Digital Product Passport for metals

Not yet. The ESPR has been in force since 18 July 2024, but it sets no requirements for a product group on its own - those come in a delegated act per group. The Commission’s indicative timeline puts the iron and steel act at the end of 2026 and aluminium in 2027, and economic operators get at least 18 months after adoption. So the duty is expected in 2028, and every one of those dates can move. What will not move is the data work behind it.

They do not, at least not in the legal text. CBAM asks an importer for the emissions embedded in a consignment, computed by the rules of Regulation (EU) 2023/956 and its implementing acts. The passport will ask for a product carbon footprint under the method the ESPR act sets. The two numbers come out different because the boundaries differ, and stating them as one invites the audit question you cannot answer. Keep both, label each with the rule it follows, and note the source of every figure.

Yes, and twice over. Whoever brings steel or aluminium into the EU places it on the market, so the future passport duty attaches to the importer just as it does to 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 third-country mill supplies neither the emission data nor the passport data, you have to obtain both by contract, and that takes far longer than the technical setup.

No. Regulation (EU) 2025/2083 replaced the old value threshold with a single mass threshold of 50 tonnes per calendar year, counted cumulatively across iron and steel, aluminium, cement and fertilisers. Stay below it and the obligations of the mechanism do not apply to you that year. Watch the running total, though - the threshold is cumulative, and exceeding it puts the full authorisation duty on you.

No. Steel is sold by grade, dimension, delivery condition and heat, not by a retail barcode, and no rule requires one. In Transpareo a product without a GTIN gets a unique Transpareo identifier, and the QR code leads to the passport just the same; the manufacturer part number carries your own article key alongside it. If you do have a GTIN, the identifier becomes a GS1 Digital Link that other systems resolve too. More on this in products without a GTIN.

All three are possible, and the question is commercial rather than technical. A passport per grade and delivery condition is the least work and matches how a catalogue is keyed. A passport per heat is what your customers actually want, because the mill certificate, the carbon figure and the scrap share belong to a heat, not to a grade. Transpareo supports batch-level and item-level passports with serial identifiers, so you can start at grade level and go deeper where a customer pays for it.

You decide, field by field. Visibility is a property of every data field in Transpareo - a value is public without any login, or restricted to a tier that readers reach through logged access. In practice the grade, the dimensions and the recycled share go public, the inspection certificate and the detailed emission data go to buyers and authorities. The same QR code shows each reader what they are entitled to see.

The delegated act will settle that, and it has not been adopted yet. What is already clear from the working plan and the preparatory work is the direction - the scrap share of the primary route and the secondary route reported separately, and pre-consumer scrap distinguished from post-consumer scrap. Most producers can name the first number today and not the second. Start collecting scrap grade and origin from your suppliers now; the field in the passport is the easy half.

The ESPR ties the lifetime of a passport to the lifetime of the product, and structural steel outlives most software contracts by decades. The duty therefore survives any change of provider, which is why the question to ask every supplier is what happens to your passports after a cancellation. With Transpareo, published passports stay reachable through a permanent address, and our provider checklist names the further questions worth asking.

Under CBAM the penalty attaches to certificates not surrendered, and the member states set the amounts; under the ESPR the member states will do the same for a missing passport. In both cases the expensive part is not the fine. A consignment without a CBAM authorisation does not clear customs, and from the passport deadline a product without a passport may not be placed on the market at all - for a mill that is a rolling programme standing still, not a line item.