Components and intermediate products fall within the ESPR’s scope, but each needs its own Digital Product Passport only when its product group’s delegated act says so. No such act had been adopted by 18 October 2026. Iron and steel are the first intermediate products in line, and the Commission plans that act for the fourth quarter of 2026.
Are components within the ESPR’s scope?
Yes. Any physical goods placed on the market or put into service, “including components and intermediate products”, says Article 1(2) of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. Article 2 defines a component as a product meant to be built into another product. An intermediate product needs further manufacturing, such as mixing, coating or assembling, before end-users can use it.
Scope is not a duty: under Article 9(1), a product needs a passport only where its group’s delegated act requires one.
Are business-to-business sales covered?
Yes. Under Article 2(39) and (40), placing on the market is the first commercial supply of a product on the EU market, to a household or a factory alike.
One reading follows, though no official text states it. A part built into a finished product outside the EU is not itself placed on the EU market; the finished product is. A part shipped in on its own is placed on the market by its importer.
Steel goes first among intermediate products
The Commission’s ecodesign working plan for 2025-2030 gives iron and steel an indicative adoption year of 2026, and aluminium 2027. It warns that regulating them could affect all final products made from them, and keeps open an option of information requirements only. One option in the steel call for evidence is passport requirements “for all actors involved in the supply chain”. No draft has been published. The ESPR priority product groups answer lists the rest.
Example: a forge outside the EU sells steel bars to an EU machine manufacturer. Neither the bars nor the machine needs a passport today. If the steel act requires a passport, the forge would have to provide one for the bars, and the EU importer would check it. The machine waits for an act of its own.
Suppliers are drawn in through their customers
Where a delegated act says so, Article 38 obliges supply chain actors to give manufacturers and authorities relevant information on request, free of charge. Under Annex III, the finished product’s passport can carry operator identifiers for other businesses and facility identifiers for their sites.
Do battery cells and construction parts need their own passport?
The Commission’s batteries page puts the duty on “the economic operator placing the finished battery on the market, rather than suppliers of individual components or modules”. The battery passport applies from 18 February 2027. A construction product passport must include the data carriers of key parts that have their own passport, under Article 76(2) of Regulation (EU) 2024/3110.
Sources: ESPR, Regulation (EU) 2024/1781, Working Plan COM(2025) 187, Steel initiative 17672, Regulation (EU) 2024/3110, DPP for batteries
For a supplier, GreenSutra’s DPP consulting starts by listing the data a customer’s passport could draw from it. The DPP guide tracks the steel act.