Iron and steel need a Digital Product Passport only after the Commission adopts an ESPR delegated act, planned for the fourth quarter of 2026 and unpublished on 19 October 2026. Such an act normally applies at least 18 months after entry into force, so adoption in December 2026 points to passports from around September 2028. Content is not set.
Has the steel act been adopted?
No. The Commission’s public consultation on initiative 17672 ran from 20 May to 12 August 2026, and no draft had been published by 19 October 2026. The Commission plans adoption for the fourth quarter of 2026 and calls that date indicative. The working plan ranks iron and steel first among the intermediate products in its priority product groups.
Will the steel act require a passport?
Yes, unless it uses the ESPR’s exemption. Article 7(2)(a) of the ESPR, Regulation (EU) 2024/1781, makes passport requirements part of any product-specific act. Article 9(4) allows an exemption only where technical specifications are missing or other EU law provides an equivalent digital system. The Commission’s steel page says passport requirements may apply to “manufacturers, producers, importers and other economic operators placing covered iron and steel products on the EU market”. That includes importers of steel made outside the EU.
When could steel passports apply?
No earlier than 18 months after the act enters into force, except in duly justified cases, under Article 4(4). Under Article 72(6), it enters into force only if Parliament and the Council do not object within two months, extendable by two.
Example, with illustrative dates:
1. The act is adopted and notified on 15 December 2026. 2. With no objection, the objection period ends on 15 February 2027. 3. Publication follows on 1 March 2027, and the act enters into force on 21 March 2027. 4. Adding 18 months gives 21 September 2028, so around September 2028 in the usual case.
The passport date list uses the same example.
What will a steel passport hold?
Nothing is fixed. The call for evidence assesses information on carbon footprint, recycled content and substances that make steel harder to recycle. It also assesses performance classes and passport requirements “for all actors involved in the supply chain”.
A Joint Research Centre study of March 2026 makes research recommendations, not law:
- the heat number as the batch identifier, with item serial numbers optional for products such as coils;
- product number, commodity codes, steel grade and technology route;
- operator and facility identifiers, country of origin and manufacturing date;
- substances of concern, a product carbon footprint and recycled content.
Many steel products also enter the construction passport, so the study calls for interoperability between the two.
Is the steel passport a CBAM report?
No. The working plan says ESPR measures complement CBAM, and the study lists a CBAM reference only as a possible voluntary input. CBAM’s steel scope is a separate question.
Sources: ESPR, Regulation (EU) 2024/1781, Working Plan COM(2025) 187, Steel initiative 17672, DPP for iron and steel, JRC steel DPP study
For a steel producer or importer, GreenSutra’s DPP consulting starts by comparing product data on file with the proposed data points. The DPP guide tracks the steel act.