Iron and Steel under ESPR and the Digital Product Passport
Iron and steel is identified in the first Working Plan as the lead category for ESPR delegated acts. Preparatory study and stakeholder consultation are underway. No delegated act has been proposed yet, but this is the category to watch most closely if you are in the steel supply chain.
Key dates for this sector
2026 to 2027
Signaled
Signaled
First category delegated acts expected. Iron and steel is the likely lead category, followed by textiles, tires, and aluminium. Dates are indicative.
Expected DPP data requirements (not yet confirmed in an act):
- Embodied carbon and carbon footprint per tonne of product
- Recycled scrap content percentage
- Substances of concern
- Country of origin and production route
Watch items
- Delegated act proposal expected 2026 to 2027. Compliance timeline of 2028 to 2029 is indicative and will shift once the act is proposed and adopted. Signaled
What to do now
Monitor Commission consultation documents for iron and steel. Begin preparing verified embodied-carbon and recycled-content data now. Customers in regulated downstream categories will request this data before your own deadline arrives.
Sources: COM(2025) 187: Working Plan · Verified 10 June 2026
Part of ESPR Atlas, the free ESPR and Digital Product Passport intelligence hub. Compare all nine categories on the Sectors in Scope page.
Frequently Asked Questions
When does ESPR apply to iron and steel?
Signaled: likely the first ESPR delegated act. Key date: 2028 to 2029 (estimated compliance). This timeline is signaled, not an adopted act; plan against date ranges rather than fixed deadlines.
What Digital Product Passport data will iron and steel require?
Expected DPP data requirements (not yet confirmed in an act): Embodied carbon and carbon footprint per tonne of product; Recycled scrap content percentage; Substances of concern; Country of origin and production route.
What should iron and steel companies watch?
Delegated act proposal expected 2026 to 2027. Compliance timeline of 2028 to 2029 is indicative and will shift once the act is proposed and adopted.
What should iron and steel companies do now?
Monitor Commission consultation documents for iron and steel. Begin preparing verified embodied-carbon and recycled-content data now. Customers in regulated downstream categories will request this data before your own deadline arrives.