IRON & STEEL · ESPR PRIORITY PRODUCT GROUP
Digital Product Passports for Iron & Steel
Iron and steel are a priority under ESPR and the first intermediate product group being prepared. The European Commission currently targets Q4 2026 for delegated-act adoption, while the exact product scope, DPP data requirements, and application date are not final.
Current position
Regulatory status at a glance
The direction is established, but the iron and steel delegated act will determine the binding details.
ESPR priority product group
The 2025–2030 ESPR working plan identifies iron and steel as a priority for product-specific ecodesign requirements.
Preparatory work underway
The European Commission and Joint Research Centre are running technical and stakeholder preparatory work to inform possible requirements.
Q4 2026 adoption target
The working plan gives Q4 2026 as an indicative target for delegated-act adoption. This is not a company compliance deadline.
Requirements are not final
Covered products, information fields, transition periods, and obligations remain uncertain pending the delegated act.
Potential scope
Who may be affected
Potentially affected businesses include manufacturers, producers, importers, and other economic operators placing covered iron and steel products—including imports—on the EU market. Final applicability will depend on the delegated act and each operator’s circumstances.
Economic operators
- Manufacturers and producers
- Importers
- Other operators placing covered products on the EU market
- Businesses handling potentially covered imported products
Representative intermediate products considered in the preparatory study include:
- Wire rod
- Hot-rolled coil
- Galvanized cold-rolled coil
- Electrical sheet/steel
- Stainless steel
Regulatory sequence
Iron & steel DPP timeline
The regulatory framework is in place, but the product-specific requirements and their application date still depend on the iron and steel delegated act.
2024
ESPR establishes the framework
Regulation (EU) 2024/1781 establishes the framework for product-specific ecodesign requirements and Digital Product Passports.
April 2025
Iron & steel prioritised
The Working Plan 2025–2030 identifies iron and steel as a priority.
2026
Preparatory work and consultation
The Commission and JRC develop the technical basis, including DPP requirements.
Q4 2026Indicative
Delegated act planned
This is the current indicative target for adoption. This is not a company compliance deadline.
Application dateNot yet defined
Compliance start depends on final delegated act
The application date has not been defined and will depend on the final delegated act.
Confirmed framework
What is already known about the DPP requirements?
The final iron and steel requirements are still developing. ESPR establishes the technical framework that applies where a delegated act requires a Digital Product Passport.
Unique product identity
Each passport is linked to a persistent unique product identifier. The exact identifier level for iron and steel will depend on the delegated act.
Physical data carrier
The passport is accessed through a physical data carrier. Exact placement requirements will depend on the delegated act.
Interoperable data
DPP data uses open standards and interoperable formats and, where appropriate, is machine-readable, structured, searchable, and transferable.
Reliable information
Information in the passport must be accurate, complete, and kept up to date.
Product-specific rules
Product-specific performance and information requirements, including any DPP data fields, will be set in the iron and steel delegated act.
Pending delegated act
What is still to be defined for iron and steel?
The delegated act turns the ESPR framework into product-specific requirements. These details remain open for iron and steel.
Product scope
The final covered products and exclusions.
Required DPP data
The final dataset has not been defined.
Passport granularity
Whether requirements apply at model, batch, or individual-item level.
Data-carrier placement
Whether the carrier must appear on the product, packaging, or accompanying documents.
Access rights
Which information will be public or restricted to defined actors.
- Not yet defined
Application date
The compliance start will depend on the final delegated act.
Responsibilities
The specific duties assigned to manufacturers, importers, and other economic operators.
Provisional only
Data categories to prepare for
The final DPP dataset is not yet settled. Current public preparatory material points to these provisional categories—not a definitive or mandatory field list:
- 01Product identification and classification
- 02Technical and material information
- 03Recycled-content and circularity information
- 04Sustainability-related information
- 05Compliance and value-chain traceability documentation
Readiness pathway
Five steps to start now
These no-regret preparation steps improve product-data control while the legal detail develops.
Map your portfolio
Create a bounded view of products and product families that may fall within the future scope.
Locate the data
Identify relevant records across ERP, PLM, PIM, spreadsheets, certificates, and other source systems.
Identify supplier dependencies
Record which information and evidence must come from upstream suppliers.
Establish ownership
Assign accountable teams for source data, evidence, review, access, and updates.
Prepare structured product data
Normalize identifiers, fields, evidence links, and update workflows so information can later support DPP requirements.
Ease your transition with Circlepass
Want help working through this list? We can support your team step by step.
How Circlepass helps
Turn existing information into workable DPP foundations
Circlepass helps manufacturers structure existing product information into DPP workflows—connecting source records, supplier inputs, evidence, ownership, and controlled updates. This supports readiness as requirements evolve; it is not a certification or compliance guarantee.
Check your DPP readinessIron and steel DPP questions
Is an iron and steel Digital Product Passport already mandatory?
No product-specific iron and steel DPP obligation is final at the review date. ESPR establishes the framework, while a future delegated act is expected to define covered products, requirements, timing, and transition arrangements.
Is Q4 2026 the compliance deadline?
No. Q4 2026 is an indicative delegated-act adoption target in the ESPR working plan, not a compliance deadline for companies. Any applicable dates and transition periods would need to come from the adopted legal act.
Which iron and steel products will be covered?
Final scope is not settled. The preparatory study considers representative intermediate products such as wire rod, hot-rolled coil, galvanized cold-rolled coil, electrical sheet or steel, and stainless steel, but this does not establish the final legal scope.
Will imported products be included?
Potentially. ESPR requirements can apply to covered products placed on the EU market, including imports. The delegated act and an operator’s role and circumstances will determine specific obligations.
What data will the passport require?
The final dataset is not yet available. Preparatory work indicates possible categories including identification and classification, technical and material data, recycled content and circularity, sustainability information, and compliance or value-chain traceability documentation.
What can manufacturers do before requirements are final?
Map the relevant portfolio, locate existing data, identify supplier dependencies, establish internal ownership, and prepare structured product information and evidence links. These steps support readiness without assuming a final requirement.
Official EU sources
Regulatory references last checked on 24 September 2026
- 01Ecodesign for Sustainable Products Regulation (EU) 2024/1781
- 02ESPR and Energy Labelling Working Plan 2025–2030
- 03European Commission: Digital Product Passport for iron and steel
- 04Commission call for evidence on iron and steel ecodesign requirements
- 05JRC Product Bureau: Metal products preparatory-study documents