STEEL DPP REQUIREMENTS
DATA & TRACEABILITY
EU COMPLIANCE 2026
By First Welding Certification Technical Editorial Team
6 Min Read
20 Aug 2026
Organize Steel Product Data
Strengthen Material Traceability
Maintain Quality Documentation
Prepare for EU DPP Compliance
A Digital Product Passport (DPP) is a digital record associated with a product via some form of data carrier like QR code or other allowed identifier. It serves to ensure accessibility of relevant product information at all stages of the value chain.In case of iron and steel, the European Commission suggests that DPP may contain product identification, technical and material information, circularity information, sustainability-related attributes, and compliance documentation. All of them will be defined in the final rules.European DPP regulation is laid down in Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation.
Even though the final delegated act will establish the mandatory fields, manufacturers can already start collecting the categories of information which are most likely to be included.
| Data Category | Examples for Steel Manufacturers |
|---|---|
| Product identification | Product type, grade, identification number |
| Material information | Steel grade, dimensions, material characteristics |
| Traceability | Heat number, batch/lot identification, production records |
| Quality documentation | Inspection documents, test results and certificates |
| Sustainability information | Recycled content and other environmental data |
| Compliance documentation | Relevant standards, declarations and technical records |
The goal is to ensure the reliability of association between the actual physical steel product and the data associated with it digitally.This is especially true in case of multiple stages of manufacturing of steel starting from production of raw materials, through processing and fabrication to the final application stage.
In any case, the reliability of the Digital Product Passport depends on the quality of the data it is based on.
For instance, when a steel plate has some particular heat number assigned, the manufacturer should be capable of associating that number with production and inspection documentation.Here comes the importance of existing material documentation. EN 10204 inspection certificates can offer structured information about the metallic products and their inspection and testing process. In case independent verification is required, EN 10204 Type 3.2 inspection certificates imply verification from the manufacturer and independent inspection authority.
For more detailed explanation of how heat numbers, inspection certificates and material identification relate to DPP readiness, read our article “Steel Traceability for EU Exports: EN 10204, Heat Numbers & Digital Product Passport.”
One can consider the following workflow of the DPP preparation process:
Steel Production → Product Identification → Testing & Inspection → Documentation → Digital Data Record → Data Carrier → EU Supply Chain
What is essential here is that the digital record must not be generated independently from the manufacturing records and should be related to the source information.
For producers of structural steel products, it would be necessary to take into account technical requirements and delivery documentation along with EN 10025-1 standard. This one includes general technical delivery conditions of hot-rolled structural steel products.
1.Determine the EU-bound steel products
First, identify which steel products are made for the EU market and what EU laws and product-specific requirements are applicable.
2. Determine existing product data
Identify the data currently available in ERP, production, laboratory, quality and inspection records.
3. Improve product identification
Make sure that heat numbers, batch numbers, product IDs and other product identifiers are consistently correlated with production records.
4. Structure technical documentation
Organize material certificates, inspection reports, test results and other conformity documentation.
5.Determine data gaps
Compare existing records with the sustainability, technical, material and traceability information expected to be required for the final version of the DPP.
6. Connect product identifiers with digital information
In connection with the final requirements, manufacturers should be ready to link product identifiers with digital information via DPP infrastructure.
The DPP Registry of the European Commission was launched in July 2026 and became a first step towards implementing the entire DPP system.
No. The Digital Product Passport cannot replace the applicable product standards, inspection reports and conformity assessment requirements.However, the DPP is meant to make the product data available digitally. Therefore, technical documentation and compliance records may become one of the sources of information within the broader product data system.
This means that DPP preparation should be considered together with the applicable technical standards and conformity assessment requirements, rather than treated as the separate certification process.Moreover, if some of the steel products are subject to EN 10025-1 certification, manufacturers can check the requirements associated with this certification.
The requirement of Digital Product Passports is becoming an increasingly significant issue for Indian steel companies that wish to sell their products in Europe. Although specific product requirements for the iron and steel industry have not yet been established, manufacturers can start getting ready for this by improving product identification, traceability, quality documentation, and digitization of data.
Data related to heat numbers, inspection reports, tests, and relevant certification documents can serve as a good basis for reliable product data. In addition, standards and certification requirements must be considered together with DPP requirements.
It will be helpful for Indian steel exporters to prepare in advance so that later on it will be easier to comply with new EU requirements related to steel-specific DPP rules.
According to the EU, iron and steel are a priority product group for developing DPP in 2026. However, the specific mandatory data requirements will be established according to the relevant product-specific delegated act.
Indian manufacturers should already start preparing product identification, material data, heat/batch traceability, testing data, inspection documentation and sustainable information until the final steel-specific requirements are published.
Not necessarily. DPP requirement does not automatically imply that every steel product needs a 3.2 certificate. The relevant inspection document depends on the product, standard, contractual requirements and conformity requirements.
Steel traceability means that there is the link between the product and its manufacturing, testing and inspection process. Therefore, identifiers like heat number become important in organizing information about the product for digital traceability.
There is no automatic DPP requirement for all steel products. There are product-specific regulations on iron and steel that the EU develops now, and only the final legal requirements will define which products have obligations and when.
For Indian steel manufacturers planning to sell their products on EU market, Digital Product Passport preparation starts with product identification, material traceability and technical documentation organization. First Welding Certification Pvt Ltd (PRVÁ ZVÁRAČSKÁ, a.s.) provides certification according to relevant European standards, including EN 10204 3.2 inspection certification for metallic products and EN 10025-1 for relevant hot-rolled structural steel products.
If you need to compare DPP with some other requirement in the EU market, then you can read our article “Digital Product Passport vs CE Marking: What Steel Manufacturers Need to Know”.In addition, if you are interested in preparing for the EU Digital Product Passport, then “How Indian Steel Manufacturers Can Prepare for the EU Digital Product Passport in 2026” may be useful for you.
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