS1, a heat number travels as AI (10) batch/lot, always with a GTIN, and a coil number as AI (21) serial. In a GS1 Digital Link that reads https://id.example.com/01/09506000134352/10/P2H26A0451.
The act has chosen no identifier scheme yet, and GTINs come from a GS1 member organisation licence.
How do CBAM numbers feed the passport carbon footprint?
Only as a starting point. Under CBAM Article 7(1) and Annex II, iron and steel goods count direct emissions only, including those embedded in relevant precursors. Purchased electricity and upstream inputs outside the precursor boundary are missing; a cradle-to-gate footprint includes them.
The JRC envisages the possibility of starting the steel digital product passport footprint from EU ETS and CBAM values and adding the missing contributors, with a method meant to work with EN 15804 environmental product declarations (EPDs).
Carbon bridge worksheet:
| Line | In the CBAM value? | In cradle-to-gate? | Data source | Owner |
|---|---|---|---|---|
| Direct emissions of your processes | Yes | Yes | ETS/CBAM monitoring | Environment |
| Relevant precursors bought in | Yes, for complex goods | Yes | Supplier CBAM data | Purchasing |
| Purchased electricity | No | Yes | Meters, supply contract | Energy |
| Upstream materials outside the precursor boundary | No | Yes | Supplier footprints, EPDs | Purchasing |
| Inbound transport | No | Yes | Logistics records | Logistics |
| Pre-consumer scrap | Zero today; would count under the COM(2025) 989 proposal | Set by the method | Scrap records | Scrap buying |
Check the CBAM precursor list for your production route before you count a line twice.
Per product number or per heat? The JRC proposes footprint declarations at batch or model level. An EPD gives a model value; a heat value needs energy and charge data per heat. Decide which level your steel digital product passport footprint can support.
Classes. The JRC proposes footprint classes A (best) to E (worst) per representative product, with A and B together covering at least 30% of production volume. Place your products against the draft class limits in its April slides now.
Low-carbon steel. The act is meant to define it for the Industrial Accelerator Act proposal (public procurement and support), and CPR acts for construction products. Selling into either? Watch both definitions.
What should you record per heat for recycled content and substances of concern?
These two fields decide whether a steel digital product passport claim survives an audit. The JRC's recycled-content declaration builds on ISO 14021 and splits pre- from post-consumer material. Your chain-of-custody model sets how fine the claim can be, self-declared or third-party verified:
| Chain-of-custody model | Finest claim it supports |
|---|---|
| Controlled blending | Heat (batch) |
| Mass balance, order level | Order |
| Mass balance, site-level rolling average | Site and period |
Pick one model per site, write down its rules and who signs, and start recording pre- and post-consumer scrap per heat from charge sheets now.
Substances of concern. The JRC's "reduced option" sets lead at 0.1% as a substance of concern, and copper at 0.05% and tin at 0.01% as substances hindering recycling, calculated on the whole intermediate product. An "extended option" adds identified hazardous substances. Both are proposals.
- Check that your lab and MTC report Pb, Cu and Sn finer than these thresholds. A tin value printed as "0.0" cannot show whether a heat is above 0.01%.
- Record coatings and surface treatments per batch. Under the JRC proposal, a coater that sells the coated product under its own name declares any new substance of concern in its own passport.
What should you ask your mill for?
Stockholders, service centres and importers can fill a steel digital product passport inventory only with what mills send. Most of this letter already serves the melt-and-pour rule and CBAM.
Subject: Steel data for EU compliance – request to [mill]
From [date], please send for every delivery to [company]:
1. Mill test certificate, EN 10204 type 3.1, per heat, showing
- the heat number, exactly as marked on the product
- the country of melt and pour
- the country of origin and the manufacturing date
- full chemical analysis, including Pb, Cu and Sn, with reporting limits
2. The same certificate as a machine-readable file (XML, JSON or CSV)
next to the PDF.
3. For CBAM: installation name and identifier, and the specific
embedded emissions of the goods delivered, with the reporting period.
4. Recycled content in % per heat or product number, the pre-/post-
consumer split, your chain-of-custody model, and any third-party
verification.
5. The reference of any EPD (EN 15804) and the products it covers.
6. Your heat-number format, and whether a number can ever repeat.
Items 1-2 with each delivery; 3-5 per reporting period; 6 once.
If you cannot supply an item, tell us by [date] which one and when.
Contact: [name, function, email]If a mill cannot deliver melt and pour:
- Gaps in the MTC. Invoices, delivery notes and similar documents may supply a missing heat number or country, but customs then run documentary checks that can delay access to the tariff rate.
- No MTC at all. Standalone documents count only during the transition window; after it, an import without an MTC has no accepted evidence and is rejected.
- Contract and volume. Make the data a contract term; move volume to mills that deliver. Non-EU mills can start with our guide for non-EU manufacturers.
Walkthrough: a hypothetical service centre in Ostrava
Take a hypothetical service centre in Ostrava, Czechia. It buys 3,500 t of hot-rolled coil a month (1,500 t from an EU mill, 2,000 t from two non-EU mills) and slits about 160 master coils into roughly 1,100 strips for racking and automotive customers.
Its steel digital product passport preparation runs in six steps:
- Import MTC check (customs coordinator). October's imports arrive with 41 MTCs. One lacks the melt-and-pour country, so the declaration leans on the invoice and delivery note, and customs open documentary checks.
- Parent-child log (production planner). Each strip ID is the coil ID plus a cut number; the heat number is copied, never retyped. A 22 t coil from heat P2H26A0451 becomes seven strips carrying that heat.
- Data inventory (quality manager). The table above, for racking strip. Recycled content and footprint are missing for both non-EU mills.
- CBAM (customs and finance). About 24,000 t of imports a year is far above 50 t, so the company needs authorised declarant status and asks both non-EU mills for specific embedded emissions.
- Supplier letter (purchasing). Sent to all three mills, with a reply date.
- Pilot (sales and IT). One racking customer: a test label with a GTIN from the company's GS1 licence and the heat number as batch/lot, scanned at goods-in.
Counterfactual 1: an MTC without the heat number. It falls short of the implementing regulation, so the import leans on complementary documents and documentary checks; at a 50% out-of-quota duty, delay costs money. That route outlives the transition window; only the no-MTC route ends.
Counterfactual 2: one strip with the wrong heat number. Nothing fails at the slitter. The strip inherits another heat's carbon and recycled-content claims, so the customer's steel digital product passport data describes the wrong steel until an audit traces it to a coil that never held that heat.
Edge cases: what if your flow does not fit?
Mixed heats in one bundle. Label each piece or list every heat on the bundle. A steel digital product passport identified per heat cannot point to an average.
EU trader importing from a third country. Importer duties apply (Article 29). CBAM's 50 t threshold covers the total net mass of all iron and steel, aluminium, fertiliser and cement goods per importer and calendar year; once exceeded, obligations cover everything imported that year.
Construction steel. It may also fall under the Construction Products Regulation. See GS1 2D codes in construction.
Ferroalloys and scrap. CBAM Annex I excludes ferro-silicon, most other ferroalloys and ferrous scrap (CN 7204); ferro-manganese, ferro-chromium and ferro-nickel are in, direct emissions only. None is a JRC representative product. Check your CN code against Annex I; keep chemistry and origin per lot.
Is the steel digital product passport one more report or the end of PDF certificates?
Three regimes now ask for overlapping facts about the same steel. Melt and pour wants heat number and country on the MTC; CBAM wants embedded emissions; a steel digital product passport would add footprint, recycled content and substances of concern to the same heat number.
The weak link is the certificate. The implementing regulation calls the MTC "neither a harmonised document nor specifically designed" for melt and pour.
The JRC found that MTCs travel mostly as PDFs or non-standardised formats, with no widely adopted data model, and calls a standard digital MTC format a key objective.
Decision: keep one structured certificate record per heat (XML or JSON next to the PDF; item 2 of the mill letter) and feed customs, CBAM and the steel digital product passport from it. Owner: quality plus IT.
Melt-and-pour data also gains weight: from the Commission takes it into account when distributing tariff quotas. Once the act applies, passports also meet the EU registry and customs checks.
What should you do in the next 90 days?
None of this waits for the act that will define the steel digital product passport, and most of it pays off first under the melt-and-pour rule and CBAM.
| Days | Action | Owner |
|---|---|---|
| 1–30 | Role map per product flow | Compliance lead |
| 1–30 | Check every import MTC since the rule started; set a fallback-document process | Customs |
| 1–30 | Heat-number audit | Quality |
| 1–30 | Watch list: subscribe to the draft act on Have Your Say; adoption, entry into force plus 18 months, CBAM deadlines, CPR acts | Compliance |
| 31–60 | Data inventory and access tiers for one product family | Quality and IT |
| 31–60 | Supplier letter to every mill | Purchasing |
| 31–60 | Parent-child rule for slitting, cut-to-length and coating | Production |
| 31–60 | Draft answers to the five feedback points | Compliance lead |
| 61–90 | Carbon bridge worksheet; per-heat or per-product decision | Environment |
| 61–90 | Chain-of-custody model; scrap split per heat | Melt shop or purchasing |
| 61–90 | Pilot: one product family, one customer | Sales and IT |
By day 90 you have a steel digital product passport pilot built on data you already need for customs and CBAM. Make your test code with the free GS1 Digital Link QR generator: no signup, and it runs in your browser. Passmith also has a free plan.
Further reading: ESPR working plan · DPP implementation in eight steps · DPP for non-EU manufacturers · DPP at EU customs
Frequently asked questions
Is a steel digital product passport mandatory yet?
Will the steel passport be per heat or per coil?
Does my CBAM figure count as the passport carbon footprint?
Who creates the passport when a service centre slits a coil?
Do fabricators of steel products need one?
What does the melt-and-pour rule have to do with the passport?
Is a QR code required on steel?
Sources
- European Commission — The Digital Product Passport (DPP) for Iron and Steel — 2026-10-07
- European Commission, Have Your Say — Ecodesign requirements for iron and steel products (initiative 17672), incl. call for evidence Ares(2026)5076198 — 2026-10-07
- Regulation (EU) 2024/1781 (ESPR), Articles 2, 4, 9, 27, 29, 30, 34 and Annex III — EUR-Lex — 2026-10-07
- Commission Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports (incl. EN 18220, data carriers) — EUR-Lex — 2026-10-07
- COM(2025) 187 final — Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 — EUR-Lex — 2026-10-07
- JRC — Study on DPP content for iron and steel products under ESPR (draft, March 2026, not a Commission position) — 2026-10-07
- JRC — Second stakeholder consultation, ESPR iron and steel draft preparatory study (slides, 13 April 2026) — 2026-10-07
- Regulation (EU) 2026/1384 on the negative trade-related effects of global overcapacity on the Union steel market — EUR-Lex — 2026-10-07
- Commission Implementing Regulation (EU) 2026/1963 on evidence of the country of 'melt and pour' — EUR-Lex — 2026-10-07
- Regulation (EU) 2023/956 (CBAM), Article 7 and Annexes I, II and IV — EUR-Lex — 2026-10-07
- Regulation (EU) 2025/2083 amending the CBAM Regulation (simplification) — EUR-Lex — 2026-10-07
- Proposal COM(2025) 989 final extending CBAM to downstream goods — EUR-Lex — 2026-10-07
- European Parliament Legislative Observatory — procedure 2025/0419(COD) — 2026-10-07
- DIN (German member of CEN) — Project DIN EN 10204 rev, Metallic products: types of inspection documents, CEN/TC 459/SC 12/WG 4 — 2026-10-07
- GS1 — Application Identifiers reference — 2026-10-07
