Every downstream passport starts with the material. A car, a building, a machine and a battery all inherit the data of the steel inside them — its origin, its carbon, its recycled content. That is why the first Digital Product Passport delegated act expected under the ESPR is not for a consumer product at all: it is for iron and steel, the intermediate product the rest of industry is built from.

Why steel is first

The Commission’s first ESPR and Energy Labelling Working Plan 2025–2030 (COM(2025) 187 final, 16 April 2025) ranks iron & steel first among intermediate products — aluminium follows in 2027 — and gives the reasons in its own table: an EU market of EUR 152 billion (2023) and “high potential to improve the impacts on climate change, energy consumption, water, air”. The Working Plan adds that ESPR measures on steel will complement the green steel label announced in the Clean Industrial Deal and the existing climate measures on steel production, the EU ETS and CBAM. Steel is first because it is the largest carbon-intensive material flow in the plan, and the one whose data every other sector will need.

The timeline, read honestly

The Working Plan gives indicative adoption of the iron and steel delegated act in 2026; the Commission’s planning points to the fourth quarter of 2026, and its public consultation on the steel requirements closed on 12 August 2026. Three cautions, because dates deserve to be read at the source. Indicative adoption is a planning signal, not a legal deadline. Adoption is not application: under Article 4 of the ESPR, a delegated act’s date of application “shall not be earlier than 18 months from its entry into force”, except in duly justified cases — so even a late-2026 adoption normally means obligations from 2028 at the earliest. And no steel passport is mandatory today: the duty, the dataset and the granularity will exist only when the delegated act says so — enough to start the data work, not enough to guess the final field list.

An intermediate product: data that must travel

Steel is an intermediate product: it is rarely the final product — it is inside final products. The Working Plan treats that as the central design problem: regulating intermediate products “could have consequences not only on the manufacturing of intermediate products but also on all final products made from these intermediate products”, so the options being assessed include setting only information requirements for steel. Read that as the architecture of the steel passport: its first job is to make material data — identity, composition, carbon, recycled content — available in structured form, so downstream manufacturers can build their own passports on it. A coil’s data has to outlive the coil: it is cut, formed and welded into products whose passports will cite it.

What the steel passport will have to carry

Only the delegated act will fix the list. But the families are already named by its framework — Article 5 product aspects and Article 7 information requirements, applied to steel:

Steel passport — data families to organise now

  • Identity and traceability: a persistent unique product identifier connected through a data carrier (Article 10), at the level the act sets — for an intermediate product the natural unit is the batch or heat, and the coil or bundle it produces. Steel already travels with mill certificates; the passport digitises that record;
  • Carbon footprint: Article 5(1)(o) names carbon and environmental footprint as product aspects — for steel, the embedded emissions of the production route, per tonne of product;
  • Recycled content and recyclability: Article 5(1)(k) and (m) — for steel, the scrap share and its quality;
  • Composition and substances of concern: tracked through the life cycle under Article 7(5) — alloying elements and the substances the act will list;
  • Origin: the mill and the production site — what downstream claims and CBAM declarations both depend on.

None of this is a final checklist — only the delegated act can make it one. Collecting it now is refusing to let evidence expire: heats are melted and shipped every day, and their data cannot be reconstructed next year.

CBAM: the same data, a different job

Steel already has one EU carbon data regime in force. The Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956, covers the iron and steel goods in its Annex I: after a transitional reporting phase (October 2023 to end-2025), its core obligations apply from 1 January 2026 — authorised declarants, declared embedded emissions, CBAM certificates priced on the EU ETS. CBAM is a border carbon price on imports. The ESPR passport is product information for products placed on the EU market, EU-made and imported alike. Different instruments, one data backbone: embedded emissions per tonne, production route, precursor inputs and the identity of the producing installation are the same facts, collected once and used twice. A steelmaker that organises its data for CBAM and the ETS has done most of the heavy lifting a steel passport will ask for.

What steel makers and buyers should do now

  • Map your flow: list your steel products against the Working Plan’s intermediate-products scope, and track the delegated-act file as your real calendar, as we map in our ESPR timeline.
  • Collect per batch, not per year: route, scrap share, emissions and composition live at heat level; annual averages will not feed a passport.
  • Digitise the mill record: certificates and test data in structured, identifier-linked form — the passport is that record, machine-readable and durable.
  • Align methods once: one emissions accounting for CBAM, ETS and passport — one carbon number per tonne, everywhere.
  • Contract for data: downstream buyers will ask for passport-ready data, as in the textile wave; suppliers who deliver it structured win the specification.

How Ledger Consortium helps

Ledger Consortium aggregates the product data held by you and your suppliers — for steel, the batch-level data above — anchors each passport record on a governed blockchain, timestamped and tamper-evident, and keeps it updated as delegated acts land. Anchoring proves a record existed and has not been altered; it does not certify that the data a client supplied was true — accuracy remains the responsibility of the operator placing the product on the market. Costs are predictable, there is no token and no crypto exposure, and the platform is GDPR- and eIDAS-aligned. In Italy, the Ledger DPP is distributed by Il Sole 24 Ore (Valore24), whose channel onboards dozens of companies per month. See a working passport in our live demo and browse the other analyses in News.