Iron and steel ecodesign consultation closes: what the JRC proposes for the steel Digital Product Passport

The first product group to get an ESPR delegated act is an intermediate product, not a consumer good. The Commission's public consultation on ecodesign requirements for iron and steel products closed on 12 August 2026. Its Iron & Steel page gives Q4 2026 as the indicative timeline for adopting the delegated act. The Commission's consultation notice framed the scope as circularity and recyclability, low-carbon steel, sustainability information and the related Digital Product Passport, and decarbonisation across the value chain.

For steel producers and importers, the most concrete picture of what the DPP will contain comes from the Joint Research Centre. Its Study on DPP content for iron and steel products under ESPR, a JRC Science for Policy Report by Aleksandra Arcipowska, Sara Blanco Pérez and Alejandro Lopez-Olmedo, was posted on the Product Bureau site on 23 March 2026 alongside the preparatory study, the substances-of-concern study, the recycled-content study and the life-cycle assessment and costing tasks. A second stakeholder consultation meeting followed on 13 April 2026. The report carries the standard JRC disclaimer that it does not necessarily reflect the position of the Commission.

Identification at heat level

The study's central design choice is granularity. It recommends the heat number as the mandatory batch-level unique product identifier, because the heat is the earliest point at which a product can be linked to a defined set of input materials and a technology route, and because EN 10168 mill test certificates already report at that level. The cast or lot number may be added as an optional batch identifier. The product number serves as the model-level reference. Item-level serial numbers would apply only to specific products, such as coils, where customer specifications already require them.

The readiness check behind this is blunt about cost. Implementing ESPR identifiers on existing labelling practices was assessed as relatively low effort. Introducing systematic item-level traceability where plants operate at batch level was assessed as significantly higher effort, with industry feedback pointing to investments of at least approximately EUR 100 000 per installation plus operating costs. QR marking on physical products was rated a medium effort. Stakeholders broadly supported heat-level identification as proportionate and saw limited added value in sector-wide item-level environmental traceability.

Environmental and circularity data

Two declarations are proposed as the environmental core of the steel passport:

• Recycled content: the proposal builds on ISO 14021 and existing industry practice, declaring the recycled content percentage and the split between pre-consumer and post-consumer material.
• Product carbon footprint: the methodology under development within the ESPR framework aligns greenhouse gas accounting with the EU ETS and CBAM data frameworks and aims to be fully interoperable with EN 15804 and Environmental Product Declarations.

The study is careful to say that both methodologies are being developed in parallel workstreams and that the granularity of these declarations depends on the final method. Under the more ambitious chain-of-custody option, controlled blending, recycled content could be tracked at batch level. Mass-balance approaches would push reporting towards site-level averages over a period, an intermediate aggregation that is neither a model nor a batch.

The proposed data structure

The summary table in the report sets product identification and classification, producer identification and origin (including country of origin and melt-and-pour at batch level), material compliance and substances of concern at batch level, and the environmental declarations at batch or model level. Classification fields such as ESPR category, steel grade and designation sit at model level. Identification data are proposed as publicly accessible. The report notes there is no widely adopted ontology for mill test certificate data and calls that a key enabler for efficient exchange.

What to do now

• Map your current mill test certificate fields (EN 10204 and EN 10168) to the proposed DPP categories. Most of the identification and technical data already exists there.
• Decide now whether your ETS and CBAM data flows can feed a product-level carbon footprint at heat level, and document the gaps.
• Follow the delegated-acts tracker and the consultations page. Adoption in Q4 2026 would put the earliest application date in 2028 given the ESPR's minimum 18-month transition.

Primary sources: Commission consultation notice; Commission Iron & Steel page; JRC Product Bureau, iron and steel documents; Study on DPP content for iron and steel products under ESPR.