Digital Product Passport for iron and steel
Iron and steel are intermediate products rather than consumer goods, which makes this group unusual — and it carries the earliest indicative date in the whole working plan.
Short answer. Iron and steel have the earliest indicative delegated act date of any ESPR group — 2026 — and are one of only two groups where the Commission confirms preparatory work has begun. With under six months of 2026 remaining and no draft published, treat that date as at real risk of slipping.
What is in scope
Iron and steel are listed as intermediate products, not final ones. ESPR explicitly covers components and intermediate products, which is what makes this possible — and what makes it different from every consumer-facing group.
For most PrestaShop merchants this group matters indirectly. You are unlikely to sell steel as such. But if you sell finished goods with significant steel content, a steel passport upstream is where the embodied carbon and recycled content figures in your eventual passport will come from.
That is the strategic point of sequencing intermediates first: you cannot populate a furniture or appliance passport with credible material data unless the materials themselves carry passports.
Timeline for Iron & steel
- 16 April 2025 Working plan names iron and steel as a priority intermediate product, indicative act 2026 — the earliest of any group.
- As of July 2026 Preparatory work confirmed under way for steel and textiles only. No draft act published. With under six months left in the year, 2026 looks at risk.
- 2027 or later Realistic adoption window if the indicative 2026 date slips, which on current evidence appears likely.
Data the passport has to carry
No delegated act exists for this group, so the product-specific field list does not yet exist. What is fixed is the ESPR framework's own Annex III data elements, which every passport must carry whatever the product. Those are listed below, together with the group-specific parameters the Commission has signalled.
Anything marked Expected is informed anticipation for data-collection planning, not a specification.
| Field | What it means in practice | Status |
|---|---|---|
| Unique product identifier | Persistent, connected to a data carrier on the product, its packaging or accompanying documentation. | In force |
| Unique operator identifiers | Manufacturer, other operators in the chain, and the EU-established responsible operator. Plus unique facility identifiers. | In force |
| Commodity codes | TARIC or equivalent, used at the customs verification step. | In force |
| Compliance documentation | Declaration of conformity, technical documentation, conformity certificates. | In force |
| Substances of concern | Name or code, location within the product, concentration or range, safe-use instructions and end-of-life handling. Framework-level under Article 7(5). | In force |
| Grade & specification | Steel grade against established standards — already well structured in this industry. | Expected |
| Embodied carbon | Steel is among the most carbon-intensive materials in general use, and this is the field the act most obviously exists to surface. | Expected |
| Recycled content | Scrap input share. Electric arc furnace and blast furnace routes differ enormously here. | Expected |
| Production route | Blast furnace versus electric arc versus direct reduced iron — the primary determinant of footprint. | Expected |
| Alloying elements | Composition affecting both performance and recyclability. | Expected |
What this means if you sell steel products on PrestaShop
Few PrestaShop merchants sell steel directly. This page exists because the group matters to merchants who sell things made of steel, and because it is the leading indicator for the whole ESPR programme.
Watch it for two reasons. First, it will be the first real ESPR delegated act, and its structure — how it defines fields, access tiers and data carriers — will set the template that consumer product acts follow. Second, whether it lands in 2026 or slips tells you how much confidence to place in every other indicative date on the working plan, including the textile one you may actually care about.
If it slips, plan on textiles slipping too.
How to prepare now
Use it as a bellwether, not a project
Unless you sell steel products, there is nothing to implement. Track whether the act appears, and read it when it does — it is the cheapest possible preview of what your own group's act will look like.
If you do sell steel products
Ask your suppliers now about production route and scrap input share. Both are known upstream, and neither is typically passed downstream today.
Questions
Why is an intermediate product first?
Will the 2026 date hold?
Does this affect me if I sell steel kitchenware or tools?
Sources
Other product groups
Batteries
The only product group with a binding passport date already set. LMT, EV and industrial batteries above 2 kWh, from 18 February 2027.
Textiles & apparel
First named priority under ESPR, and already subject to the unsold-goods destruction ban that took effect in July 2026.
Tyres
A priority group with an indicative 2027 act, and one that already carries mandatory EU labelling.
Get the data before you need the passport
Whatever your product group, the bottleneck is the same: supplier data you do not have yet. The readiness checklist tells you what to start asking for.