Iron, steel and aluminium are among the first product groups the EU Digital Product Passport rules are planned to reach. For a UK foundry, forge or machine shop that sells into Europe, the practical question is not the technology. It is what data you already hold, and where it lives. This post explains the EU working plan, what its dates mean in October 2026, and what a small supplier can do this winter.
What the working plan is and when it was adopted
The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, entered into force on 18 July 2024. It does not switch on passports for every product at once. Each product group gets its own delegated act, and a first working plan chooses which groups come first. The Commission published that plan as COM(2025) 187 final on 16 April 2025.
Iron and steel and aluminium are both in the first set. Both are classed as intermediate products. The years in the working plan are indicative, and the Commission's own DPP page now gives narrower windows for some groups. The Commission says these timelines may change as the legislative and technical work moves on.
The Regulation sets the basic duties. Under Article 9(1), a product covered by a delegated act can only be placed on the market if a passport is available, and its data must be accurate, complete and up to date. Under Article 10(1), the passport must be linked through a data carrier to a persistent unique product identifier, and the carrier must be physically present on the product, its packaging or the documents that come with it, as the delegated act specifies.
The working plan, row by row
The table lists each group from the working plan, with the Commission's refinement from its DPP page as checked in October 2026. Every row is indicative. None is adopted.
| Product group | Category | Working plan year | Commission refinement | Status |
|---|---|---|---|---|
| Iron and steel | Intermediate product | 2026 | Q4 2026 | Not adopted, indicative |
| Aluminium | Intermediate product | 2027 | Q3 to Q4 2027 | Not adopted, indicative |
| Textiles (apparel focus) | Final product | 2027 | Q4 2027 | Not adopted, indicative |
| Tyres | Final product | 2027 | Q3 to Q4 2027 | Not adopted, indicative |
| Furniture | Final product | 2028 | 2028 | Not adopted, indicative |
| Mattresses | Final product | 2029 | 2029 | Not adopted, indicative |
| Repairability, including a score | Horizontal | 2027 | None given | Not adopted, indicative |
| Recycled content and recyclability of electrical and electronic equipment | Horizontal | 2029 | 2029 | Not adopted, indicative |
No product delegated act is adopted yet. The instruments adopted so far set up the infrastructure: the registry rules, Implementing Regulation (EU) 2026/1778, in force from 6 August 2026, and Implementing Decision (EU) 2026/1736 of 14 July 2026, published in the Official Journal on 15 July 2026, which cites six harmonised DPP standards. The registry is a Commission and authority system for product identifiers. TraceID does not register passports with the EU registry and does not connect to it.
Why iron, steel and aluminium are intermediate products
The working plan treats iron and steel and aluminium as intermediate products, meaning materials or parts sold on to be made into something else. The scope of the act has not been set. The delegated act will decide which steel and aluminium products are in scope, and the JRC draft refers to intermediate steel products. A shop making castings, forgings or machined parts should watch that draft for whether its products are in, and should not assume either way. The obligation falls on whoever places the product on the EU market, so the question for each product is who does that.
In practice, a UK supplier that places products on the EU market or in Northern Ireland should check whether its products fall within the act once it is adopted. The government's own call for evidence treats EU DPP requirements as applying in Northern Ireland under the Windsor Framework. A business that sells only to customers in Great Britain is not, on our reading, covered by the EU act.
Great Britain does not yet have an equivalent law. The Department for Business and Trade published a call for evidence on digital product records on 27 July 2026. It closed on 21 September 2026, and the government has not yet determined its approach for Great Britain. This is our reading of the regulation, not legal advice. Check your position with your customers and an adviser before you rely on it.
What the JRC steel proposal lists
In spring 2026 the Commission's Joint Research Centre published a draft proposal on the content of a steel passport, for stakeholder consultation. It is a draft, not an adopted act. The steel delegated act it would feed into has not been adopted. The draft lists candidate data, including:
- Identifiers: a unique product identifier, a unique operator identifier and a unique facility identifier.
- Product identification: the HEAT number from the mill test certificate, a model-level identifier, a CAST or LOT number where it applies, and the global trade item number.
- Producer and origin: the country of origin, melt and pour information, and the manufacturing date, which the draft says is typically reported in the mill test certificate.
- Classification: the TARIC code, the steel grade and designation, and the technology route.
- Compliance and use: declarations of conformity, technical documentation, manuals and safety information.
Treat this as a list of candidates, not a specification. The adopted act will decide what is required.
What to do this winter
You do not need a system to start. You need the data to exist in a usable form. Four steps will help whatever the final act says:
- Find where your batch data lives. For most shops it is spread across melt or furnace records, foundry or forge logs, inspection output and the paperwork that travels with the job.
- Start keeping it per batch, not per year. Give each batch a number that follows the parts through the shop.
- Keep certificates with the batch. Mill test certificates, material certificates and inspection records should link back to the batch number, not sit in a folder by supplier.
- Ask your larger customers which identifiers and records they expect. Their answers show what they will want before the acts are adopted.
How Traced holds it
Traced is the TraceID module for product traceability and passports. It holds the product side of this in four parts:
- A product record, with an image, certificates and manuals attached.
- Batches beneath it, each with an operator, a start and end, a PASS or FAIL result, and the QC data behind it, such as CMM results.
- A passport, which is any JSON the customer uploads. Each version is kept, and each carries a SHA-256 checksum.
- A 16-character trace ID for each serialised product or each batch, shown as a QR code. A public scan page shows the passport to anyone who scans it.
Traced does not yet check a passport's fields against the regulation, because the rules for iron, steel and aluminium are still being finalised. We will adopt the iron and steel and aluminium delegated-act schemas as they are published.
For how passports work in Traced, see the digital product passport page.
Frequently asked questions
Is the iron and steel act adopted?
No. The Commission's DPP page gives Q4 2026 for the iron and steel delegated act, and it describes that date as indicative. No adopted act exists yet, and at the time of checking we found no draft. Until an act is adopted, no iron or steel product has a passport requirement in force.
Does this apply to a UK foundry?
It depends on where you sell, and on what the act covers. The obligation falls on whoever places the product on the EU market. A UK foundry that sells into the EU or Northern Ireland should check whether its castings are in scope once the act is adopted. Whether castings are in scope depends on the act, which has not been adopted and whose scope has not been set. On our reading, a business that sells only to customers in Great Britain is not covered by the EU act. Great Britain does not yet have an equivalent law, and the government has not yet determined its approach. This is not legal advice.
What level will the passport sit at?
Not yet settled. Article 9(2) says each delegated act decides whether a passport applies at model, batch or item level. The JRC draft for steel is a proposal for consultation. It suggests batch level for the HEAT number, item level for a serial number, and model level for the product number and the global trade item number. Your passport will follow whatever the adopted act says.
Need a clearer record model?
Discuss a practical Traced or Verified setup for your product and inspection workflow.
Talk to usRelated Articles
The shift towards connected, transparent products
The EU's Digital Product Passport marks a shift from fragmented documentation towards live,...
Read The shift towards connected, transparent productsWhat is the Digital Product Passport in the United Kingdom?
The UK is no longer part of the EU, but UK exporters selling into the EU will need passports as each...
Read What is the Digital Product Passport in the United Kingdom?Why is the EU introducing Digital Product Passports?
The EU introduced DPPs to close information gaps that hinder circularity and enable comparable data...
Read Why is the EU introducing Digital Product Passports?