9 Key Takeaways from the JRC Study on Digital Product Passports for Steel

Steel and Iron sit at the heart of the EU's industrial transition. Named as priority product groups to implement Digital Product Passports under the 2025–2030 Ecodesign and Energy Labelling Working Plan, they are central to the EU’s plans for a circular economy, more efficient use of resources, and the decarbonisation of heavy industry.

The Joint Research Centre (JRC), the European Commission’s science and knowledge service, released an extensive report detailing the findings of their study on DPP content for steel and Iron products under ESPR.

It sets out what Digital Product Passports for Steel mean in practice, and specifically, recommendations for what it believes DPPs for intermediate Steel products should contain.

The JRC Recommendations for Steel DPPs – 9 Key Takeaways

The recommendations of the JRC are intended to feed into the future delegated act for Steel under the Ecodesign for Sustainable Products Regulation (ESPR), making them very important to consider with the steel deadline impending in 2027/28.

The key points for Steel organisations to be aware of are:

1. You're in scope if you make or import intermediate steel for the EU market

‍The DPP obligation applies specifically to Hot Rolled Coil, Wire Rod, Cold Rolled Coil Galvanised, Electrical Steel, and Stainless Steel.  

If you transform steel and place the new product on the market, the DPP obligation transfers to you at that point, so you'll need to both receive upstream DPP data and issue your own.

2. Your heat number becomes the unique product identifier

‍You won't need to adopt a new identifier scheme. The JRC proposes using the heat number you already record under EN 10168 and carry on your Mill Test Certificates.  

Cast or lot number can be added optionally, meaning your existing MTC-based identification can be reused rather than replaced.

3. Batch-level identification is the default; item-level only where you already do it.  

You'll identify at heat/batch level unless you supply product categories where item-level tracking (such as serial numbers on individual coils) is already standard. This includes typically flat steel going into aerospace, defence, oil & gas or nuclear.  

The proposal deliberately avoids forcing item-level traceability on bulk products, since industry feedback put the cost of implementing it from scratch at €1 million or more per installation.

4. The mandatory data set is kept tight.  

You'll need to provide:

1. Product identification and classification
2. Producer identification and origin - including country of melt and pour, not just country of manufacture
3. Substances of concern under Article 7(5) of the ESPR
4. Environmental and circularity data, specifically Product Carbon Footprint and recycled content with a pre-/post-consumer split (ISO 14021-based)

5. Most of your MTC data stays voluntary.  

Mechanical properties and the broader MTC parameters are proposed as voluntary or conditional fields rather than mandatory, because their relevance depends on end-use.  

CBAM report IDs, CPR Declarations of Performance, and REACH documentation are also voluntary. You can include them to streamline reporting across regimes, but you won't be required to.

6. Access rights are set field-by-field, using three tiers.

Following the Battery Regulation model: public, legitimate-interest, or authority-only. Worth noting for your commercial teams: your declared PCF value will be public, but the calculation inputs behind it stay ‘legitimate interest’ only.  

Detailed chemical composition and the pre-/post-consumer recycled content split are also restricted rather than public.

7. Expect your DPP to need to line up with the CPR DPP.  

A large share of intermediate steel ends up in construction products, which have their own DPP under the revised Construction Products Regulation (CPR).  

The JRC treats interoperability between the two regimes as a requirement, particularly on product identification, so you shouldn't have to report the same product twice in incompatible formats.

8. Some decisions you're waiting on aren't in this document.  

The data carrier (QR, DataMatrix, RFID), the EU DPP Registry, and the public Web Portal are all being defined separately through horizontal delegated acts and CEN/CENELEC JTC 24 standards.

This report only covers what goes into the DPP, not how it's carried, stored, or accessed.

9. Several open issues are flagged for the impact assessment phase.  

How Digital Product Passport responsibility transfers cleanly from one operator to the next along the value chain, how modelled (rather than measured) environmental data gets verified, and the shift away from PDF-based certificates toward machine-readable, digitally signed attestations are all unresolved.

These are areas where requirements may still change, so worth monitoring as the delegated act develops.

List of Recommended Steel and Iron DPP Data Points

Below, we have set out the data points that the JRC Study has recommended for Steel and Iron products under the ESPR, broken down by mandatory and voluntary classifications:

Mandatory

Product identification and classification

• Heat number (per EN 10168) as the unique product identifier
• Cast/lot number (where applicable)
• Item-level serial number (only for specific product categories, e.g. coils for aerospace/defence/oil & gas/nuclear)
• GTIN (Global Trade Identification Number)
• TARIC code
• HS / CN code
• Purchase order reference
• Product ESPR category
• Steel grade classification (EN 10020)
• Steel designation (EN 10027-2)
• Technology route

Producer identification and origin

• Unique Facility Identifier (UFI) - e.g. EORI / GLN / DUNS
• Unique Operator Identifier (UOI) - e.g. LEI
• Manufacturer / authorised representative name, address, trademark, contact
• Importer name, address, trademark, contact
• Other operator identifier (where applicable)
• Country of origin
• Melt & pour location
• Manufacturing date

Material compliance / Substances of concern

• Substance name (IUPAC or other international name)
• EC number and CAS number (where available)
• Location of the substance within the product
• Concentration / maximum concentration / concentration range (with value and units)
• Instructions for safe use (where relevant)
• Information relevant for disassembly, reuse, recycling and end-of-life handling

Environmental and circularity information

• Product Carbon Footprint declaration
• PCF conformity declaration / certification
• Recycled content declaration (%)
• Pre-consumer / post-consumer material split
• Recycled content conformity declaration / certification

Voluntary

• Full scope of Mill Test Certificate parameters (per EN 10168), including mechanical properties
• CBAM report ID
• CPR Declaration of Performance (DoP / DoPC)
• REACH documentation

As you can see, the mandatory data recommendations are quite extensive (and are likely to be adopted via delegate act), meaning that Steel producers and other members of the metal supply chain need to start preparing for DPPs now – especially with the deadline approaching for Steel in 2027.

In our eBook “The Pathway to Digital Product Passport Readiness”, we give practical, actionable insight into how to start preparing your business for Digital Product Passport implementation. Download it here.

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Provenant provides a specialist Digital Product Passport platform and Digital Product Passport Consulting Services, purpose-built to help organisations prepare for compliance with EU DPP mandates.

Our solutions are fully aligned with the European Commission’s ESPR framework, enabling companies to demonstrate the sustainability and circularity of their products at scale.

Get in touch to discuss your Digital Product Passport journey now.

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