An Industry Perspective

Steel is becoming data. Digital Product Passports are making it real.

This explainer brings together how Digital Product Passports for steel are taking shape under ESPR — and what that means for how product data is structured, shared and used in practice.

It helps industrial companies understand where things stand, what is emerging, and how to start navigating it.

Market context

Steel is a foundation of modern society. But what defines its value is changing.

Steel is a fundamental part of modern society and a strategically important industry in Europe. It underpins everything from infrastructure and construction to mobility and energy systems. At the same time, the industry is under increasing pressure to reduce its environmental impact while remaining competitive in a global market shaped by overcapacity, price pressure and shifting trade conditions.

As this unfolds, the role of data is also changing. It is no longer enough to know what is produced. It becomes just as important to understand how, where and with what impact. For a sector like steel, which supplies many different industries, it quickly becomes clear that the same information does not always suffice. It is requested in different ways, in different formats and for different purposes along the value chain.

This puts today's way of sharing information under clear pressure.

Global steel production

1.9B

~1.9 billion tonnes produced annually, reflecting global demand and structural overcapacity.

World Steel Association

Steel in the built environment

~50%

Nearly half of global demand, making steel essential to buildings, infrastructure and urban growth.

World Steel Association

European steel economy

€152B

A major industrial sector supporting jobs, supply chains, and economic activity across Europe.

European Commission

Steel and global emissions

~8%

A significant share of global CO2 emissions, placing steel at the centre of industrial transition.

International Energy Agency (IEA)

Steel recycling dynamics

~90%

Highly recycled globally, but not retained at the same material quality.

World Steel Association

Industry challenge

The current model for exchanging product information is no longer sufficient

Products and materials carry critical information across global and complex value chains. This includes characteristics, performance, origin, how they are produced, and increasingly data related to sustainability and circularity.

At the same time, product information is often scattered across documents, emails and isolated systems, without a shared structure or standardisation. This makes it difficult to combine, verify and reuse, especially across organisational boundaries.

As expectations for this type of information continue to grow, these limitations are no longer just inefficiencies, they are becoming business critical.

Product information is fragmented, unstructured and hard to use

FIG 0.1

Documents without structure

Product information is typically distributed across multiple document formats, such as data sheets, material certificates and sustainability declarations. These are often based on different standards and shared as PDFs or similar document formats, without a common structure.

FIG 0.2

Siloed distribution

The same information is then distributed through emails, supplier portals or attached documents. It remains siloed across systems and organisations, making it difficult to access, combine or reuse in a consistent way.

FIG 0.3

Unreliable and unverifiable data

Without shared structure and traceability, product information becomes difficult to trust. It cannot be reliably traced to its source, verified at scale or consistently reused, limiting its value across the value chain.

A shared challenge across the value chain

The same product data moves across the entire value chain, but is created, interpreted and used differently by each actor. Without a shared structure, this creates friction at every step — from production to procurement to compliance.

Steel producers

Primary and secondary steelmakers

Role in value chain

Transform raw materials and scrap into products such as slabs, coils and beams that move further through the value chain.

Key product information

Generate core product information such as material chemistry, mechanical properties, batch data and, increasingly, production emissions.

Current challenge

Core product data still leaves production as PDFs, making it difficult to use in digital workflows.

Role in value chain

Transform raw materials and scrap into products such as slabs, coils and beams that move further through the value chain.

Key product information

Generate core product information such as material chemistry, mechanical properties, batch data and, increasingly, production emissions.

Current challenge

Core product data still leaves production as PDFs, making it difficult to use in digital workflows.

Solution concept

From compliance requirements to industrial data infrastructure

ESPR and Digital Product Passports represent a regulatory driven shift in how product data is expected to be shared and used. It is a challenge that individual companies and entire industries have struggled to solve on their own.

It is easy to view this as another compliance requirement. But what is emerging is more fundamental than that. Product information is moving from documents to structured and interoperable data that can be shared and used across systems and organisations.

Those who treat this as compliance will meet the requirements. Those who see it as a shift in how data can be used will be better positioned to work with and extract value from their product data across the value chain.

Core concepts of a Digital Product Passport

A Digital Product Passport is built on a set of core concepts that connect physical products to structured, shareable data.

FIG 1.1

Digital Product Passport — product identification concept illustration

Physical product identity

Each product needs a clear way to be identified and linked to its digital information. In practice, this is enabled through identifiers such as QR codes or tags that connect the physical item to its digital record.

FIG 1.2

Digital Product Passport — distributed data access and federation illustration

Decentralised data access and exchange

Product data remains with different actors across the value chain. Controlled and decentralised access makes it possible to share information without duplicating data or relying on document flows.

FIG 1.3

Digital Product Passport — standardised product data structures illustration

Standardised data protocols

Product data follows shared definitions and structures. This makes information consistent, interoperable and usable across systems, organisations and value chains.

A Digital Product Passport is not a single system. It is an architecture.

It is not something you send, but something you access. When a product is scanned, relevant data is retrieved from multiple sources and presented based on what the viewer is allowed to see.

This changes how product data works in practice. Instead of static documents, information becomes accessible, reliable and available where and when it is needed.

Conceptual runtime flow for resolving and assembling a Digital Product Passport

From static document flows to Digital Product Passports in steel

A simplified view of how Digital Product Passports in steel can support a shift from static document flows to accessible, structured and trusted product data.

Concepts for how DPPs are generated and accessed over time

Concepts for what DPPs contain as structured product data

Abstraction

Steel passport protocol

Hot rolled steel coil

UPI-EU-NSW-20240315-88412

Access policy:Legitimate interest

Product

S355MC / 1.0976

Serial number

NSW-C-88412

HS / CN code

HS 7208.37 · CN 7208 37 00

Industry opportunity

From compliance to a shared data foundation

As product data becomes structured, accessible and reliable, its role begins to change. What was previously handled as reporting can start to be used operationally across systems, processes and organisations.

This creates the conditions not only to follow up, but to guide and optimise. Decisions can be made on better foundations, not just at the product level but also in how production, flows and collaboration are planned across the value chain.

Trusted sustainability claims

53%

of environmental claims reviewed in the EU were found to be vague, misleading or unsubstantiated.

Structured product data makes sustainability claims verifiable — not just declarable, by linking them directly to production data such as route, recycled content and primary emissions.

Environmental performance

Product carbon footprint0.42 tCO₂e/t

Key drivers

Production routeEAF

Recycled content85 %

Melt & pour countrySweden

Methodology

Standard usedEN 15804+A2

System boundaryCradle-to-gate

Third-party verifiedYes

Scalable product verification

90-95%

of incoming material certificates can be validated automatically.

Structured product data enables certificates, material declarations and environmental performance data to be verified automatically against product specifications, customer requirements and regulatory rules - reducing manual verification work and improving traceability.

Records verified today348

Auto-verified329

Exceptions19

Incoming material validation

Batch ID	Grade	Yield	Tensile	Status
H-2847-A	S355J2	355 MPa	510 MPa	✓ OK
H-2848-B	S355J2	358 MPa	515 MPa	✓ OK
H-2849-C	S355J2	361 MPa	512 MPa	✓ OK
H-2850-D	S355J2	349 MPa	498 MPa	⚠ Tolerance
H-2851-E	S355J2	357 MPa	509 MPa	✓ OK

Smart manufacturing

30-60 min

typical production disruption time after material variation.

When primary material data becomes available digitally across production systems, manufacturing parameters can be adjusted in advance - reducing production disruptions and unplanned downtime, and enabling more stable production runs.

Production disruptions with early material data

Stable run

Disruptions

Material parameters

Heat / batchH-2847-A

Steel gradeS355J2

Bar diameter82.01 mm

Diameter tolerance±0.02 mm

Yield strength355 MPa

Hardness170 HB

Circular steel ecosystems

0.3%

typical copper limit for many steel grades.

Residual elements such as copper accumulate in recycling streams and can limit the use of scrap in high-performance steels. This often leads to downcycling despite high recycling rates. Structured material data makes scrap composition visible and enables matching to suitable applications.

Impurity accumulation in recycling cycles

Impurity content

Recycling cyclesGrade limit

Scrap composition

Cu0.12%

Sn0.03%

Target gradeS235

SuitabilityOK

State of play

From policy to implementation: where steel stands now

The Digital Product Passport is part of an ongoing transition from policy into implementation. What started with the ESPR proposal is now translating into concrete requirements for steel.

The focus is shifting from what it means to how it will work in practice.

Mar 2022
ESPR proposed
Jul 2024
Framework adopted
Apr 2025
Working Plan released
Iron and steel move into concrete implementation.
Q2 2026
NOW
Initial proposals emerge
Initial proposals emerge, alongside developing and published standards.
2026/2027
Requirements finalised
~2028
Compliance in force
Applies to companies placing steel products on the EU market.

Jul 2024

Framework adopted

Q2 2026

NOW

Initial proposals emerge

Initial proposals emerge, alongside developing and published standards.

~2028

Compliance in force

Applies to companies placing steel products on the EU market.

Mar 2022

ESPR proposed

Apr 2025

Working Plan released

Iron and steel move into concrete implementation.

2026/2027

Requirements finalised

What is happening now

We are now moving from foundational analysis into early drafting and alignment. Research-based initial content proposals are available, while technical standards are being developed and published, defining how product data can be identified, structured and exchanged.

This creates both direction and momentum. While key elements are still evolving, there is now enough clarity for companies to begin preparing and engaging.

Key building blocks

Study on DPP content for iron and steel products
EN 18219 Unique identifiers
EN 18220 Data carriers
EN 18216 Data exchange protocols
EN 18223 System interoperability
EN 18221 Data storage and persistence
EN 18222 API interfaces
Implementing Act for DPP registry

Joint Research Centre (JRC)
CEN/CENELEC JTC 24
European Commission, DG GROW

Useful entry points

First steel DPP content proposal

European Commission JRC

This first proposal translates regulatory intent into draft data expectations for steel. It is not final, but concrete enough to understand what may be required and where gaps exist today.

Explore proposal

Technical standards in progress

CEN/CENELEC JTC 24

European standards are being developed and published, defining how data is identified, structured and exchanged across systems. These specifications underpin interoperability, but are still evolving.

Explore standards work

Next step

Where do we go from here?

The direction is becoming clearer. The question is no longer if, but how to start.

Many organisations can now move with more confidence than a year ago. The gap is rarely ambition, but preparation — shared clarity, ownership and a realistic view of where to begin.

Early work is most effective when it stays focused and practical. Build enough understanding to move forward, without overcommitting too early. That is what creates momentum.

Preparations

Frame the opportunity
Engage business stakeholders and create a shared understanding of what this could mean in your context — and where value might emerge.
Set ownership and direction
Define clear ownership, form a cross-functional taskforce, and create the conditions to move forward.
Understand your starting point
Map your current state across data, value and feasibility — identify gaps, assess where value can be created, and evaluate what is realistically achievable across systems and processes.
Test in small steps
Run focused initiatives to validate assumptions, build learning, and create momentum, both internally and in collaboration with actors across the value chain.

Scaling

Structured data models
Consistent product data across systems and actors.
System integration
Data flows across internal systems and partners.
Operational governance
Clear roles, ownership and ongoing processes.

Practical questions

Key questions companies are asking about the steel Digital Product Passport

The Digital Product Passport is still evolving, but companies across the steel value chain are already working to understand what it means in practice.

These are some of the questions coming up most often.

A small group of front-runners have started to act, typically through early preparation and simple prototypes. At the same time, many organisations have assigned initial ownership and, in some cases, formed working groups to monitor the topic. The dominant approach has been to observe, build understanding and wait for clearer direction before committing to larger initiatives.

The scope has been evolving, driven largely through policy development and expert discussions rather than implementation. With the prioritisation of steel, awareness has increased and more organisations are now following developments more closely. As a result, many are moving from passive monitoring towards more active evaluation.

Many organisations have taken a cautious approach, focusing on understanding rather than acting. What is changing now is a combination of signals that together reduce uncertainty.

Priorities and timelines are becoming clearer, while early content proposals provide a more concrete view of what product data may be expected. This has also increased market awareness, making the topic easier to engage with. At the same time, technical standardisation and reference architectures are starting to take shape, providing direction for how data can be structured and shared.

Together, this removes some of the key uncertainties that previously made it difficult to act and shifts the focus from passive monitoring towards more active evaluation.

The regulatory scope is generally understood to directly affect manufacturers and importers placing steel on the European market. At the same time, current research and preparatory work has focused on a selected set of steel product groups where the expected impact is highest. This gives an initial scope, but does not represent the full range of steel-based products.

In practice, the relevance already extends further. Downstream industries are following the topic with increasing interest, meaning that even organisations not directly in scope today may still need to take an early position.

Ownership is rarely clear from the outset. Given the data scope, multiple functions are involved. In practice, many interpret this as a sustainability, compliance or IT/digital topic and place it accordingly, but its cross-functional nature quickly becomes apparent.

Progress typically requires setting ownership, identifying stakeholders and building mandate across functions. Long-term ownership and governance are rarely defined upfront and instead emerge over time as the organisation builds understanding and alignment.

It is often approached as a compliance topic, and in part, it is. At the same time, it builds on a well-established industry challenge: how to structure and distribute product data in a consistent and reliable way.

What is changing is that product data becomes more structured, accessible and connected. This creates a shift — from reporting towards something that can be used across processes and decisions — and starts to support verification, optimisation and more data-driven ways of working.

There is now a clearer starting point. Early content proposals, together with emerging technical standards and reference architectures, make it possible to understand what data is being discussed and how it is expected to be structured and exchanged.

From there, the focus shifts to setting ownership, identifying stakeholders and building mandate through a few early, balanced activities. This includes understanding where value may emerge, making an initial feasibility assessment and beginning to test in a controlled way.

That is often enough to define a realistic next step.

A common pattern is to move too quickly into detailed analysis. There are many aspects to consider, and it is natural to try to break them down early, but without balancing clarity, alignment and mandate, this can lead to work that is difficult to anchor or move forward.

In practice, progress comes from balancing early analysis with building mandate, understanding value and aligning stakeholders, creating a more stable foundation for moving forward.

Steel is becoming data. Digital Product Passports are making it real.

Product information is fragmented, unstructured and hard to use

A shared challenge across the value chain

Primary and secondary steelmakers

Core concepts of a Digital Product Passport

Physical product identity

Decentralised data access and exchange

Standardised data protocols

A Digital Product Passport is not a single system. It is an architecture.

From static document flows to Digital Product Passports in steel

What is happening now

Frame the opportunity

Set ownership and direction

Understand your starting point

Test in small steps

Structured data models

System integration

Operational governance