Digital Product Passport for Iron, Steel & Aluminium
Iron, steel and aluminium are among the most carbon-intensive materials in global production. Under ESPR, these materials are expected to be addressed in a later wave of sector rules, with passport requirements currently discussed for around 2029 to support transparency on carbon footprint, recycled content, and supply chain traceability.
The DPP for metals complements the Carbon Border Adjustment Mechanism (CBAM), which already requires carbon reporting for imported steel and aluminium since October 2023.
Regulatory Timeline
2023
CBAM transitional period begins
Regulation (EU) 2023/956 requires importers of iron, steel and aluminium to report embedded CO₂ emissions — a foundation for future DPP data.
2026
CBAM fully operational
Full CBAM implementation with carbon certificates required for imports. Emissions data reporting becomes mandatory for all covered goods.
2024
ESPR enters into force
Regulation (EU) 2024/1781 establishes the framework for Digital Product Passports. Iron, steel and aluminium are listed as priority product categories.
DPP for iron, steel and aluminium expected
Delegated acts specifying DPP requirements for iron, steel and aluminium products are expected to apply from approximately 2029, subject to adoption timeline.
Expected DPP Data Requirements
Carbon Footprint
CO₂ emissions per tonne of product, covering Scope 1, 2, and 3 emissions across the full production lifecycle.
Recycled Content
Percentage of recycled material (scrap-based vs. primary production), distinguishing pre- and post-consumer recycled content.
Material Composition
Alloy grades, chemical composition, coatings, and surface treatments. Full declaration of substances of concern.
Energy Source
Share of renewable energy in production. Production route specification (e.g. BOF vs. EAF for steel, primary vs. secondary aluminium).
Supply Chain Traceability
Origin of raw materials, mine-to-market tracking, and due diligence information on responsible sourcing.
Durability & Recyclability
Mechanical properties, expected service life, corrosion resistance data, and end-of-life recyclability rate.
Who Is Affected?
The DPP requirement for iron, steel and aluminium will affect all actors placing these products on the EU market:
- Steel producers — both Basic Oxygen Furnace (BOF) and Electric Arc Furnace (EAF) operations
- Aluminium smelters and rolling mills — primary and secondary aluminium production
- Iron ore miners and processors — upstream raw material suppliers
- Importers — companies importing iron, steel, or aluminium products into the EU (already affected by CBAM)
- Downstream manufacturers — automotive, construction, packaging, and engineering industries using metal as input material
The DPP builds on the CBAM reporting infrastructure. Companies already complying with CBAM carbon reporting will have a significant head start in meeting DPP requirements, as much of the emissions and supply chain data is already being collected.