Sectors and timing
When an iron or steel product needs an EU passport
No steel passport rule exists yet. The Commission plans to adopt one in late 2026, so the earliest application is about mid 2028.
No iron or steel product needs a digital product passport today. The European Commission has not adopted the rule for the group. The earliest date such a rule can apply is about the middle of 2028.
Iron and steel is the first product group in the European Union (EU) ecodesign programme. You may sell a stainless steel milk vat or a coil of galvanised steel into the EU. On the Commission's plan, your date comes before any other ecodesign sector.
Two mistakes cost money here. The first is to buy a passport system now, against a rule that nobody has written. The second is to ignore the steel rule because you sell something else. If the Commission adopts it first, the steel rule will show what an ecodesign passport demands.
Nothing binds today, because the rule does not exist
The Ecodesign for Sustainable Products Regulation (ESPR) creates the passport. It is Regulation (EU) 2024/1781, and it has been in force since 18 July 2024.
ESPR by itself makes no product need a passport. Article 9 makes a passport a condition of market access, and only for a product group that a separate rule covers. That separate rule is called a delegated act, and the Commission adopts one group at a time. See what is a delegated act.
As at 15 August 2026 the Commission has adopted no delegated act for any product group. So no iron or steel product carries an ESPR passport duty, and neither does anything else. Which products need a passport, and when sets out every group.
GS1 in Europe, a standards body, summarises ESPR Article 18(5). That summary names iron and steel among the priority product categories. Aluminium, textiles, furniture and tyres are on the same list. See ESPR priority categories.
The steel rule has reached the consultation step
The Commission ran two consultations on the iron and steel rule, not one. Both closed on 12 August 2026.
| Consultation | What it asked for |
|---|---|
| A call for evidence | Evidence for the impact assessment behind the act |
| An open public consultation | Comment from anybody, through the Commission's own form |
The Commission has published the planned act's own title. It is a Commission Delegated Regulation establishing ecodesign requirements for sustainable and circular iron and steel products under Regulation (EU) 2024/1781. That title is a plan and not an act, and no draft text is published.
The Commission's planning record puts adoption in the fourth quarter of 2026. The Commission marks its own dates as indicative, and says they may change as the work progresses. Nothing here is adopted law.
The Commission also states what the act will do. It will define low-carbon steel, and it will set ecodesign requirements for the design of iron and steel products. That is the Commission speaking about its own plan, so read it as a plan.
Four steps stand between adoption and your date
Read the table as arithmetic, not as a promise. Only the first row is a plan. The rows below it come from articles of ESPR that are in force.
| Step | Time | Source and status |
|---|---|---|
| The Commission adopts the delegated act | Q4 2026 | Commission planning record, indicative |
| Parliament and Council may object | Two months, extendable by two more | ESPR Article 72(6), in force |
| The act enters into force | 20 days | Usual interval |
| Companies prepare | At least 18 months | ESPR Article 4(4), in force |
| A steel passport applies | About mid 2028 | Calculated, earliest possible |
Article 4(4) says the date of application "shall not be earlier than 18 months from its entry into force". The same article allows an earlier date in duly justified cases. So treat that period as the usual minimum.
Mid 2028 is the earliest date for any ecodesign passport
The Commission plans to adopt the steel act before any other ecodesign act, which means no other ecodesign sector starts sooner.
Textiles come later. The Commission plans to adopt the textile rule in late 2027, which puts application in 2029 at the earliest. A supplier who tells a merino jumper exporter to be ready in 2027 is quoting the year the rule gets written. See how to read the timeline and why the textile date is not 2027.
One passport duty binds before steel, and it does not come from ESPR. The battery regulation covers three battery types from 18 February 2027. It does not cover every battery.
- An electric vehicle battery.
- A light means of transport battery, such as an e-bike battery.
- An industrial battery with a capacity greater than 2 kilowatt hours.
See batteries.
Nobody can tell you what data a steel passport will carry
No act exists, so no data fields exist. Any list of steel passport fields you are shown today is a guess, however confident the presentation.
Four things around the data are settled, and they are worth knowing.
- Six passport standards are cited: EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223.
- Citation gives a product built to a standard a presumption of conformity. The standards stay voluntary. See the six standards.
- ESPR names the ISO/IEC 15459 series for the identifier and the data carrier. It does not name GS1 Digital Link. See identifier schemes: what is verified.
- The EU registry is operational, and no operator has to upload to it yet. See the EU registry.
So the shape of the technical work is public. The product content for steel is not, and it will not be until the act appears.
The duty falls on the operator that places the steel on the EU market
ESPR Article 13(4) names the party:
The economic operator placing the product on the market or putting it into service shall upload, in the registry, the data referred to in paragraphs 1 and 2.
If you have no EU establishment, you are usually not that operator. Your EU importer is. See who is the economic operator.
That does not release you. The importer cannot publish data that you never sent it. You may supply steel fasteners or steel wire rope to a manufacturer in Germany. In that case no EU law reaches you directly. That manufacturer still asks you for the data as a condition of purchase. See what a non-EU exporter must supply.
Monitor the steel act even if you never sell steel
The Commission plans the steel act as the first delegated act under ESPR. If the Commission adopts it, the act will show four things that no summary can show today.
- How the Commission defines the boundary of a product group.
- Which data the Commission demands, and at what level of detail.
- How long the transition period really is for the first act.
- How the act treats a supplier outside the EU.
Read the steel act when it appears, whatever you export.
Do not buy a steel passport system this year
- Do not buy a steel passport system this year. No rule defines the data.
- Monitor the delegated act itself. Do not plan against the year in the plan.
- Ask your EU importer which data it needs, and when.
- Find out where you keep your product data, and who owns it.
- Check the date on any steel guidance you read. Material from 2025 predates the two consultations.
The last two points are worth doing whatever your product is. See what this means for New Zealand exporters for the wider picture.