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

> A legally disciplined guide to Digital Product Passports for iron, steel and aluminium: why these two groups sit first on the statutory priority list in Article 18(5) of Regulation (EU) 2024/1781, what it means that they are intermediate products rather than finished goods, why no product-specific passport obligation or data field list yet exists, how the carbon border adjustment mechanism already forces embedded emissions accounting on the same materials, and what producers, service centres, fabricators and buyers should build now.

## 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?](#what-would-a-steel-or-aluminium-passport-be)
* [Do Steel and Aluminium Already Require a Passport?](#do-steel-and-aluminium-already-require-a-passport)
* [Why Intermediate Products Change the Question](#why-intermediate-products-change-the-question)
* [Which Products Could Be Affected?](#which-products-could-be-affected)
* [Why Steel and Aluminium Are Difficult](#why-steel-and-aluminium-are-difficult)
* [What Information May Matter?](#what-information-may-matter)
* [Where Does the Data Come From?](#where-does-the-data-come-from)
* [Embedded Emissions and Carbon Accounting](#embedded-emissions-and-carbon-accounting)
* [Scrap, Recycled Content and Circularity Claims](#scrap-recycled-content-and-circularity-claims)
* [Material Identity: Heats, Casts, Coils and Cuts](#material-identity-heats-casts-coils-and-cuts)
* [Mill Certificates and Existing Documentation](#mill-certificates-and-existing-documentation)
* [Supplier and Evidence Requirements](#supplier-and-evidence-requirements)
* [Data Quality and Validation](#data-quality-and-validation)
* [Standards and Interoperability](#standards-and-interoperability)
* [Adjacent and Overlapping Regulation](#adjacent-and-overlapping-regulation)
* [Legal Responsibility](#legal-responsibility)
* [Enterprise Architecture](#enterprise-architecture)
* [SME Implications](#sme-implications)
* [Enterprise Implications](#enterprise-implications)
* [Preparing Before Final Requirements Exist](#preparing-before-final-requirements-exist)
* [What Not to Build Yet](#what-not-to-build-yet)
* [Pilot Strategy](#pilot-strategy)
* [Worked Example](#worked-example)
* [Common Mistakes](#common-mistakes)
* [Preparation Checklist](#preparation-checklist)
* [Frequently Asked Questions](#frequently-asked-questions)
* [References](#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.

A product data record that a product-specific delegated act adopted under Regulation (EU)
2024/1781 would require for a defined group of iron, steel or aluminium products, connected to a
persistent unique product identifier, reachable through a data carrier on the product, its
packaging or its documentation, and available to defined actors for a defined period. For steel
and aluminium the delegated act that would create such a requirement has not been adopted, so
every element of that description is currently unspecified for these materials.

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.

> **Read the framework, not the trade press**
>
> Articles 9, 10, 11, 12, 13 and 18 of Regulation (EU) 2024/1781 are short, and reading them settles
> most of the questions that circulate as rumour in metals markets. In particular, Article 18(5) is
> the source of the widely repeated claim that steel and aluminium are "first", and reading it shows
> exactly what that priority does and does not mean.

## 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.

| Instrument                                               | Status                                    | What it actually means for steel and aluminium businesses                                                                                                  |
| -------------------------------------------------------- | ----------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Regulation (EU) 2024/1781 (ESPR) framework               | **Binding EU law**                        | Framework in force; passport duties arrive only through product-specific delegated acts adopted under Article 4                                            |
| Article 18(5) priority listing of iron, steel, aluminium | **Binding on the Commission, not on you** | Statutory instruction to prioritise these groups in the first working plan. No product obligation, no date, no content                                     |
| Ecodesign and Energy Labelling Working Plan 2025-2030    | **Planning intention**                    | COM(2025) 187, adopted 19 April 2025. States the Commission's intended sequence of work. Creates no obligation and fixes no application date               |
| Delegated act for iron and steel                         | **Not adopted**                           | No passport requirement, no data content, no date                                                                                                          |
| Delegated act for aluminium                              | **Not adopted**                           | No passport requirement, no data content, no date                                                                                                          |
| Regulation (EU) 2023/956 (carbon border adjustment)      | **Binding EU law**                        | Iron and steel and aluminium are in Annex I. Reporting-only transitional period, definitive regime applying from 1 January 2026 with authorised declarants |
| Regulation (EU) 2024/3110 (construction products)        | **Binding EU law**                        | Its own digital regime for construction products, which includes structural steel and aluminium products. Separate from ESPR passports                     |
| Regulation (EU) 2024/1157 (waste shipments)              | **Binding EU law**                        | Controls on shipments of scrap metal, including export conditions, relevant to recycled input sourcing                                                     |
| Regulation (EC) No 1907/2006 (REACH)                     | **Binding EU law**                        | Substance registration and restriction duties relevant to alloying elements, coatings and surface treatments                                               |
| ResponsibleSteel, Aluminium Stewardship Initiative       | **Voluntary**                             | Private certification schemes. Evidence a company may choose to hold. Not EU law and not a passport                                                        |
| EN 15804 and ISO 14025 environmental declarations        | **Voluntary standards**                   | Product category rules and declaration formats. Legally relevant only where an adopted instrument references them                                          |

#### Reading the working plan as a compliance calendar

A working plan states what the Commission intends to work on and in what order. Preparatory
studies, consultation and impact assessment sit between a working plan entry and an adopted
delegated act. Any specific year attached to a steel or aluminium passport today is an estimate,
and treating it as a deadline means committing capital against an intention.

## 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.

A product that requires further manufacturing or transformation, such as mixing, coating or
assembling, to make it suitable for end users. The definition appears at Article 2(3) of
Regulation (EU) 2024/1781, and Article 1(2) confirms that the Regulation applies to components and
intermediate products as well as finished goods.

#### One tonne, four passports

A single heat of steel is cast, hot rolled, cold rolled, galvanised, slit into six coils, sold to
three customers, stamped into brackets, and installed in two different appliance models. If any of
those downstream products eventually carries a passport that states recycled content or embedded
emissions, the number that appears there is a property of the heat. The chain that connects the
heat to the bracket is the asset. The passport is only the display surface.

## 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.

| Product family                                               | Position                            | Planning note                                                                                               |
| ------------------------------------------------------------ | ----------------------------------- | ----------------------------------------------------------------------------------------------------------- |
| **Flat-rolled steel** (hot rolled, cold rolled, coated coil) | Squarely inside the framework scope | High volume, heat-based identity, already carries mill certificates and increasingly carbon data            |
| **Long steel products** (sections, rebar, wire rod, bar)     | Squarely inside the framework scope | Construction-heavy, so overlaps with the separate construction products regime                              |
| **Tubes, pipes and hollow sections**                         | Inside the framework scope          | Frequently re-processed by third parties, which weakens the identity chain                                  |
| **Stainless and specialty alloys**                           | Inside the framework scope          | Alloying element data is commercially sensitive and technically necessary at once                           |
| **Primary aluminium and remelted ingot**                     | Inside the framework scope          | Origin, smelter identity and electricity source dominate the environmental profile                          |
| **Aluminium extrusions and flat-rolled products**            | Inside the framework scope          | Alloy and temper identity is mature; recycled content accounting is not                                     |
| **Castings and forgings**                                    | Inside the framework scope          | Batch identity is natural, but input scrap traceability is weak                                             |
| **Semi-finished parts and fabrications**                     | Boundary                            | May be treated as components of the downstream product rather than as their own group                       |
| **Scrap and secondary raw material**                         | Different regime                    | Waste law governs it until end-of-waste; it is an input to passport claims, not obviously a passport holder |
| **Structural metal construction products**                   | Separate digital regime             | Regulation (EU) 2024/3110 has its own digital arrangements, distinct from ESPR passports                    |

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.

| Information area                             | Why it is plausible                                                          | Where it lives today                               |
| -------------------------------------------- | ---------------------------------------------------------------------------- | -------------------------------------------------- |
| Product identity and grade                   | Article 10 requires a persistent unique product identifier                   | ERP order and production records, mill certificate |
| Producer and facility identity               | Article 12 addresses operator and facility identifiers                       | Plant master data, certification records           |
| Chemical composition and alloy specification | Already stated on inspection certificates for most products                  | Laboratory and quality systems                     |
| Mechanical properties                        | Core existing certificate content                                            | Quality and testing systems                        |
| Process route (for example primary or scrap) | Determines almost every environmental property of the material               | Production planning and metallurgical records      |
| Embedded emissions and methodology           | Already computed for carbon border adjustment purposes for these materials   | Carbon accounting systems, verified reports        |
| Recycled content and its basis               | A recurring ecodesign parameter and a common procurement requirement         | Charge mix records, mass balance calculations      |
| Scrap input origin and quality               | Underpins any recycled content claim                                         | Purchasing, weighbridge and yard systems           |
| Substances of concern                        | Substance information is contemplated by the framework and required by REACH | Safety data, supplier declarations                 |
| Coatings and surface treatment               | Affects recyclability, substances and downstream processing                  | Process specifications                             |
| Recyclability and end-of-life handling       | Central to circularity objectives                                            | Technical documentation, sector guidance           |
| Conformity and standard references           | Existing product standards are already cited on certificates                 | Quality management systems                         |
| Verification and assurance status            | Distinguishes a self-declared figure from a verified one                     | Audit and verification reports                     |

#### Publishing a number without its method

A recycled content percentage or an emissions figure with no stated method, boundary, reference
period or verification status is not transparency. In metals it is the most common way for a
well-intentioned disclosure to become an unsupportable claim.

## 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.

| Origin class                  | Metals examples                                                          | Governance implication                                                 |
| ----------------------------- | ------------------------------------------------------------------------ | ---------------------------------------------------------------------- |
| **Declared by you**           | Grade, dimensions, product identity, plant of manufacture                | You own it. Failures here are master data failures                     |
| **Measured**                  | Chemical analysis, mechanical test results, mass                         | Instrument, sample and method must be recorded with the value          |
| **Calculated**                | Embedded emissions, recycled content, mass balance allocations           | The method and its inputs must be stored, not just the output          |
| **Supplied by others**        | Scrap composition, alloying element origin, upstream emissions factors   | Contractual data terms and refusal logging are the control             |
| **Attested by a third party** | Verification statements, certification scheme audits, test house reports | Bind the attestation to the exact claim and record its validity period |

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.

#### Record origin class alongside every value

Store, for every material property you hold, whether it was declared, measured, calculated,
supplied or attested, plus the date and the source. This single discipline converts a data
warehouse into a defensible compliance asset, and it is portable to any future field list.

## 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.

> **Reuse the carbon data model, not the carbon report**
>
> The valuable asset from carbon border compliance is the underlying model: goods identified
> precisely, emissions attributed to quantities, methods recorded, values verified, suppliers
> contractually obliged to provide inputs. Build passport readiness on that model. The report itself
> is an output format for one regulator and will not serve any other consumer.

## 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.

#### A mass balance figure presented as physical content

Saying that this coil contains sixty per cent recycled material, when the truth is that the plant
charged sixty per cent scrap across the quarter, is a factual misstatement about a specific
product. Publish the allocation method with the number, or publish the plant figure as a plant
figure.

## 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.

| Level                          | What it is                                           | Passport relevance                                           |
| ------------------------------ | ---------------------------------------------------- | ------------------------------------------------------------ |
| **Heat or melt**               | One furnace charge of liquid metal                   | Where composition and process route are genuinely determined |
| **Cast or batch**              | Material solidified from the heat                    | The natural anchor for most metallurgical properties         |
| **Coil, plate, ingot, billet** | A discrete physical object                           | The candidate unit for an item-level identifier              |
| **Slit or cut item**           | A subdivision produced later, often by a third party | The point at which most chains lose the link                 |
| **Delivered consignment**      | What the customer receives against an order          | The level at which customers and customs currently think     |

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.

#### Model division and merger explicitly

Represent subdivision and combination as first-class events, each with a timestamp, a quantity, a
parent and a child. Most metals data models fail because they can express "this coil is grade X"
but cannot express "this coil is the third slit output of that coil, which came from that cast".

## 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.

#### Assuming one passport satisfies every regime

Construction product duties, carbon border duties and any future ESPR passport are separate legal
obligations with separate scopes, actors and formats. Build one governed data foundation, then
publish to each regime. Building to one regime and assuming coverage of the others is how
programmes discover, late, that they must start again.

## 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.

> **Reconstructing identity from what you already have**
>
> Most mills and service centres already record charge mixes, cast numbers, coil numbers, slitting
> operations and delivery quantities, in separate systems, for operational reasons. The identity
> graph is usually an integration exercise over data that exists, not a new data capture programme.
> Costing it as the latter is why these programmes get rejected at budget stage.

## 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.

#### Justify every step commercially

Each of these nine actions can be justified today by customer data requests, carbon compliance,
procurement requirements or quality assurance. A passport programme that depends on a future
delegated act for its business case will not be funded, and does not need to be.

## 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.

#### The finding that repeats everywhere

In metals pilots the most common discovery is that the business knows what it made and knows what
it bought, but cannot connect the two, because the identity of the input is dropped at the point
of charging or processing. Every downstream data problem is a consequence of that single break.

## Common Mistakes

#### Steel and aluminium have a passport deadline because they are first on the list

Article 18(5) of Regulation (EU) 2024/1781 places iron and steel and aluminium first among the
product groups the Commission must prioritise. That is an instruction to the Commission. No
delegated act has been adopted for either group, so there is no obligation, no content and no
date.

#### Carbon border compliance means we are passport ready

The carbon border regime produced excellent emissions data and no product identity, no carrier, no
access model and no non-carbon content. It is the best available head start and it is not the
thing itself.

#### Our mill certificates already contain everything

They contain the information and not the data. A certificate that cannot be queried by a system,
or that covers a delivery containing several heats, cannot support product-level claims at any
scale.

#### Recycled content is a single number

Without the distinction between pre-consumer and post-consumer input, the mass balance basis, the
period and the verification status, a recycled content percentage is not verifiable and is easy to
overstate by implication.

#### We are an intermediate supplier, so this is our customers' problem

Intermediate products are explicitly in scope under Article 1(2), and in any case downstream
passports will be populated with data that only the metal producer holds. Being upstream defers
nothing.

#### A certification scheme membership proves material claims

Voluntary schemes attest to site and management practice. They do not state the composition, the
recycled content or the emissions of a specific consignment, and they are not EU law.

#### We will serialise everything so we are ready for any requirement

Serialising before the identity relationships exist produces a large number of unique codes
attached to records that still cannot say what the material is or where it came from.
Relationships first, identifiers second.

#### Construction steel is covered by the same regime

Construction products are governed by Regulation (EU) 2024/3110, which has its own digital
arrangements. Treating it as the same obligation as a future ESPR passport will produce a system
that satisfies neither cleanly.

## 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](/docs/knowledge-base/industry-guides/digital-product-passports-for-electronics)
* [Digital Product Passports for Furniture: What Companies Need to Know](/docs/knowledge-base/industry-guides/digital-product-passports-for-furniture)
* [Digital Product Passports for Textiles and Apparel: What Companies Need to Know](/docs/knowledge-base/industry-guides/digital-product-passports-for-textiles-and-apparel)
* [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport)
* [How Conformity Assessment Works for Digital Product Passports](/docs/knowledge-base/regulations/how-conformity-assessment-works-for-digital-product-passports)
* [How Digital Product Passports Will Be Enforced](/docs/knowledge-base/regulations/how-digital-product-passports-will-be-enforced)
* [How Does a Digital Product Passport Work?](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work)
* [What Are Delegated Acts?](/docs/knowledge-base/regulations/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](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](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](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](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](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](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](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](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](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](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](https://eur-lex.europa.eu/homepage.html)

## About This Article

About This Article

<dl>
  <dt>
    Last Reviewed
  </dt>

  <dd>
    2026-08-09
  </dd>

  <dt>
    Next Scheduled Review
  </dt>

  <dd>
    2027-08-09
  </dd>

  <dt>
    Article Version
  </dt>

  <dd>
    1.0
  </dd>
</dl>

tieback Knowledge is a continuously maintained reference library covering Digital Product
Passports, product traceability, product compliance and related regulations. Articles are
reviewed regularly as legislation, standards and implementation guidance evolve.

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