EU Iron & Steel
Digital Product Passport
The Ecodesign for Sustainable Products Regulation (ESPR) and the Carbon Border Adjustment Mechanism (CBAM) together create mandatory carbon disclosure and traceability requirements for iron and steel products placed on the EU market from July 2026.
What an iron & steel DPP must contain
Under ESPR and the CBAM framework, a compliant iron and steel product passport must expose product identity, embedded carbon, recycled content, and supply chain traceability — machine-readable, accessible via QR code, and verifiable by customs authorities.
Product Identification
Unique product identifier, product name, steel grade designation (e.g. EN 10025, ASTM A36), dimensions, and surface finish. Accessible via QR code or data matrix on the product or packaging.
MandatoryMaterial Composition
Chemical composition by element (Fe, C, Mn, Si, P, S, Cr, Ni, Mo, etc.) within declared tolerances, conformance to EN or ISO steel standard, and heat treatment condition.
MandatoryEmbedded Carbon Footprint
Lifecycle embedded carbon in kg CO₂e per tonne of steel, declared per production batch. Includes Scope 1 and 2 emissions from steelmaking process route (BF-BOF, EAF, DRI-EAF). Required for CBAM declarations.
MandatoryRecycled Content
Percentage of recycled steel (post-consumer scrap) by weight. EAF route typically 90–100% recycled; BF-BOF route typically 20–30%. Required for ecodesign compliance and green procurement claims.
MandatoryManufacturing Facility
Name and address of the steel production facility, EU Economic Operator identifier (EORI), country of origin of raw materials, and steelmaking process route (blast furnace, electric arc furnace, DRI).
MandatoryCBAM Authorisation
CBAM declarant authorisation number, EU importer EORI, and the CBAM embedded emissions value used for the quarterly CBAM declaration. Links the product DPP to the customs obligation.
MandatoryHazardous Substances
Surface coatings and treatment chemicals (zinc, chromates, oils) present above threshold concentrations, REACH SVHC declarations, and restriction compliance under RoHS where applicable.
RecommendedEnd-of-Life & Recyclability
Recyclability rate of the product at end of life (typically >95% for steel), disassembly instructions for coated or composite steel products, and scrap classification under EU waste codes.
RecommendedCBAM carbon data — linked to your DPP
PassportLab connects CBAM-compliant embedded emissions data directly into your product passport. Importers, customs authorities, and downstream manufacturers can read verified carbon intensity from the same QR code as the product specification.
CBAM embedded carbon integration
PassportLab stores embedded carbon values per batch and links them directly to CBAM declarations. Importers can pull verified carbon data from the DPP QR code at the EU border, reducing manual reporting effort.
Heat/batch traceability
Link each DPP to a specific production heat or batch number. Downstream manufacturers and steel service centres can trace the exact melt from which their material came — with mill test certificate evidence attached.
GS1 Digital Link & customs-ready QR
Every steel DPP QR code is a standards-compliant GS1 Digital Link — readable by EU customs scanners, GTIN-connected to global trade item registries, and resolvable to the full DPP in any browser.
W3C Verifiable Credential signing
Carbon footprint and material composition declarations are signed with Ed25519 and issued as W3C VC v2.0 credentials. EU customs and notified bodies can independently verify claims without calling PassportLab.
Iron & Steel DPP — key dates
Carbon Border Adjustment Mechanism transitional phase started for iron & steel, cement, aluminium, fertilisers, electricity, and hydrogen. Quarterly embedded emissions reporting required from importers — no financial payments yet.
CBAM certificates become payable. EU importers of iron and steel must purchase CBAM certificates matching the carbon price that would have been paid under EU ETS for the embedded emissions in imported goods.
ESPR Digital Product Passports become mandatory for iron and steel products in scope of the delegated acts. QR-code-accessible product data including carbon footprint and recycled content must be published.
Free allocation of EU ETS allowances to domestic producers is fully phased out. CBAM provides full carbon equalisation for imported steel. DPP data requirements may expand based on ESPR review.
Sources: Regulation (EU) 2024/1781 (ESPR) and Regulation (EU) 2023/956 (CBAM). View all ESPR deadlines →
Iron & Steel DPP — FAQ
What is CBAM and how does it relate to an iron & steel DPP?
CBAM (Carbon Border Adjustment Mechanism) is an EU carbon tariff on imports of carbon-intensive goods including iron and steel. Importers must declare the embedded emissions in imported goods and purchase CBAM certificates. The iron & steel DPP acts as the product-level data carrier for the embedded carbon values used in CBAM declarations — linking the physical product to the emissions obligation.
Which iron and steel products are in scope for ESPR?
ESPR applies to iron and steel products used in construction (structural sections, plates, coils, tubes) and in manufacturing as intermediate products. The exact scope is defined in delegated acts. Products already covered by other product-specific regulations (e.g. construction products under CPR) may have overlapping requirements.
What counts as 'embedded carbon' for CBAM purposes?
CBAM embedded carbon covers Scope 1 and Scope 2 CO₂ emissions from the production of the steel: direct process emissions (blast furnace, EAF) plus electricity and heat consumed. For complex products containing steel as a component, the embedded carbon of the steel input is included in the product's CBAM declaration.
Does a mill test certificate (EN 10204) count as a DPP?
No. A mill test certificate (MTC) under EN 10204 3.1 or 3.2 documents mechanical and chemical properties at the time of production but is a static PDF document. An ESPR DPP is a machine-readable, QR-code-accessible, live data record that must be accessible throughout the product lifecycle and include additional ecodesign data not present in an MTC.
How does recycled content affect CBAM obligations?
Steel produced via the electric arc furnace (EAF) route using scrap typically has 60–80% lower embedded carbon than blast furnace (BF-BOF) steel. Under CBAM, lower embedded carbon means fewer certificates to purchase. Declaring accurate recycled content and process route in the DPP directly reduces the importer's CBAM cost and provides a competitive advantage for low-carbon steel.
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