Digital Product Passport for metals
The Digital Product Passport for metals is expected for steel in 2028 and for aluminium a year later. The CBAM carbon duty has applied since 2026.
Where Transpareo supports you
For steel and aluminium, every product needs a passport once its act applies. Transpareo is the DPP platform on which mills, rolling mills and importers create and publish their product passports for metals. Below each card is the section that says more about it.
CBAM and the future passport both ask about carbon, each by its own rules. In Transpareo you keep both values as fields of their own, each labelled with its method.
Customers ask for the scrap share, split by origin. Transpareo keeps the recycled-content declaration on the passport and the scrap input as a component of its own.
Every delivery travels with an EN 10204 certificate, often with an environmental product declaration too. The steel template brings fields for both, the certificate at first for entitled readers only.
Steel is sold by grade and heat, without a retail barcode. Transpareo issues an identifier of its own and produces the QR code for the tag or the plate.
The carbon figure and the scrap share belong to a heat. In Transpareo you keep the passport per grade, batch or item, and a batch keeps the values it had.
Importers need emission and passport data from mills outside the EU. With Transpareo Upstream the mill enters its values itself, and you check every one.
Everyone may see the grade and the recycled share, only buyers and authorities the certificate and emission details. In Transpareo you set this for every field.
Years later, customers still check which values applied to their delivery. Every publication is signed and verifiable with the Transpareo Time Machine.
What is coming for steel and aluminium producers
The digital product passport for metals arrives from two directions at once, and the two do not arrive on the same day. Transpareo is the DPP platform on which steel and aluminium producers keep both sides in one dataset today.
What is still moving
The first direction is the Ecodesign Regulation. It has been in force since 18 July 2024 and covers intermediate products too, such as coils, plates and ingots. In the first working plan iron and steel and aluminium have priority.
The working plan of 16 April 2025 puts the iron and steel act at 2026 and the aluminium act at 2027. Both years are indicative.
For iron and steel the work is under way. From 20 May to 12 August 2026 companies could comment on the planned initiative. The Commission plans adoption for the fourth quarter of 2026. It has not published a draft yet.
The initiative is also to define low-carbon steel. The proposal for the Industrial Accelerator Act of 4 March 2026 needs that definition. It would bind public buyers to low-carbon requirements for steel and aluminium. Parliament and Council are still negotiating it.
After adoption, at least 18 months usually pass before the duty applies. That is where the 2028 above comes from. It is an expectation drawn from a published roadmap.
What already applies today
The second direction is the Carbon Border Adjustment Mechanism, CBAM for short, and it already applies. Its transitional reporting phase ran from 1 October 2023. On 1 January 2026 the definitive period began.
CBAM is already law; the passport act is not yet.
Since then only an authorised CBAM declarant may import steel or aluminium into the EU. The emissions embedded in each consignment are reported. From 1 February 2027 the member states sell the certificates for them.
From 1 February 2027 the embedded emissions cost certificates.
The CBAM simplification of 2025 took the edge off. Whoever stays below 50 tonnes a year is exempt entirely. The threshold counts steel, aluminium, cement and fertilisers together. The annual declaration is due by 30 September, for the first time in 2027 for the year 2026.
What this page covers
This page is your reference work on the digital product passport for steel and aluminium. The timeline lists the dates of both regimes. Then come the roles, the required data and the official sources. A sample spreadsheet shows what a heavy plate looks like in the import. At the end are the questions steel and aluminium producers ask us most often. Words underlined with dots show the wording of the provision.
From the rules to the passport
In the diagram the rules for your metal are grey. Teal is the data from plant and laboratory you already hold for them. Blue shows the Transpareo product passport with its reading tiers.
The three biggest hurdles in practice
- Two carbon numbers for one product: CBAM computes the emissions of a consignment by its own rules. The passport act will ask for a carbon footprint by another method. The numbers will differ. A customer who receives both without a label asks which one is true. In Transpareo you create a field for each number and name its method.
- No GTIN, and no single unit: steel is keyed by grade, dimension, delivery condition and heat. Whether your passport describes a grade, a heat or a plate is a commercial decision. You make it before the data model. Transpareo keeps passports at all three levels.
- The scrap chain ends where your records end: the recycled share is only as good as the documented scrap grade and origin. Most producers state the input share today. Almost none split pre-consumer from post-consumer scrap. With a supplier request you bring your scrap suppliers’ figures straight into Transpareo.
More on this: Carbon footprint in the DPP: which method to choose? and Products without a GTIN.
Regulatory timeline for steel and aluminium
The key dates of the rules that apply to steel and aluminium or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 1 January 2021Conflict-minerals due diligence applies
Union importers of tin, tantalum, tungsten and gold run a management system, assess risks, have themselves audited and report publicly. Regulation (EU) 2017/821 requires it. Steel and aluminium are not covered, but imported alloying metals such as ferro-tungsten are.
- 1 October 2023CBAM transitional period starts
Importers of steel and aluminium report the emissions embedded in every consignment each quarter. No certificates are bought yet, and no money changes hands.
- 18 July 2024ESPR enters into force
Regulation (EU) 2024/1781 becomes the framework for ecodesign and the digital product passport. It covers intermediate products too. A steel coil and an aluminium ingot are exactly that.
- 16 April 2025Working plan names iron, steel and aluminium
The first ESPR and Energy Labelling Working Plan 2025-2030 lists iron and steel and aluminium as priority intermediate products. It gives 2026 and 2027 as indicative years. The duties only arrive with the delegated acts.
- 1 January 2026CBAM definitive period
Only an authorised CBAM declarant may still import covered goods. Regulation (EU) 2025/2083 exempts importers below 50 tonnes a year from the whole mechanism. The threshold counts steel, aluminium, cement and fertilisers together.
- May to August 2026Consultation on the iron and steel act
From 20 May to 12 August 2026 the Commission collects feedback on ecodesign requirements for iron and steel products. The initiative is also to define low-carbon steel. No draft of the act has been published yet.
- 20 July 2026EU DPP register operational
The central register of the ESPR starts operating, with a test environment. Implementing Regulation (EU) 2026/1778 sets out how it works. Every product passport is registered there once the act for its product group applies.
- Expected Q4 2026Delegated act for iron and steel
The Commission plans to adopt the iron and steel act in the fourth quarter of 2026. It has not been adopted yet. So nothing in it is final.
- 2027CBAM certificates and the first declaration
Certificates go on sale from 1 February 2027. The declaration for the 2026 import year is due by 30 September 2027, as amended by Regulation (EU) 2025/2083. The aluminium act is expected in the same year.
- Expected 2028Passport duty for steel
After a delegated act, at least 18 months usually pass before its passport requirements apply. With an act at the end of 2026 that lands in 2028. Aluminium follows a year behind. Both dates hang on acts that do not exist yet.
Who is affected?
Duties for steel and aluminium: what falls on each economic operator on the way to the market.
Creates the passport for the grade and delivery condition it places on the market. The carbon figures come from its own installation, and it keeps them current. The passport data has to be accurate, complete and up to date. Only the mill can hand the scrap share and the mill certificate down the chain.
Whoever brings steel or aluminium into the EU places it on the market and carries two duties. One is the passport for the product. The other, above 50 tonnes a year, is the authorisation, the declaration and the certificates under CBAM. Mills outside the EU rarely supply either without a contract clause. From 21 September 2027 the new Union Customs Code applies. The importer then also answers for the product rules customs apply. For distance sales to consumers, the seller or the marketplace is the importer.
Cuts, slits and stocks material without changing its grade. Maintains no carbon figures of its own. It does keep the passport of every heat reachable and passes the mill certificate on with the delivery.
Delivers the input the recycled-content figure is made of. Without a documented scrap grade and origin, the producer cannot state a recycled share that survives an audit. With a supplier request in Transpareo, the scrap supplier enters both itself.
What goes in the DPP for steel and aluminium?
Data fields for steel and aluminium: the key ones the relevant EU regulation requires.
Cradle-to-gate per tonne, with the method, the system boundary and the share of primary data. CBAM asks the same question under different rules. So both numbers belong in the passport, each labelled with the rule it follows.
The scrap share fed into the primary process and the share of the secondary route, stated separately. Pre-consumer and post-consumer scrap are different numbers. They are rarely reported as one.
Whoever imports tin, tantalum, tungsten or gold as ore or metal carries supply chain due diligence duties. For steelworks that means ferro-tungsten or tin for tinplate, for example. It takes a management system, a risk assessment, a third-party audit and an annual report.
Melting shop, rolling mill and heat number belong here. Then come the documents a delivery already travels with. These are the EN 10204 inspection certificate, an environmental product declaration and scheme certificates such as ResponsibleSteel or ASI.
Checklist for steel and aluminium
The EU has not yet published which data points a product passport for steel and aluminium has to carry: the act that fixes them is pending. As soon as it is public, a checklist for Metals appears here, as a page and as a PDF, the way the battery checklists follow the regulation text today. Until then, the required data above and the official documents below are the reliable guide.
Downloads
The sample spreadsheet is the Transpareo template for steel and aluminium: the data the current rules already ask for and the fields a passport usually carries, as our data model, not as the delegated act. Open it next to your own product data, no account needed; we adjust the template when the act lands.
Sample row for steel and aluminium, filled in and with every column the import expects.
15 columns, sample values included
Transpareo for steel and aluminium
Transpareo is the DPP software for producers and importers of steel and aluminium. The steel template brings fields for the inspection certificate, the recycled-content declaration, the environmental product declaration, the declaration of conformity and the technical documentation. You create the product carbon footprint and the CBAM emissions as two fields of your own, each with a unit. So every figure stays with its rule.
You keep the scrap input as a component of its own, with grade and origin. Mills and scrap suppliers enter their values themselves through a supplier request. You review every value before it goes into the passport.
You publish passports per grade, batch or item. A batch keeps the values that applied when it was created. Each field has its own visibility, and every reader sees only their tier.
Your data comes in through the web interface, by Excel import or through the API. The sample spreadsheet above is a heavy plate in S355J2+N with every column of the import, including the components sheet for the scrap input. Every publication carries a signature, and older states stay retrievable. Everything exports at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for steel and aluminium
Is the DPP for steel already law?
Not yet. The Ecodesign Regulation has been in force since 18 July 2024. It sets requirements for a product group only through a delegated act. The Commission plans the iron and steel act for the fourth quarter of 2026 and the aluminium act for 2027. After that, at least 18 months usually pass. So the duty is expected in 2028, and every one of those dates can move. The data work behind it stays the same. In Transpareo you can start on it today.
How do CBAM and the product passport fit together?
In the legal text they do not. CBAM asks an importer for the emissions embedded in a consignment. It computes them by its own rules and implementing acts. The passport will ask for a product carbon footprint, computed by the method its act sets. The boundaries differ, and so do the numbers. Stating both as one invites an audit question you cannot answer. Keep both, label each with its rule and record where it came from. In Transpareo each figure becomes a field of its own.
Does this apply to importers too?
Yes, and twice over. Whoever brings steel or aluminium into the EU places it on the market. So the future passport duty reaches the importer just as it reaches a European mill. CBAM lands on the importer alone. Since 1 January 2026 only an authorised CBAM declarant may import the covered goods. If your mill supplies neither emission data nor passport data, obtain both by contract. That takes far longer than the technical setup. With a supplier request in Transpareo, the mill enters its passport data itself.
We import less than 50 tonnes a year. Does CBAM still concern us?
No. The 2025 simplification replaced the old value threshold. Today a mass threshold of 50 tonnes per calendar year applies. It counts iron and steel, aluminium, cement and fertilisers together. Stay below it and the obligations of the mechanism do not apply to you that year. Watch the running total, though. Whoever exceeds the threshold carries every obligation for all imports of that year.
Do I need a GTIN?
No. Steel is sold by grade, dimension, delivery condition and heat, and no rule requires a retail barcode. The passport needs a persistent unique product identifier. Without a GTIN, Transpareo issues an identifier of its own, and the QR code leads to the passport just the same. Your manufacturer part number carries your own article key alongside it. If you do have a GTIN, the identifier becomes a GS1 Digital Link. More on this in products without a GTIN.
Passport per grade, per heat or per plate?
All three are possible. Which level applies is for the act to set. Until then the question is a commercial one. A passport per grade and delivery condition is the least work and matches your catalogue. A passport per heat is what your customers actually want. The mill certificate, the carbon figure and the scrap share belong to a heat. Transpareo keeps passports per grade, batch or item. You start at grade level and go deeper where a customer pays for it.
Who sees the carbon figure and who sees the mill certificate?
You decide, field by field. In Transpareo every data field has its own visibility. The tiers are public, on request, legitimate interest and authorities. The grade, the dimensions and the recycled share usually go public. The inspection certificate and the emission details go to buyers and authorities. The same QR code shows each reader what they are entitled to see.
What does the recycled-content figure have to cover?
The delegated act will settle that, and it has not been adopted yet. The direction is emerging, though. The primary and the secondary route are reported separately, and pre-consumer scrap is told apart from post-consumer scrap. Most producers can name the first number today, hardly any the second. Start collecting scrap grade and origin from your suppliers now. The field in the passport is the easy half.
How long does the passport have to stay available?
The Ecodesign Regulation ties the period at least to the expected lifetime of the product. Structural steel outlives most software contracts by decades. So the duty outlives any change of provider. Check before you sign what becomes of your passports if you cancel. With Transpareo, published passports stay reachable through a permanent address. What else to ask a provider is in our provider checklist.
What does non-compliance cost?
Under CBAM, EU law sets the penalty itself. For every certificate not surrendered the penalty of the EU emissions trading system applies. Whoever imports without an authorisation pays three to five times that. For a missing passport the member states set the penalties, and they have to be dissuasive. The fine is rarely the expensive part. Without a CBAM authorisation a consignment may not be imported. From the passport deadline a product without a passport may not be placed on the market. For a mill that means a rolling programme standing still.
Official documents
Legal sources for steel and aluminium to read for yourself: what each document is and when you need it.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation for the digital product passport. It sets what a passport is, who has to keep it and how the register works. What steel and aluminium have to put in one comes later, in their delegated acts.
- Commission initiative on iron and steel productsThe page of the planned delegated act on “Have your say”. It shows the consultation from 20 May to 12 August 2026 and the planned adoption in the fourth quarter of 2026. The draft appears here first.
- Regulation (EU) 2023/956 (CBAM)The carbon border adjustment mechanism itself. It covers the goods named in a list, and the definitive regime has applied since 1 January 2026. Read it before you sign a supply contract with a mill outside the EU.
- Regulation (EU) 2025/2083The 2025 simplification of CBAM. It introduces the 50-tonne threshold, postpones the sale of certificates to 1 February 2027 and moves the annual declaration to 30 September. The most important document for small importers.
- Regulation (EU) 2017/821 on conflict mineralsThe due-diligence duties for Union importers of tin, tantalum, tungsten and gold, in force since 1 January 2021. The regulation lists the covered ores and metals with their volume thresholds, ferro-tungsten among them. Relevant to steelworks through imported alloying metals.
- Implementing Decision (EU) 2026/1736 on the harmonised DPP standardsCites six harmonised standards, EN 18216 and EN 18219 to EN 18223, in the Official Journal. Whoever complies with them enjoys the presumption of conformity for the passport’s identifier, data carrier, storage and interfaces.
- DPP page of the European CommissionThe official roadmap for the product passport, including the indicative year of each delegated act and the state of the register. The place where date changes appear first.
- CBAM page of the European CommissionGuidance, forms and the authorisation procedure for CBAM declarants, maintained by the Directorate-General for Taxation and Customs Union. Start here if you import rather than produce.
Further reading on our blog
A pragmatic guide to the carbon footprint methods the ESPR accepts. It compares life-cycle assessment, environmental declarations and system boundaries.
Construction products without a GTIN get their passport via batch IDs. How that works for cement, bricks and steel beams.
The EU register for Digital Product Passports became law on 16 July 2026. What it asks of you, and what we prepare for you.
Six harmonised DPP norms are set in stone. The target has stopped moving, and we already meet it.
Ready for your steel and aluminium passports?
Set up your passports for steel and aluminium today. By the time the obligation takes effect, you have long been up and running.