Digital Product Passport for metal components

The basics

What a Digital Product Passport is

A Digital Product Passport links a product to its data through a data carrier, which points to a persistent unique product identifier. The rules sit in Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, or ESPR.

The ESPR entered into force on 18 July 2024. It sets no single date. Each product group's delegated act makes a passport mandatory for that group.

The rules

What the Regulation requires

Article 9(1) says a product covered by a delegated act can only be placed on the EU market if its passport is available. The delegated act then sets the detail.

Level. Each delegated act says whether the passport applies at model, batch or item level (Article 9(2)).
Data carrier. The carrier sits on the product, its packaging or its documents, as the act specifies (Article 10(1)(b)).
Data. Annex III lists the data classes, including the unique product identifier, the global trade item number and the manufacturer's identifiers.
Persistence. The passport stays available for at least the product's expected lifetime, even if the operator becomes insolvent (Articles 9(2) and 11).
Registry. The EU registry went live on 20 July 2026, under Implementing Regulation (EU) 2026/1778. Registration is not proof of compliance (Article 13(5)).

Six of the eight CEN-CENELEC JTC 24 standards are cited in the Official Journal, through Implementing Decision (EU) 2026/1736 published on 15 July 2026. The other two are not yet cited.

TraceID does not register passports with the EU registry and does not connect to it.

Level

Why we expect a casting or machined part to be batch-level

Article 9(2) leaves the level to each delegated act, so no product group has a level in force yet.

For steel, the Commission's Joint Research Centre published a draft for stakeholder consultation in 2026. It puts the heat number at batch level. It is a draft, not an adopted act. We therefore expect a casting or machined part to be batch-level, carried with its heat or lot number. That is an expectation. The delegated act for the product group will decide.

Traced follows that shape. A serialised part can carry its own trace ID instead of the batch's.

Carrier

Where the carrier goes on a metal part

The carrier goes on the product, its packaging or its documents. Each product group's delegated act says which. None is adopted, so nothing is fixed for metal parts yet.

Until then, the carrier can go on the part, a tag, or the packaging and batch paperwork. Which is right depends on the part and its product group's rules.

Traced gives each serialised part or batch a 16-character trace ID, shown as a QR code. QR today, NFC-ready: NFC is not live yet, and the record is designed so a tag can be added later.

In Traced

How a Traced product record and batch map to the passport

Traced keeps one record per product. Batches sit beneath it, and the passport sits against the product.

Product record: the model-level information, with its image, certificates and manuals.
Batch: the operator, start and end times, PASS or FAIL result and detailed QC data, recorded beneath the product.
Passport: the passport data itself, held against the product.
Trace ID and QR code: the data carrier that links the physical part or batch to its record.
Scan page: the public view of the passport, with the same record available as JSON.

Scanning opens a public, mobile-first page. Signed-in staff also see the batch record, and every scan is logged.

Status

What is and is not validated today

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.

A passport is any JSON the customer uploads, versioned, with a SHA-256 checksum, previous versions kept. The checksum lets you confirm that a stored version has not changed since upload. It does not show that the content meets the regulation.

Timeline

The timeline

The Commission's first working plan, COM(2025) 187 final, was published on 16 April 2025. The timings below come from the Commission's digital product passport pages, checked on 18 October 2026. Every row is indicative. None of these product acts has been adopted.

Product group	Adopted or indicative	Indicative timing
Iron and steel	Indicative	Q4 2026
Aluminium	Indicative	Q3 to Q4 2027
Textiles, with an apparel focus	Indicative	Q4 2027
Tyres	Indicative	Q3 to Q4 2027
Furniture	Indicative	2028
Mattresses	Indicative	2029
Repairability, horizontal measure	Indicative	2027
Recycled content and recyclability of electrical and electronic equipment, horizontal measure	Indicative	2029
Energy-related products, 16 items carried forward from the earlier plan	Indicative	2026 to end 2030, item by item

Adopted means published in the Official Journal or in force. Indicative means a planning date that is not set in law. The working plan treats iron and steel and aluminium as intermediate products, and the scope of those acts has not been set.

The first passport obligation is in the Battery Regulation (EU) 2023/1542. From 18 February 2027, light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries must have a battery passport (Article 77(1)). Portable batteries are not covered by that date.

The delegated act for DPP service providers is not adopted. Its indicative date is Q2 to Q3 2027.

The UK

UK status

The UK has no digital product passport requirement. 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. For Great Britain, the UK government 'has not yet determined its approach'.

EU passport rules apply in Northern Ireland under the Windsor Framework. The call for evidence also mentions sector work on batteries, construction products, toys and low-carbon industrial products such as steel, cement and concrete.

Questions

Common questions

Answers come from the Regulation, the Commission and the UK government.

When does a passport become a requirement for my parts?

There is no single start date. Passports are introduced product by product, through delegated acts under the Ecodesign Regulation. The Commission's FAQ says a product group being in the working plan does not automatically make a passport mandatory. No product delegated act has been adopted yet. The first obligation is under the Battery Regulation, from 18 February 2027, and covers only some batteries: electric vehicle, light transport and industrial batteries above 2 kWh.

Which product rules are closest for metal parts?

The working plan treats iron and steel as an intermediate product, and the Commission's indicative date for its act is Q4 2026. Aluminium is indicatively planned for Q3 to Q4 2027. Neither act has been adopted. A JRC draft proposal for steel content was prepared for stakeholder consultation in 2026. It is a draft proposal, so it is not a rule.

Does this apply in Northern Ireland and Great Britain?

EU DPP requirements apply in Northern Ireland under the Windsor Framework. The UK has not adopted a DPP requirement. The Department for Business and Trade call for evidence closed on 21 September 2026, and for Great Britain the UK government 'has not yet determined its approach'. If you ship to Northern Ireland, plan for the EU requirements. For Great Britain, watch the outcome of that call for evidence.

Who creates the passport, us or our customer?

The Commission's FAQ says primary responsibility for creating a passport, and for its accuracy, sits with the economic operators that place the product on the EU market. That includes the manufacturer, the authorised representative and the importer. If you sell into the EU, check which of these roles you hold. Traced does not register passports with the EU registry and does not talk to it.

What must a passport contain?

Each product's delegated act sets the data, by reference to Annex III of the Regulation. Annex III lists the unique product identifier, the global trade item number, commodity codes, compliance documents, user manuals, manufacturer and facility identifiers, and the importer's EORI number. A JRC draft for steel adds more, but it is a draft. Traced does not yet check a passport's fields against the regulation.

Is the passport kept per model, per batch or per item?

Each delegated act decides. Article 9(2) lets the act say whether the passport applies at model, batch or item level, and Article 10(1)(f) says the data must refer to the model, batch or item that the act specifies. No product act has been adopted, so no product has a level in force today. The JRC steel draft proposes a level for each data point, such as batch for the heat number, but that is a proposal.

What data carrier will the passport use?

The delegated act for each product group sets the data carrier. Article 10(1)(b) says it must sit physically on the product, its packaging or the documents that come with it, as the act specifies. The Commission's FAQ says CEN-CENELEC JTC 24 is assessing technologies, including QR codes and NFC chips. No carrier is fixed for metal parts yet, so check each delegated act when it appears.

What does the EU registry hold, and does it hold our data?

The Commission's FAQ says the registry stores unique identifiers and links each one to its passport, but does not store the detailed product data itself. The registry became operational on 20 July 2026. Under Article 13(5), a registration identifier is not proof of compliance. Customs links to the registry are expected around 2029. Traced does not register passports with the EU registry and does not talk to it.

Do we need a service provider for the back-up copy?

The Commission's FAQ says operators must provide a back-up copy of the passport through a third-party service provider, under Article 10(4). The back-up keeps the passport available for the product's expected lifetime, even after insolvency. The registry includes a list of verified service providers. The delegated act on service providers is not adopted, and its indicative date is Q2 to Q3 2027.

Are the standards final?

Not all of them. CEN-CENELEC JTC 24 is writing eight standards for the passport. Implementing Decision (EU) 2026/1736, published in the Official Journal on 15 July 2026, cites six as harmonised standards for Articles 10 and 11. EN 18239 and EN 18246 were published by CEN on 16 September 2026 but are not yet cited. The Commission's indicative date for those two is November 2026, so do not treat all eight as harmonised yet.