Iron & Steel
The Digital Product Passport for Iron and Steel
Steel is ESPR's first delegated act candidate. Heat-level traceability, scrap ratio, embodied carbon and the overlap with CBAM.
Iron and steel is the first delegated act candidate in the ESPR Working Plan — not only because of the sector's environmental impact but because steel is an intermediate product: its data flows into thousands of finished goods, from cars to buildings to appliances.
Which data will be needed?
| Field | Description |
|---|---|
| Grade and standard | EN standard, quality code |
| Chemical analysis | Heat analysis (C, Mn, Si, S, P, …) |
| Mechanical properties | Yield, tensile, elongation |
| Production route | Blast furnace-BOF or electric arc furnace |
| Scrap ratio | Recycled input share |
| Embodied carbon | kg CO2e per tonne, with method declared |
| Origin | Facility identity, country |
| Heat number | The traceability key |
See DPP data fields and proving recycled content.
Heat-level traceability
In steel the natural traceability unit is the heat: all products from one heat share the same analysis and origin. That simplifies granularity — batch-level passports cover most scenarios. See choosing granularity.
Identity on the product itself is usually applied by direct part marking. See Data Matrix and DPM.
The CBAM overlap
CBAM requires embedded emissions to be declared for steel imports, and the DPP will require a carbon field in the passport. The two regimes may use different boundaries and methods, but they want the same plant data: energy consumption, production volumes, scrap ratio and process emissions.
Designing both as one data collection programme is the highest-return step available in this sector. See CBAM and the DPP and how to calculate a PCF.
What being an intermediate product means
For a steelmaker, customer demand arrives before regulation: automotive and construction customers need your data for their own passports. Your preparation calendar is therefore set by your customers, not by your own delegated act. See DPP in automotive and DPP for construction products.
Preparation steps
- Digitise heat-level records (in most plants they sit as PDF certificates).
- Move mill certificates (EN 10204 3.1 and similar) into structured fields.
- Make energy and scrap data reportable per plant on a regular cycle.
- Choose and document your embodied carbon methodology.
- Standardise customer data requests into one template.
Frequently asked questions
Does my mill certificate replace a passport?
No. A certificate is a document; a passport is a machine-readable, versioned, tiered record. But certificate content feeds the core of the passport.
How do I evidence the scrap ratio?
Through input records and mass balance. The EAF route naturally has a high ratio, but it still needs period-based accounting and declaration.
I export steel into the EU. What should my priority be?
CBAM reporting already applies; run DPP preparation on the same data.


