ESPR by product group

ESPR for Iron and Steel

Last updated · 2026-06-08Delegated act expected first, indicatively 2026 (not yet adopted)

Iron and steel is expected to be the first ESPR product group to get a delegated act, indicatively in 2026, ahead of the other priority groups. Requirements are likely to focus on carbon footprint, recycled content and recyclability. The exact rules only exist once the act is adopted, so this page separates the firm from the expected.

TL;DR

  • Iron and steel is expected to be the first ESPR product group with a delegated act, indicatively in 2026.
  • It is a priority group in the first ESPR Working Plan (adopted 16 April 2025).
  • Requirements are likely to focus on carbon footprint, recycled content and recyclability.
  • As an intermediate material, the data it carries flows into many downstream products.
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Status and timing

Where iron & steel stands today

Delegated act: Delegated act expected first, indicatively 2026 (not yet adopted)

Digital Product Passport: DPP expected to follow its delegated act (provisional)

  • Iron and steel is named as a priority product group, and is expected to be first in the sequence.
  • A delegated act is expected to set requirements on carbon footprint, recycled content and recyclability, plus information requirements.
  • Exact products and thresholds will only exist once the iron and steel delegated act is adopted.

Iron and steel is largely an intermediate material, so its DPP data is expected to feed into the passports of many downstream products.

Priorities and indicative timing come from the first ESPR Working Plan (2025-2030), under the framework of Regulation (EU) 2024/1781.

The data you will need

What a DPP for iron & steel will likely carry

  • Carbon footprint of the material, a flagged priority for iron and steel.
  • Recycled content and recyclability.
  • Grade and composition of the steel or iron.
  • Substances of concern present in the material.
  • Identifiers behind the data carrier that downstream products can reference.

The exact fields are set per product group in its delegated act, so treat this list as the expected shape of the data, not the final requirement. See the DPP data requirements guide for the full picture.

What to do now

What to do for iron & steel

  1. Confirm whether you place iron or steel products on the EU market as a manufacturer, importer or distributor.
  2. Start measuring the carbon footprint of your materials, since this is a flagged priority for iron and steel.
  3. Document recycled content, grade and composition so the data can flow to downstream customers.
  4. Track the iron and steel delegated act closely, as it is expected first, indicatively in 2026.
  5. Use the DPP Readiness Checklist to organise the data you will eventually publish.

FAQ

Iron & Steel and ESPR: common questions

When will ESPR rules apply to iron and steel?
Iron and steel is expected to be the first ESPR product group with a delegated act, indicatively in 2026. That date is an indicative Working-Plan estimate, not yet adopted law, so treat it as expected rather than firm.
What will ESPR require for iron and steel?
The delegated act is expected to set requirements focused on carbon footprint, recycled content and recyclability, with information carried via a Digital Product Passport. The exact thresholds do not exist until the act is adopted.
Why is iron and steel expected first?
The first Working Plan sequences iron and steel ahead of the other priority groups, indicatively in 2026. As a high-emission intermediate material, it is a priority for carbon-footprint requirements and feeds many downstream products.
Will iron and steel need a Digital Product Passport?
It is expected to, following its delegated act. Because iron and steel is an intermediate material, its passport data is expected to feed into the DPPs of downstream products that use it.
What should steel producers do now?
Start measuring the carbon footprint of your materials and documenting recycled content, grade and composition, since these are the fields a DPP is likely to require and the ones customers will ask for.

Related

Get ready for ESPR and the DPP

Work through the DPP Readiness Checklist, then explore the tools and guides built for your product group.

Get the DPP Readiness Checklist

This is guidance, not legal advice

This is guidance to help you understand how ESPR is expected to apply to iron & steel, not legal advice. ESPR is a framework law and most product rules arrive via delegated acts that are not yet adopted, so confirm with the official sources we link or a qualified adviser before acting.

Sources

  1. [1]Regulation (EU) 2024/1781 (ESPR), full text (EUR-Lex)retrieved 8 Jun 2026
  2. [2]European Commission: 2025-2030 ESPR Working Planretrieved 8 Jun 2026
  3. [3]Regulation (EU) 2023/1542 (EU Battery Regulation), full text (EUR-Lex)retrieved 8 Jun 2026
  4. [4]CIRPASS-2: EU Digital Product Passport pilotsretrieved 8 Jun 2026
  5. [5]JRC: Digital Product Passport data-requirements methodology (JRC145830)retrieved 8 Jun 2026

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