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Steel & Aluminium DPP

Steel & Aluminium DPP: The ESPR and CBAM Data Playbook for Metals

Iron, steel and aluminium are intermediate priority materials in the first ESPR working plan - the iron-and-steel act is indicatively expected as early as 2026, aluminium around 2027. This is what producers and importers must disclose - embodied carbon, EPD data, scrap and recycled content, and alloy traceability - and how to build a Digital Product Passport that also carries you through CBAM.

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Iron, steel and aluminium are among the earliest priority materials in the EU's first Ecodesign for Sustainable Products Regulation (ESPR) working plan, adopted by the European Commission on 16 April 2025. They are listed as intermediate product groups - materials that feed into countless finished products rather than reaching the consumer directly - and the working plan flags the iron-and-steel delegated act as the most advanced, indicatively expected as early as 2026, with the aluminium act following around 2027. The dates are indicative, not legally binding deadlines: the binding timeline crystallises only when each metal-specific delegated act is published under Article 4 of Regulation (EU) 2024/1781. But metals are unusual among DPP categories because the data the passport will demand is already being produced for a parallel, legally live regime - the EU Carbon Border Adjustment Mechanism (CBAM), whose definitive phase began on 1 January 2026 and which already obliges importers of iron, steel and aluminium to report verified embedded emissions. That convergence is the strategic core of the metals DPP: the embodied-carbon and material-composition data the ESPR passport will require overlaps heavily with the CBAM embedded-emissions data importers are already verifying, so a metals producer that builds the passport data model now is also de-risking its CBAM exposure. The metals passport is fundamentally an environmental-data and traceability problem. The headline figure is embodied (cradle-to-gate) carbon, expressed in kg CO2-equivalent per tonne of steel or aluminium, computed under a recognised life-cycle methodology and ideally backed by an Environmental Product Declaration (EPD) per EN 15804 and the relevant product category rules. Around that sit the scrap and recycled-content share - the single biggest lever on a metal's carbon intensity, since secondary aluminium uses a fraction of the energy of primary smelting - and the alloy specification and traceability that downstream manufacturers, recyclers, and market-surveillance authorities need. This pillar is the reference for sustainability, procurement, and compliance leaders at steel mills, aluminium smelters and rolling mills, metal service centres, and the importers who place finished metal products on the EU market, who will sign platform contracts in 2026 and need a passport architecture that satisfies the metals delegated acts and feeds CBAM at the same time.

  • July 2024Done

    ESPR enters into force

    Regulation (EU) 2024/1781 published in the Official Journal on 28 June 2024 and applicable from 18 July 2024, repealing the old Ecodesign Directive. It establishes the horizontal legal basis for the Digital Product Passport and for product-specific ecodesign requirements set in delegated acts, including for intermediate materials such as iron, steel and aluminium.

  • 1 January 2026Upcoming

    CBAM definitive phase begins

    The EU Carbon Border Adjustment Mechanism enters its definitive phase. Importers of iron, steel and aluminium must report verified embedded emissions and, from 2026 imports, face CBAM certificate cost exposure, with certificate sales starting 1 February 2027. The verified embedded-emissions data CBAM demands overlaps directly with the embodied-carbon data the ESPR metals passport will require.

  • 16 April 2025Done

    First ESPR working plan adopted

    The Commission's first Ecodesign and Energy Labelling Working Plan 2025-2030 names iron and steel and aluminium as priority intermediate product groups, alongside textiles, furniture, mattresses and tyres. Iron and steel is flagged as the most advanced, with an indicative delegated-act adoption as early as 2026; aluminium follows indicatively around 2027.

  • 2026 (indicative)Upcoming

    Iron & steel delegated act expected

    Under the first working plan, the iron-and-steel delegated act is indicatively expected as early as 2026 - the earliest of the priority groups. It will fix the binding DPP data fields, embodied-carbon disclosure rules, recycled and scrap-content requirements, and the conformity-assessment route for steel. Aluminium follows on a similar pattern around 2027.

  • Post-adoption transitionNext deadline

    DPP becomes mandatory after transition

    ESPR delegated acts apply after a transition period from adoption. From the end of that transition, in-scope iron, steel and aluminium placed on the EU market must carry a compliant, machine-readable Digital Product Passport accessible through a data carrier, with the embodied-carbon and material data aligned to the EPD and CBAM evidence already in the producer's systems.

Required data

Every field the metals DPP will demand.

  • Unique product identifier and the identity of the responsible economic operator (producer, importer, or EU authorised representative) placing the metal on the EU market.
  • Material grade and full alloy specification - the steel grade or aluminium alloy designation, with chemical composition and the relevant EN or ISO standard reference.
  • Embodied (cradle-to-gate) carbon footprint in kg CO2-equivalent per tonne, computed under a recognised life-cycle methodology and aligned with the embedded-emissions accounting used for CBAM.
  • Environmental Product Declaration (EPD) reference per EN 15804 and the applicable product category rules, where available, with the verifier and validity period.
  • Recycled-content and scrap share - pre-consumer and post-consumer scrap by mass percentage - the single biggest determinant of the metal's carbon intensity.
  • Production route - for steel, primary blast-furnace/basic-oxygen versus electric-arc-furnace; for aluminium, primary smelting versus secondary remelting - and the energy mix where required.
  • CBAM linkage for imported metal
    the embedded-emissions value, the verification status, and the installation or supplier reference, reusing the same verified data the passport carries.
  • Traceability and chain-of-custody from melt to product, including heat or cast number where applicable, so downstream users and recyclers can trace the material back to its source.
  • Restricted-substances and hazardous-content declaration relevant to coatings, surface treatments and alloying elements, aligned with REACH where applicable.
  • Durability, recyclability and end-of-life information - the metal's suitability for recycling, separation guidance, and the recovery pathway, exposed through the public layer of the passport.
  • Mechanical and performance properties where the delegated act requires them, such as tensile strength, yield, and temper, traceable to mill test certificates (EN 10204 3.1 / 3.2).

The ESPR working plan treats iron, steel and aluminium as intermediate product groups - materials that are placed on the EU market as inputs to other products: coils, plates, sections, bars, billets, ingots, extrusions, castings and semi-finished forms. That is a different scope from a finished-product passport. The obligation falls on the economic operator that places the metal on the EU market: the mill or smelter if it is EU-based, the importer if production happens outside the EU, or an EU authorised representative. Because the EU is a large net importer of both steel and aluminium, the importer dimension is central - and it is exactly where ESPR and CBAM converge, since the importer already has to report verified embedded emissions under the CBAM definitive regime that began on 1 January 2026. In practice the operational scope reaches up the value chain to the melt: scrap suppliers, alloy producers, and energy contracts all feed the carbon and recycled-content figures the passport must carry. Finished products that happen to contain steel or aluminium - a piece of furniture with a steel frame, a vehicle, a building - are not in scope of the metals acts themselves; they sit under their own product-specific delegated acts (or none yet), though their makers still need the underlying metal data and may pull it directly from a supplier's metals passport. The runway for steel is the shortest of any ESPR priority group, with the delegated act indicatively expected as early as 2026, and the data demands are not hypothetical: any producer or importer already complying with CBAM is producing most of the embodied-carbon and material evidence the passport will need. The strategic move is to structure that data once, in a passport-ready model, rather than maintaining parallel CBAM and ESPR data silos.

A steel or aluminium Digital Product Passport is an environmental-data and traceability problem first, and the architecture is built around the embodied-carbon figure and the chain of custody from melt to product. The passport is reached through a data carrier - a QR code conforming to ISO/IEC 18004, or for bulk and semi-finished metal a per-batch or per-coil marking - that resolves to a unique URL returning the public layer, with restricted layers gated for downstream manufacturers, recyclers, customs, and market-surveillance authorities. The platform mints GS1-compliant identifiers, hosts the resolver using GS1 Digital Link, and signs each passport version with W3C Verifiable Credentials so a customs officer or notified body can confirm authenticity independently. The decisive design choice for metals is treating the carbon figure as a first-class, verifiable, reusable object. Our platform ingests embedded-emissions data in the structure CBAM already requires, maps it to the ESPR embodied-carbon field, links the supporting EPD per EN 15804 and the mill test certificate per EN 10204, and records the recycled and scrap share and production route alongside. Every value is versioned and audit-logged with provenance back to the supplier declaration, the verification report, or the measurement run. Records expose JSON-LD and Asset Administration Shell representations so the passport interoperates with the upcoming European DPP registry, downstream manufacturers' systems, and CBAM reporting. For a mill, smelter or importer the payoff is concrete: one data model that satisfies the metals delegated act, feeds CBAM, and answers the deepening sustainability questions in downstream tenders - rather than three disconnected spreadsheets that drift apart.

Risks

What non-compliance actually costs.

Risk

Unverified or inconsistent embodied-carbon data

Consequence

The headline metals figure is embodied carbon, and the most damaging failure is a passport carrying a self-declared carbon number that diverges from the verified embedded-emissions value the same material reports under CBAM. Divergent or unverified figures undermine both regimes at once: they can fail an ESPR conformity assessment and expose the importer to CBAM penalties and default high-emission benchmarks. Under the CBAM definitive regime, supplier-specific emissions must be verified by an accredited third party to be used at all - otherwise default values apply. The platform treats the carbon figure as a single verified object reused across ESPR and CBAM, with the verification status and verifier recorded and any unverified value flagged before publication.

Mitigation

One verified embodied-carbon object reused for ESPR and CBAM, EPD per EN 15804 linkage, accredited third-party verification status recorded, and a pre-publish gate on unverified values.

Risk

Unsubstantiated recycled and scrap-content claims

Consequence

Recycled and scrap content is the single biggest lever on a metal's carbon intensity and a prime greenwashing risk. Overstated or undocumented recycled-content claims - common where pre-consumer and post-consumer scrap are conflated, or where mass-balance accounting is not transparent - expose a producer to both ESPR data-integrity failure and broader EU green-claims scrutiny. A passport that asserts a recycled-content percentage without traceable scrap-input evidence will not survive an audit.

Mitigation

Structured pre-consumer and post-consumer scrap fields with documented mass-balance accounting, scrap-supplier declarations linked to the passport, and a versioned audit trail behind every recycled-content figure.

Risk

Broken melt-to-product traceability and alloy mis-declaration

Consequence

Metals are alloyed, remelted and reprocessed, and traceability from the heat or cast through to the finished semi-finished product is easily lost across service centres and processors. A passport that cannot tie the alloy grade and composition back to a mill test certificate, or that mis-declares the alloy, fails the conformity assessment, breaks downstream users' own compliance, and can compromise safety-critical applications. Generic DPP platforms that model metal as a flat record cannot represent heat-level traceability.

Mitigation

Melt-to-product traceability with heat/cast linkage, alloy grade and composition tied to EN 10204 mill test certificates, and a chain-of-custody model that survives reprocessing and service-centre handling.

Buying checklist

Vet any DPP platform against this.

  • Does the platform model the embodied-carbon figure as a single verified object reused for both the ESPR passport and CBAM, rather than separate silos?
  • Can it link an EPD per EN 15804 and the accredited third-party verification status to the carbon value, and flag any unverified figure before publication?
  • Does it capture pre-consumer and post-consumer scrap separately, with documented mass-balance accounting behind every recycled-content claim?
  • Does it record alloy grade and composition tied to EN 10204 mill test certificates, with melt-to-product (heat/cast) traceability that survives reprocessing?
  • Does it generate GS1 Digital Link data carriers, host a resolver, and export JSON-LD and Asset Administration Shell for the European DPP registry and downstream CBAM and tender use, with a committed schema-update after each delegated-act amendment?
Case studies

How metals producers are getting ahead.

Industry

Electric-arc-furnace steel mill

Challenge

An EAF mill with a genuinely low-carbon, high-scrap production route wants its environmental advantage to be visible and verifiable to customers, not buried in a PDF datasheet, while also preparing for the iron-and-steel delegated act and answering CBAM questions from EU importer customers.

Solution

A passport per product grade that carries the verified embodied-carbon figure, the post-consumer scrap share with mass-balance documentation, the EAF production route, and the EN 15804 EPD, reusing the same verified carbon object the mill already reports for CBAM.

Result

A verifiable low-carbon claim that wins tenders, one data object serving ESPR and CBAM, and a defensible audit trail for both regimes from a single source.

Industry

Aluminium smelter and rolling mill

Challenge

An aluminium producer running both primary smelting and secondary remelting must distinguish the very different carbon intensities of its product lines and trace recycled content and alloy composition through remelting, with the aluminium delegated act expected around 2027 and CBAM already live.

Solution

A passport model that records production route (primary versus secondary), energy mix, recycled-content share, and alloy designation per batch, with melt-to-product traceability and the embedded-emissions value aligned to CBAM verification.

Result

Product-line-accurate carbon and recycled-content data, traceable alloy and recycled claims through remelting, and CBAM-ready embedded-emissions figures reused in the passport.

Industry

Metal importer and service centre

Challenge

An importer placing steel and aluminium semi-finished products on the EU market already reports verified embedded emissions under CBAM and inherits the future ESPR passport obligation, but holds the upstream carbon and recycled-content data in CBAM-only spreadsheets disconnected from any product passport.

Solution

An ingestion workflow that pulls the importer's existing CBAM embedded-emissions and verification data into a passport-ready model, links EPDs and mill test certificates, and binds the importer as the responsible economic operator into each signed passport.

Result

CBAM and ESPR served from one structured dataset, no parallel data silos, and a head start on the metals passport using data the importer already had to verify.

Steel & Aluminium FAQ

Frequently asked,
about the metals DPP.

Recurring questions from steel mills, aluminium smelters, service centres and importers preparing for the ESPR metals delegated acts and the live CBAM regime.

Book a compliance briefing →
Is the steel or aluminium DPP already legally mandatory?+

Not yet. Iron and steel and aluminium are priority intermediate product groups in the first ESPR working plan, with delegated acts indicatively expected as early as 2026 for steel and around 2027 for aluminium. The binding obligation begins only after each metal-specific delegated act is adopted under Regulation (EU) 2024/1781 and its transition period ends. The working-plan dates are indicative, not legal deadlines.

How does the metals DPP relate to CBAM?+

They overlap heavily. CBAM's definitive phase began on 1 January 2026 and already requires importers of iron, steel and aluminium to report verified embedded emissions. The embodied-carbon and material data the ESPR passport will demand reuses much of that verified CBAM data, so building the passport model now also de-risks CBAM rather than creating duplicate work.

Does the metals act apply to finished products that contain steel or aluminium?+

No. The iron-and-steel and aluminium acts cover the metals as intermediate materials - coils, plates, bars, extrusions, ingots and semi-finished forms. A finished product such as furniture or a vehicle sits under its own product-specific delegated act, though its maker still needs the underlying metal data and can pull it from a supplier's metals passport.

What carbon figure does the passport require?+

Embodied, cradle-to-gate carbon in kg CO2-equivalent per tonne, computed under a recognised life-cycle methodology and ideally backed by an Environmental Product Declaration per EN 15804. Under CBAM, supplier-specific emissions must be verified by an accredited third party to be used; the same verified value should feed the passport.

Why does recycled and scrap content matter so much?+

It is the single biggest lever on a metal's carbon intensity - secondary aluminium uses a fraction of the energy of primary smelting, and electric-arc-furnace steel from scrap is far lower-carbon than the blast-furnace route. The passport must record recycled and scrap share with traceable evidence, and overstated claims are a prime greenwashing and audit risk.

Should metals producers start before the delegated act is published?+

Yes - and more so than other sectors, because the data already exists. Any producer or importer complying with CBAM is already verifying embodied-carbon and material data. Structuring it once in a passport-ready model, rather than in CBAM-only silos, means the binding ESPR fields slot straight in when the steel act lands as early as 2026.

One verified carbon dataset for ESPR and CBAM.

Iron and steel lead the first ESPR working plan, with a delegated act indicatively expected as early as 2026, and aluminium follows around 2027 - while CBAM is already live and demanding verified embedded emissions today. The producers and importers who win are the ones who structure their embodied-carbon, scrap-content and traceability data once, in a passport-ready model that also feeds CBAM. Book a scoping call and we will map your metal portfolio to the passport schema, reuse your CBAM-verified data, and return a fixed-scope implementation plan - live across English, German, French, Italian, Spanish, and Polish from day one.

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