Digital Product Passports for Steel and Aluminium: What Companies Need to Know

Executive Summary

Iron and steel and aluminium are not just named in the Ecodesign for Sustainable Products Regulation. They are the first two entries on the statutory priority list. Article 18(5) of Regulation (EU) 2024/1781 directs the Commission to prioritise a specific set of product groups, and that list opens with “(a) iron and steel” and “(b) aluminium”, ahead of textiles, furniture, tyres, detergents, paints, lubricants and chemicals. No other sector has a stronger claim to be early.

That priority is not an obligation. As of the date of this article, no product-specific delegated act imposing Digital Product Passport requirements on steel or aluminium has been adopted. There is therefore no passport start date for these materials, no legally defined passport data content, no defined identity level and no defined data carrier. Anything presented as “the steel passport schema” is somebody’s estimate.

What makes steel and aluminium different from every other industry guide in this library is that they are intermediate products. Article 1(2) of the Regulation states that it applies to physical goods placed on the market or put into service, “including components and intermediate products”, and Article 2(3) defines an intermediate product as one that requires further manufacturing or transformation, such as mixing, coating or assembling, to make it suitable for end users. A coil, a billet, a plate or an extrusion is a product in its own right under this framework, and it is also an input to the passport of something else. Steel and aluminium companies therefore have to plan for two roles at once: holder of a passport, and supplier of data into the passports of their customers.

The second thing that makes these sectors different is that a large part of the hardest data has already been forced into existence by other law. The carbon border adjustment mechanism, Regulation (EU) 2023/956, covers iron and steel and aluminium in Annex I, ran a reporting-only transitional period, and moved to its definitive regime with effect from 1 January 2026, requiring authorised declarants to account for embedded emissions, including indirect emissions from electricity for the relevant goods. Producers, importers and traders in these materials are already operating carbon accounting at consignment level. That capability is the single largest head start any sector has towards a passport.

This guide sets out what is adopted law, what is planning intention, what remains undetermined, and what a steel or aluminium business can build now that will not be wasted when the legal position resolves.

Table of Contents

• What Would a Steel or Aluminium Passport Be?
• Do Steel and Aluminium Already Require a Passport?
• Why Intermediate Products Change the Question
• Which Products Could Be Affected?
• Why Steel and Aluminium Are Difficult
• What Information May Matter?
• Where Does the Data Come From?
• Embedded Emissions and Carbon Accounting
• Scrap, Recycled Content and Circularity Claims
• Material Identity: Heats, Casts, Coils and Cuts
• Mill Certificates and Existing Documentation
• Supplier and Evidence Requirements
• Data Quality and Validation
• Standards and Interoperability
• Adjacent and Overlapping Regulation
• Legal Responsibility
• Enterprise Architecture
• SME Implications
• Enterprise Implications
• Preparing Before Final Requirements Exist
• What Not to Build Yet
• Pilot Strategy
• Worked Example
• Common Mistakes
• Preparation Checklist
• Frequently Asked Questions
• References

What Would a Steel or Aluminium Passport Be?

A Digital Product Passport is a structured, machine-readable record about a specific product, reachable through a data carrier associated with that product, containing the information a legal act requires, available to the parties that the same legal act names.

Four articles of the framework carry the weight.

Article 9 creates the passport obligation and makes it conditional. A passport is required only where a delegated act adopted under Article 4 says so, and the same delegated act specifies the data content, the data carrier, its layout and positioning, and whether the passport applies at model, batch or item level. That last point matters more in metals than in any other sector, and it is precisely the point that has not been decided.

Article 10 sets the essential requirements. The passport must be connected through a data carrier to a persistent unique product identifier, the carrier must be physically present on the product, its packaging or its documentation, and the data must be machine-readable, structured, searchable and based on open standards.

Article 11 governs technical design and operation, including full interoperability between passports required under different delegated acts, and access rights for customers, manufacturers, importers, distributors, repairers, recyclers, market surveillance authorities and customs.

Article 12 covers unique operator identifiers and unique facility identifiers. In metals this is not a footnote. Provenance in this sector is expressed as a plant and a process route, so facility identity is close to the centre of any credible material claim.

There is one further framework item worth knowing. Article 13 requires the Commission to establish an EU registry storing at least the unique identifiers of products covered by passports, with a deadline of 19 July 2026 for setting it up. A registry existing is not the same as a steel obligation existing. The registry is horizontal plumbing; the obligation still arrives only through a product-specific act.

Do Steel and Aluminium Already Require a Passport?

No. Six statements are commonly blended together in this sector. Only some are law.

Statement one: the framework is in force. True. Regulation (EU) 2024/1781 is in force, and its framework provisions, including the empowerment to adopt product-specific delegated acts, apply now.

Statement two: iron, steel and aluminium are top of the priority list. True, and it is the strongest form of priority in the Regulation. The list is in the enacting text at Article 18(5), not in a communication, and iron and steel and aluminium are items (a) and (b).

Statement three: therefore steel and aluminium have a passport deadline. False. Article 18(5) imposes a duty on the Commission about prioritisation in its working plan. It imposes nothing on a mill, a service centre, a foundry, a trader or a fabricator, and it sets no application date for any passport.

Statement four: the passport data content for steel is already defined. False. Article 9 reserves data content, identity level, carrier and access rights to the delegated act. Preparatory studies, consultation material, industry association templates and vendor schemas are useful for anticipating themes. None of them is a legal requirement.

Statement five: steel and aluminium are otherwise unregulated on data until then. False, and this is the expensive misconception. Carbon border adjustment obligations, waste and scrap shipment controls, construction product rules for structural metal products, chemical legislation and, for many companies, customer and public procurement requirements already demand product-level data on these materials today.

Statement six: the carbon border adjustment mechanism is the steel passport. False. It is a customs and carbon pricing instrument, not a product information instrument. It is nevertheless the closest thing the sector has to a rehearsal, because it forces verified, consignment-level, product-specific emissions data through the same organisations.

Why Intermediate Products Change the Question

Every other guide in this pillar concerns products that reach an end user broadly as they left the factory. Steel and aluminium do not. A slab becomes a coil, the coil is slit, the strip is formed, the part is coated and assembled, and the object that reaches a consumer is a washing machine or a facade or a car. The Regulation nevertheless applies to intermediate products explicitly, and that produces three consequences that shape the whole preparation problem.

Consequence one: you may be a passport holder in your own right. Article 1(2) brings components and intermediate products into scope, so a delegated act could require a passport for, say, flat-rolled products or extruded profiles, independent of anything downstream. That passport would attach to the metal product as placed on the market.

Consequence two: you are certainly a data supplier. Even in the absence of any metals delegated act, downstream sectors that do get one will need material data from their metal suppliers. Recycled content, embedded emissions, alloy composition and substance data cannot be invented by a fabricator. Steel and aluminium businesses will be answering passport questions long before they are answering passport obligations.

Consequence three: data has to survive transformation. A passport claim about a finished product that depends on the metal in it requires the metal data to travel through slitting, forming, welding, coating and assembly without losing its link to the physical material. This is the true engineering problem of the sector, and it is not solved by choosing a data format.

Which Products Could Be Affected?

No legal scope statement exists for these groups. The table below is an analytical planning map derived from the wording of the priority list and from ordinary industry structure, not from any adopted act.

Two boundary cases repay attention. First, construction. Structural steel and aluminium products are construction products, and the construction products regime is a separate legal instrument with its own digital provisions. A metals business selling into construction should assume two distinct regimes rather than one. Second, automotive and packaging. Metal supplied into vehicles or into packaging is caught by other sectoral regimes whose data expectations may arrive earlier than any metals act, and those regimes will ask the mill the same questions in a different vocabulary.

Why Steel and Aluminium Are Difficult

The sector often assumes that because its products are chemically simple and heavily documented, passport readiness is largely done. Mill certificates already exist, after all. The difficulty is elsewhere.

Identity is continuous, not discrete. A heat is a quantity of liquid metal. A cast, a coil, a slit coil and a cut length are successive subdivisions of it. There is no natural “unit” that corresponds to a consumer product, and the subdivision continues after the material leaves the producer. Any identity model has to describe division and merger, not just assignment.

Merger destroys attribution. Remelting, scrap blending and multi-coil processing combine material with different histories into one output. Once merged, the properties of the output are a weighted result, and no honest system can attribute a specific atom to a specific origin. Mass balance and average-based accounting become unavoidable, and they must be labelled as such rather than presented as physical traceability.

Composition data is commercially sensitive. Alloy recipes and process routes are competitive assets. Article 10 explicitly contemplates protection of commercially confidential information, but the reconciliation of confidentiality with recycled content and emissions transparency is a genuine tension rather than a solved problem.

Emissions numbers are contested and methodology-dependent. Two mills can report different embedded emissions for chemically identical products because of allocation choices, system boundaries and electricity accounting. A passport field labelled “carbon footprint” is meaningless without the method that produced it, and methods are still consolidating.

Documentation is document-shaped, not data-shaped. Mill certificates exist in enormous numbers, mostly as PDFs, frequently re-issued and transcribed by traders and service centres. The information is present and the data is not, because nothing downstream can consume it without human reading.

Processing intermediaries break the chain. Service centres, stockholders and traders sit between the producer and the user. Material is bought, stored, mixed by grade, cut to order and resold. In many chains the certificate is passed on while the physical link between certificate and metal is maintained only by warehouse practice.

Long life, long tail. Structural metal remains in service for decades and is then recycled. Any record that is expected to support end-of-life decisions has to outlive the producer’s ERP system, and possibly the producer.

What Information May Matter?

There is no legal field list. What follows is a planning inventory derived from three defensible sources: the categories of information the Regulation permits a delegated act to require, the data already demanded by adopted regimes applying to these materials today, and the information already exchanged in the sector through mill certificates and environmental declarations. Treat every row as a capability to build, not a field to publish.

Where Does the Data Come From?

The Passport Data Origin Model, TBF-042, separates passport data by where it originates, because the governance problem differs entirely by origin. Applied to metals the model is unusually clean, which is one reason this sector is a good place to build the capability early.

The reason this matters is that a passport does not merely display values. It implies that each value is maintainable, that someone will notice when it goes stale, and that evidence exists behind it. A number whose origin class is unknown cannot be maintained, because nobody knows who would have to update it.

Embedded Emissions and Carbon Accounting

Steel and aluminium are covered by Annex I of Regulation (EU) 2023/956, the carbon border adjustment mechanism. The instrument ran a reporting-only transitional phase and then moved to its definitive regime, whose substantive obligations apply from 1 January 2026. Under the definitive regime, imports of covered goods are made through an authorised CBAM declarant, embedded emissions must be determined and reported, and certificates are surrendered against them. For the relevant goods, embedded emissions include not only direct process emissions but also indirect emissions from the electricity used in production, which is what makes aluminium so sensitive to power sourcing.

Several features of that regime deserve attention from anyone thinking about passports.

It is consignment-level, not company-level. The obligation attaches to goods, identified by customs classification, in defined quantities, with emissions attributed to them. That is far closer to product data than to corporate sustainability reporting.

It forces methodology discipline. Emissions have to be determined according to defined rules rather than by a company’s preferred approach, and the difference between installation-specific values and default values matters.

It forces the supplier conversation. European importers have spent the transitional period asking non-EU producers for installation-level emissions data. Whatever else it achieved, it established that this data can be obtained and revealed exactly which suppliers cannot or will not provide it.

It is not a passport. It has no data carrier, no consumer access, no repairer or recycler access, and no product identifier semantics. Treating carbon border compliance as passport readiness will produce a system that cannot answer any non-carbon question.

The simplification measures adopted in 2025 as part of the Commission’s simplification package changed the administrative perimeter of the carbon border regime, notably by exempting smaller importers below a volume threshold while retaining coverage of the large majority of embedded emissions. Because that package amended the Regulation, always check the current consolidated text of Regulation (EU) 2023/956 on EUR-Lex for the thresholds and procedural rules that apply to your own imports, rather than relying on a secondary description, including this one.

Scrap, Recycled Content and Circularity Claims

Recycled content is the single most requested figure in metals procurement and the single most frequently misstated. Three distinctions decide whether a claim survives scrutiny.

Pre-consumer versus post-consumer. Internal process scrap returned to the furnace is not the same as metal recovered at end of life. Both are legitimately recycled input under many definitions, and they carry very different environmental and reputational weight. A single percentage that does not distinguish them is not informative.

Physical versus mass balance. In a furnace, inputs merge. A claim that a specific coil contains a specific percentage of post-consumer scrap is, in almost all cases, an allocation from a charge mix over a period, not a measurement of that coil. That is defensible if disclosed and indefensible if presented as physical traceability.

Basis and boundary. A percentage by mass of what, over what period, verified by whom. Two mills using different periods and boundaries can publish very different numbers for identical practice.

Scrap sourcing itself sits inside adopted waste law. Shipments of metal scrap are governed by Regulation (EU) 2024/1157 on shipments of waste, including conditions on exports, and material remains waste until it satisfies end-of-waste criteria. For a passport programme the practical implication is narrow but important: the origin, quality and status of scrap inputs are data you will need, and they live in yard, weighbridge and purchasing systems that are rarely connected to product data.

Material Identity: Heats, Casts, Coils and Cuts

Identity is where metals passport programmes succeed or fail. The sector already has an identity system; it is simply not a product identity system in the sense the framework assumes.

The framework leaves the choice of model, batch or item level to the delegated act. Because that choice is open, the correct preparation is not to pick a level and build for it, but to make the relationships explicit: which item came from which coil, which coil from which cast, which cast from which heat, and which inputs went into that heat. A system that can answer those questions can serve any level a delegated act eventually chooses. A system that stores only a grade against an order can serve none of them.

Marking is the physical constraint. Coils carry tags, plates carry stencils and stamps, extrusions carry labels, and every one of those can be lost during processing. Any carrier decision has to survive coil handling, cutting, cleaning, heat treatment, coating and welding, and no adopted act yet requires a specific approach for these materials.

Mill Certificates and Existing Documentation

Almost every relevant fact a passport might carry about a steel or aluminium product is already written on an inspection document. Composition, mechanical properties, dimensions, the standard applied, the heat number, the producing works. The sector’s advantage over textiles or furniture is enormous, and it is routinely squandered for a single reason: the document is not data.

Three failure patterns recur.

Transcription. Traders and service centres re-issue certificates, sometimes retyping values or attaching a scan of the original. Errors and detail loss enter here, and so does ambiguity about which physical material a document describes.

Aggregation. One certificate is supplied for a delivery containing material from several heats, because that is administratively convenient. Any downstream claim about a specific piece is then a guess.

Storage as files. Certificates filed by order number in a document system are retrievable by a human who knows the order number. They are not retrievable by a system that has a bracket in front of it and needs to know what the bracket is made of.

Converting certificate content into structured, heat-keyed data is the highest-return preparation work in this sector, and it is worth doing on commercial grounds alone. It shortens customer data requests, supports carbon and recycled content reporting, and it is a prerequisite for any passport regardless of what the eventual field list says.

Supplier and Evidence Requirements

Metals supply chains are short in tiers and deep in volume, which changes the supplier problem. There are usually fewer counterparties than in textiles or electronics, but each one supplies a great deal, and the data that matters most sits with the fewest of them: the melting operation and the scrap supplier.

The controls that work are contractual and unglamorous.

• Data provision terms in purchase agreements, specifying format, granularity, timing and the obligation to update when a value changes.
• Heat-level linkage terms, requiring that documentation identify the heat or cast for each delivered quantity rather than each delivery.
• Methodology disclosure, requiring that any emissions or recycled content figure arrive with its method, boundary, period and verification status.
• Change notification, requiring notice when a process route, plant or significant input changes.
• Audit and verification rights, proportionate to the value of the claim being relied upon.
• A dated request log, recording every request made and every refusal received.

That last item is the cheapest and most undervalued control in compliance. A documented, dated attempt to obtain data that a supplier refused is a far stronger position than a silent gap, and at contract renewal it converts a compliance problem into a commercial conversation with evidence attached.

Voluntary schemes such as ResponsibleSteel and the Aluminium Stewardship Initiative are useful evidence about site practice and management systems. They are not EU law, they do not state the composition or emissions of a specific consignment, and they should be stored as attestations bound to a facility and a period, not substituted for product-level values.

Data Quality and Validation

Metals data fails in characteristic ways, and the validation rules that catch those failures are worth writing before any passport requirement exists.

Completeness. Every delivered quantity resolves to a heat or cast. Every claim has an origin class and a source. Every calculated value has its inputs stored.

Consistency. Units are consistent, and mass reconciles. If the mass of outputs attributed to a heat exceeds the mass of the heat, something is wrong upstream of any passport.

Plausibility. Composition values sit inside the grade specification. Emissions intensity sits inside the plausible range for the process route. A blast furnace route with an electric arc furnace emissions figure is a data error, not an achievement.

Method integrity. Recycled content and emissions are recomputed from stored inputs rather than being carried forward as literals, so that a changed input changes the output.

Evidence binding. Every test report and verification statement is bound to the material it covers and carries a validity period, rather than being filed by year.

Staleness. Values with a reference period, particularly emissions factors and verified figures, carry a review date and are flagged when the period lapses.

Standards and Interoperability

Article 10 requires that passports rely on open, interoperable standards, and Article 11 requires interoperability between passports created under different delegated acts. That is a legal requirement on the eventual system, not a licence for anyone to declare today which standards will be named.

What can be said now, without speculation:

• Identification and carriers. General product identification and data carrier practice is mature and is treated in the identity and carrier articles in this library. What is not settled is which identity level applies to metals, which is the decision that determines everything else.
• Event data. Supply chain event standards are the natural way to represent subdivision, merger and custody change, which is exactly the metals problem. Adopting an event model internally is useful regardless of the eventual legal choice.
• Environmental declarations. EN 15804 and ISO 14025 provide product category rules and declaration formats widely used for construction-relevant metal products. They are voluntary standards and become legally material only where an adopted instrument references them.
• European standardisation work on passports. European standardisation bodies are working on horizontal Digital Product Passport standards following a Commission standardisation request. Status changes over time, and specific standard numbers and publication states should be checked against the standardisation bodies’ own registers before being cited.

The practical interoperability advice for metals is narrower than the standards debate suggests. Ensure that your internal identifiers are stable, globally unambiguous, and expressible in more than one scheme, and ensure that every value is retrievable through an interface rather than only through a document.

Adjacent and Overlapping Regulation

A metals business is rarely governed by one regime, and overlap is the main source of duplicated effort.

Construction products. Regulation (EU) 2024/3110 establishes the current EU framework for construction products and carries its own digital arrangements. Structural steel and aluminium products sold as construction products fall under it. This is a separate legal track from ESPR passports and must be planned separately, even where the underlying data is the same.

Carbon border adjustment. Regulation (EU) 2023/956 as described above. Product scope by customs code, emissions accounting, authorised declarants.

Waste and scrap. Regulation (EU) 2024/1157 governs shipments of waste, including metal scrap, with export conditions that affect input sourcing strategies.

Chemicals. REACH obligations apply to substances used in coatings, surface treatments and some alloying contexts, and substance information is a plausible passport theme in any sector.

Automotive end of life. Proposals concerning end-of-life vehicles include recycled content and design provisions relevant to metals. Proposals are not law, and their content changes during negotiation. Track them; do not build to them.

Sector policy. The Commission’s steel and metals policy work, including its 2025 action plan communication, signals intentions around industrial decarbonisation and lead markets for low-carbon metal. Policy communications are not binding instruments, and any procurement or carbon-content criteria they discuss become obligations only through subsequent legal acts.

Legal Responsibility

Responsibility follows the role a business plays in placing a product on the Union market, not its size or its self-description. In metals the roles are unusually blurred, so it is worth being precise.

The producer that places the product on the market carries manufacturer duties for that product.

The importer bringing metal into the Union carries verification duties, and under the carbon border regime the associated obligations attach to the authorised declarant for the goods.

A trader or service centre that processes material may become a manufacturer in law for the resulting product, particularly where it changes the product’s characteristics or sells under its own name. Slitting, cutting to length, coating and forming are not neutral acts in this analysis.

A distributor that neither processes nor rebrands still carries duties to check that required documentation accompanies the product.

None of these responsibilities can be contracted away to a supplier. Contracts allocate cost and effort between commercial parties; they do not move the legal position under product law.

Enterprise Architecture

The architecture question for metals is not which passport platform to buy. It is where the material identity graph will live, because everything else attaches to it.

A material identity layer. Heats, casts, coils, subdivisions and merges, with parent and child relationships, quantities and timestamps. This is the foundational asset. It usually does not exist in a usable form, and it is usually reconstructable from production and logistics systems that already record the events separately.

A property store. Composition, mechanical properties, process route, emissions, recycled content, each value carrying its origin class, method, source, date and evidence link.

An evidence store. Certificates, test reports, verification statements and scheme attestations, bound to material identities and claims rather than filed by order or year.

A calculation service. Emissions and recycled content computed from stored inputs on demand, so that figures are reproducible and change when inputs change.

A publication layer. The part that renders a passport, a customer data file, a carbon report or a declaration. It should be thin, because the value is upstream of it, and it should be replaceable, because formats will change.

Sequence matters. Organisations that begin with the publication layer end up with a display for data they cannot maintain. Organisations that begin with identity find that every later requirement is a query.

SME Implications

The metals value chain contains a large number of small businesses: service centres, stockholders, fabricators, foundries and specialist processors. Passport preparation advice written for an integrated producer is useless to them, and mostly unnecessary.

What a small business in this chain should actually do is short.

Keep the link between document and material. If a delivery contains material from three heats, keep three linkages, not one certificate for the lot. This is a warehouse discipline question far more than a software question.

Stop re-typing certificates. Pass through the original, and where you must re-issue, keep the original attached and the heat reference intact.

Structure the small number of things you sell most. A stockholder with two hundred grade and dimension combinations has a two hundred row problem, not a per-tonne problem.

Answer customer data requests once. Requests from customers for composition, recycled content and emissions are already arriving. Answering each one ad hoc is the expensive path; building one structured answer set and reusing it is the cheap one.

Log what you cannot get. A dated record of a supplier refusal costs nothing and is worth a great deal later.

Buy nothing yet that assumes a field list. No adopted act defines metals passport content, so software sold on that basis is selling a guess.

Smaller importers should also verify their own position under the carbon border regime rather than assuming it applies to them in full, because the 2025 simplification changed the administrative perimeter. Check the consolidated Regulation text against your import volumes.

Enterprise Implications

For integrated producers and large processors the constraint is different. The data exists, in quantity, across many plants and many systems, in inconsistent forms, and the organisation has already built at least two partly overlapping reporting capabilities: one for carbon border compliance and one for corporate sustainability reporting. The characteristic enterprise failure is a third silo.

Consolidate the calculation, not the reports. One governed method for embedded emissions and recycled content, one set of stored inputs, many outputs. Where different regimes require different boundaries, model the boundary as a parameter rather than as a separate system.

Treat plant identity as master data. Facility identifiers, process routes and their attributes belong in governed master data, because provenance claims resolve to plants.

Decide the identity level position early, and document it. Not because you can know what the delegated act will require, but because your systems must be able to answer at cast level even if you eventually publish at product model level.

Plan for confidentiality tiering. Article 10 contemplates access differentiation. Enterprises with genuinely sensitive process data should be modelling now which values could be public, which are for customers, and which are for authorities only.

Do not sign schema commitments with customers. Large customers under pressure from their own regulators will ask suppliers to commit to their preferred data model. Provide the data; avoid contractual commitments to a specific schema that no adopted act supports.

Preparing Before Final Requirements Exist

Nine actions are worth doing regardless of what any delegated act eventually says, because each of them serves an existing commercial or regulatory need as well.

1. Build the material identity graph. Heats, casts, coils, subdivisions, merges, deliveries.
2. Structure certificate content. Convert inspection document content into data keyed to heat or cast.
3. Record origin class for every property. Declared, measured, calculated, supplied, attested.
4. Consolidate emissions methodology. One method, stored inputs, reproducible outputs, verification status recorded.
5. Make recycled content honest. Distinguish pre-consumer and post-consumer, disclose mass balance, state basis and period.
6. Fix supplier contracts at renewal. Data provision, heat-level linkage, methodology disclosure, change notification, audit rights.
7. Bind evidence to claims. Every certificate and verification statement attached to the specific material and claim it supports, with a validity period.
8. Test physical marking survival. Establish, per product family, which marking approaches survive your customers’ processing.
9. Assign legal monitoring. A named person tracking EUR-Lex, the working plan and standardisation status, reporting quarterly.

What Not to Build Yet

Restraint is as valuable as preparation in a sector with no adopted product act.

• Do not build to a published “steel DPP schema”. None is law. Committing your data model to somebody else’s guess creates migration cost with no compliance benefit.
• Do not serialise every coil, plate and cut length now. Establish the identity relationships and the ability to serialise. Serialise at scale when a requirement or a customer pays for it.
• Do not publish consumer-facing material claims ahead of the evidence. Recycled content and low-carbon claims made without method and verification are the likeliest source of an enforcement or advertising problem in the interim period.
• Do not procure a passport platform with a long committed term. Carrier, format and access requirements are undefined for these materials.
• Do not build a separate passport data warehouse. It duplicates the carbon and quality data you already maintain and will drift from it within a year.
• Do not assume the construction products route and the ESPR route will merge. Plan them as two.
• Do not treat working plan timing as a project deadline. Plan capability milestones, not compliance dates that no instrument has set.

Pilot Strategy

A useful metals pilot is narrow, physical and customer-driven.

Choose one product family and one route. For example, one galvanised coil grade from one plant, or one extrusion alloy from one press. Resist the urge to pilot across the portfolio.

Choose a real customer question. A live customer request for composition, recycled content or emissions data is a better pilot driver than a hypothetical passport, because it produces a deadline and a verdict.

Trace one heat end to end. From charge mix through cast, coil, slitting and delivery to a specific customer receipt. The pilot’s real output is the list of places where the chain broke.

Compute one number twice. Calculate recycled content or embedded emissions independently by two routes and reconcile the difference. The reconciliation exposes the methodology assumptions that would otherwise surface during an audit.

Test one physical marking. Apply an identifier, send it through a customer’s processing, and see whether it survives.

Write down what you could not answer. The gap list is the deliverable that shapes the programme.

Worked Example

Company. Northmere Metals, a fictional aluminium extruder with two presses, 260 employees, buying billet from three suppliers, selling profiles to construction, transport and industrial customers across the Union.

Starting position. Billet purchases are recorded by supplier and delivery note. Cast numbers are recorded on goods receipt but not carried into production. Press orders reference customer part numbers. Recycled content is quoted to customers from a supplier statement about their smelter average. Emissions data is compiled annually for corporate reporting and separately, in more detail, for one customer’s questionnaire.

Trigger. A construction customer bidding for a public project asks for profile-level recycled content and product carbon footprint, with methodology and third party verification, per delivery, for a two year supply agreement.

What the pilot finds.

• Cast number is captured at goods receipt but lost at charging, so no output profile can be traced to a billet cast.
• The recycled content quoted to customers is a smelter-level annual average, described in the sales documentation in language that implies it is a property of the delivered profile.
• Process scrap returned to the remelt is included in the recycled figure without distinguishing it from post-consumer input.
• The two emissions calculations, corporate and customer-facing, differ by a material margin because of different electricity accounting.
• One of the three billet suppliers provides installation-level data promptly, because it already produces it for carbon border purposes. One provides an annual brochure figure. One declines.
• Profiles are labelled per bundle, and the label does not survive the customer’s anodising.

What Northmere changes.

• Carries the billet cast number through charging and press orders, creating a genuine parent and child chain from cast to bundle.
• Splits recycled content into pre-consumer and post-consumer, publishes the mass balance basis explicitly, and rewrites the sales language to stop implying physical content.
• Adopts one emissions method with stored inputs, and reports the corporate and customer figures from the same calculation with different boundaries as parameters.
• Adds data provision and methodology disclosure clauses at renewal with all three billet suppliers, and shifts volume towards the supplier that already had the data.
• Moves marking from the bundle label to a durable per-length marking for the customer’s product family, after testing survival through anodising.

Outcome. Northmere wins the supply agreement, discovers that its recycled content statements had been overstated in implication rather than in number, and finds that the work it valued least, carrying a cast number through two systems, was the work that made everything else possible. When a delegated act arrives, it will be mapping fields rather than rebuilding traceability.

Common Mistakes

Preparation Checklist

Material identity

• Heats and casts are recorded and carried through production, not only at goods receipt.
• Subdivision and merger events are captured with parent, child, quantity and timestamp.
• Every delivered quantity resolves to at least one cast or heat.
• Identifiers are stable, globally unambiguous and not reused.

Property data

• Composition, mechanical properties and process route are stored as data, not only on documents.
• Every property carries an origin class, a source and a date.
• Calculated values are reproducible from stored inputs.
• Units and reference conditions are consistent across plants.

Carbon and circularity

• One embedded emissions method is used, with boundary as a parameter and verification status recorded.
• Recycled content distinguishes pre-consumer and post-consumer input.
• Mass balance is disclosed wherever allocation rather than measurement is used.
• Scrap inputs record origin, quality and status.

Suppliers and evidence

• Purchase agreements include data provision, methodology disclosure and change notification terms.
• Documentation from suppliers identifies heat or cast, not just delivery.
• Every certificate, test report and verification statement is bound to material and claim with a validity period.
• A dated log records requests made and refusals received.

Systems and operations

• Certificate content is structured and queryable.
• Validation rules cover completeness, consistency, plausibility, method integrity and staleness.
• Marking approaches have been tested for survival through customer processing.
• A named person monitors EUR-Lex, the working plan and standardisation status and reports quarterly.

Frequently Asked Questions

Do steel or aluminium products need a Digital Product Passport today? No. Regulation (EU) 2024/1781 creates passport obligations only through product-specific delegated acts, and no delegated act covering iron and steel or aluminium has been adopted.

Iron and steel and aluminium are first on the priority list. Does that not make it certain? It makes them the highest-ranked priority in the enacting text of the Regulation itself, at Article 18(5). It does not create an obligation, fix a date or define content. Priority determines the order of the Commission’s work, not the existence of a duty.

When will a steel or aluminium delegated act arrive? No adopted instrument states a date. Preparatory study, consultation, impact assessment and formal adoption sit between prioritisation and an act. Treat any specific year attributed to a metals passport as an estimate and verify it against the working plan text and EUR-Lex.

Are intermediate products really in scope? Yes. Article 1(2) states that the Regulation applies to physical goods placed on the market or put into service, including components and intermediate products, and Article 2(3) defines intermediate product. Whether a specific metals product group receives a passport requirement remains a matter for a delegated act.

Is the carbon border adjustment mechanism a Digital Product Passport? No. Regulation (EU) 2023/956 is a carbon pricing and customs instrument covering iron and steel and aluminium among other goods, with a reporting-only transitional period and a definitive regime applying from 1 January 2026. It has no data carrier, no product identifier semantics and no access model for repairers, recyclers or consumers.

Will a metals passport be per heat, per coil or per grade? Unknown. Article 9 leaves the model, batch or item choice to the delegated act. Build the relationships between heat, cast, coil and delivered item so that any level can be answered.

Does a mill certificate satisfy a passport requirement? No. It is a document, not a machine-readable record connected to a persistent unique identifier through a data carrier. It is, however, the best source of the content a passport would need.

How should we state recycled content? With the distinction between pre-consumer and post-consumer input, the basis and period, whether the figure is mass balance or physical, and the verification status. A bare percentage invites challenge.

Our scrap supply is variable. Can we still make claims? Yes, if the claim reflects the accounting method honestly. Variability is a reason to publish a period average with the period stated, not a reason to publish nothing or to imply precision that does not exist.

We only slit and cut material. Are we affected? Probably, in two ways. Processing can make you the manufacturer in law for the resulting product, and your customers will ask you for data that only survives if you preserve the heat linkage through processing.

Does the construction products regime cover our structural steel? Structural steel and aluminium construction products fall under Regulation (EU) 2024/3110, which has its own digital arrangements. Plan it as a separate obligation from any future ESPR passport.

Should we join ResponsibleSteel or the Aluminium Stewardship Initiative to prepare? Those are commercial decisions about market access and assurance. They are voluntary schemes, not EU law, and membership does not create or satisfy any passport obligation.

Should we buy passport software now? Not on the basis of a field list, a carrier standard or a transport format, because none is defined for these materials. Invest in identity, structured property data, evidence binding and supplier terms, all of which are portable.

What is the single highest-value thing to do first? Carry the heat or cast identity all the way through production and delivery. Almost every other capability in this article depends on it, and almost no other capability compensates for its absence.

Related Articles

• Digital Product Passports for Electronics: What Companies Need to Know
• Digital Product Passports for Furniture: What Companies Need to Know
• Digital Product Passports for Textiles and Apparel: What Companies Need to Know
• Digital Product Passport
• How Conformity Assessment Works for Digital Product Passports
• How Digital Product Passports Will Be Enforced
• How Does a Digital Product Passport Work?
• What Are Delegated Acts?

References

• Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products: https://eur-lex.europa.eu/eli/reg/2024/1781/oj
• Regulation (EU) 2024/1781, Article 18(5), statutory priority product groups, and Articles 9 to 13 on the Digital Product Passport: https://eur-lex.europa.eu/eli/reg/2024/1781/oj
• European Commission, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187, adopted 19 April 2025: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187
• Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, including Annex I product scope and the application of the definitive regime: https://eur-lex.europa.eu/eli/reg/2023/956/oj
• European Commission, carbon border adjustment mechanism, including current guidance and simplification measures: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
• Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products: https://eur-lex.europa.eu/eli/reg/2024/3110/oj
• Regulation (EU) 2024/1157 on shipments of waste: https://eur-lex.europa.eu/eli/reg/2024/1157/oj
• Regulation (EC) No 1907/2006 (REACH): https://eur-lex.europa.eu/eli/reg/2006/1907/oj
• Regulation (EU) 2019/1020 on market surveillance and compliance of products: https://eur-lex.europa.eu/eli/reg/2019/1020/oj
• European Commission, Steel and Metals Action Plan, COM(2025) 125, 19 March 2025: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0125
• EUR-Lex, register of delegated and implementing acts, for the current adoption status of measures under Regulation (EU) 2024/1781: https://eur-lex.europa.eu/homepage.html

About This Article

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