The iron and steel delegated act is not adopted yet. The Commission's indicative date is Q4 2026. When it arrives, one question will shape your records: does the passport apply at model, batch or item level? Here is what the Regulation says, what we expect, and what it means for the records you already keep.
What the Regulation says
Regulation (EU) 2024/1781 names three levels. Article 9(2) says each delegated act specifies whether the digital product passport applies at model, batch or item level. Article 10(1)(f) says the passport data shall refer to the product model, batch or item, as the delegated act sets out.
The same Article 9(2) list also covers the data, the data carrier, the layout and placement of that carrier, access rights, and who may create or update the passport. The level is therefore decided alongside the carrier, not on its own.
In this post, a model is one part design built to one specification. A batch is a group of parts made together in one run. An item is one physical part with its own serial number. The delegated act will set the official meaning for each product group.
Who decides
The manufacturer does not choose the level. The delegated act for each product group does. No product delegated act is adopted, so no product has a level in force today.
Article 9(1) sets the stakes. Once a product falls within a delegated act, it can only be placed on the market or put into service if a passport is available, and the data in it must be accurate, complete and up to date. The level decides which physical units a passport describes, so getting the level right affects every record behind it.
Why intermediate metal products will probably be batch level
This is an expectation, not a fact. The Commission has not yet said which level it will choose for iron and steel.
The clearest signal so far is a draft proposal from the Commission's Joint Research Centre, published for stakeholder consultation in 2026. It gives each data point a granularity of batch, model or item. It places the HEAT number, which identifies the steel melt, at batch level. It mentions a serial number for item-level cases.
A melt is shared by many parts, so batch level fits. A machining batch cut from the same heat also fits batch level. That is why we expect batch-level passports for many intermediate metal products.
Whether a machined part is itself in scope of the steel act depends on how that act defines the product. The act does not exist yet, so that question is open.
When item level is likely anyway
Some parts will need item level whatever the draft says. Serialised safety-critical parts are the obvious case, where the inspection and origin of one part matter most. A customer may also require item-level records in a supply contract. That requirement comes from the contract, not the Regulation, but it may arrive first.
Annex III of the Regulation lists the classes of data a passport may carry, including the unique product identifier, facility identifiers and operator identifiers. Those identifiers have to point at the right level, so the choice affects the whole record, not just the serial number.
What each level means for your records
You probably keep most of what each level needs already.
| Level | Identifier | Records you probably keep |
|---|---|---|
| Model | Part number and drawing revision | Drawing, specification and revision number |
| Batch | HEAT number for the steel, plus a batch or lot number for the machining run | Mill test certificate per heat, CMM results per batch, operator, start and end, PASS or FAIL |
| Item | Serial number on each part | Inspection record for that serial number, and any certificate issued with it |
Two points follow from the table. The identifier differs at each level, so one part can carry a batch reference and a serial number at the same time. The records themselves change little. The work is linking each record to the right identifier and keeping that link when the part leaves the shop.
How Traced maps the levels
Traced already holds the layers this table describes. A product record sits at the top, with its image, documents and default QC type. A 16-character trace ID is assigned to each serialised product or to each batch, and shown as a QR code.
Batch records sit beneath the product. Each batch holds the operator, start and end, a PASS or FAIL result and detailed QC data, such as CMM results, stored as JSON.
The passport itself is any JSON the customer uploads. It is versioned, carries a SHA-256 checksum and keeps previous versions. For a machined part, we would hold the passport at product level and keep the batch records underneath it. A trace ID can sit on a batch or on a serialised product, so the layout can follow whichever level the delegated act sets. Article 10(1)(a) asks for the passport to connect through a data carrier to a persistent unique product identifier, whichever level applies.
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.
What to do now
On standards, the Commission's implementing decision of 14 July 2026 cites six of the eight CEN-CENELEC standards for the digital product passport in the Official Journal. Those include the standards for unique identifiers and data carriers. The Commission's indicative date for the remaining two is November 2026.
- Ask your customers which level they expect for each part number, and write the answer down.
- Check that your batch records carry the heat reference and the inspection result for each batch.
- Keep serial records for any part a customer has asked you to trace individually.
- Re-check the Commission's pages before you act on a date. The iron and steel date is indicative only.
We will update this post when the iron and steel delegated act is adopted, or when the Commission changes its indicative date.
The same question comes up for other metals. Read our posts on DPPs for aluminium castings and steel components and where the DPP data carrier goes.
For the wider picture, see the digital product passport overview.
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