EUROPEAN COMISSION
DPP
PREPRATION GUIDE
How Indian Steel Manufacturers Can Prepare for the EU Digital Product Passport in 2026
By First Welding Certification Technical Editorial Team
9 Min Read
20 Aug 2026
Table Of Contents
- What Is a Digital Product Passport for Steel?
- Why Should Indian Steel Manufacturers Care About the EU DPP?
- EU Digital Product Passport Timeline for Steel
- What Information Could a Steel DPP Contain?
- The Connection Between DPP and Steel Traceability
- A Practical DPP Readiness Roadmap for Indian Steel Manufacturers
- 10-Point EU DPP Readiness Checklist
- What Indian Steel Manufacturers Should Do in 2026
- Digital Product Passport vs Traditional Steel Documentation
- Final Takeaway
- Frequently Asked Questions
Key Takeaways
Organize Steel Product Data
Strengthen Material Traceability
Maintain Quality Documentation
Prepare for EU DPP Compliance
The European Union is moving toward a more transparent and digitally connected product economy, and steel is one of the sectors at the centre of this transition.
For Indian steel manufacturers exporting to Europe, the EU Digital Product Passport (DPP) is becoming an important compliance and data-readiness topic.
Under the EU Ecodesign for Sustainable Products Regulation (ESPR), iron and steel have been identified as priority product groups for future Digital Product Passport requirements. The European Commission currently indicates Q4 2026 as the expected timeline for adoption of the sector-specific delegated act for iron and steel.
At the same time, the EU Digital Product Passport Registry became operational on 20 July 2026, providing the infrastructure for registering DPPs and their associated identifiers and metadata.
For Indian manufacturers, this means the right time to prepare is before the final requirements become mandatory.
This guide explains what the Digital Product Passport means for steel manufacturers and the practical steps Indian exporters can take in 2026.
What Is a Digital Product Passport?
A Digital Product Passport is a digital record containing information about a product and, where applicable, its materials, characteristics, sustainability attributes, compliance information and lifecycle.
Instead of relying entirely on disconnected paper documents and PDFs, the DPP framework is designed to make relevant product information more accessible and interoperable across the value chain.
For iron and steel, the European Commission states that the future DPP framework is intended to improve transparency and traceability throughout the value chain. Depending on the final legislation, information may include product identification, technical and material data, circularity information, sustainability-related information and documentation supporting compliance and traceability.
A DPP should therefore be viewed as more than a QR code.
It is part of a broader product-data and traceability infrastructure.
Why Should Indian Steel Manufacturers Care About the EU DPP?
India is an important global steel producer and exporter, and many Indian manufacturers supply steel products, fabricated components and engineering products to European customers.
As EU requirements become increasingly focused on transparency, sustainability and digital traceability, manufacturers may need to provide more structured information about their products.
The DPP can potentially affect manufacturers involved in:
- Structural steel
- Steel plates and sections
- Fabricated steel components
- Industrial equipment
- Construction-related products
- Automotive supply chains
- Engineering products
- Machinery components
- Other iron and steel products covered by future EU legislation
The exact obligations will depend on the final product-specific delegated act.
The important point is that Indian manufacturers placing covered products on the EU market can fall within the scope of applicable DPP obligations, because EU DPP requirements apply to relevant economic operators placing covered products on the Union market, including imported products.
EU Digital Product Passport Timeline for Steel
The DPP framework is already moving from policy development toward implementation.
Key 2026 milestones
July 2026 — DPP Registry framework established
The European Commission established the operational framework for the DPP Registry.
20 July 2026 — DPP Registry becomes operational
The European Commission launched the DPP Registry and testing environment. The Registry supports registration of product identifiers and associated metadata.
Q4 2026 — Iron and steel
The Commission’s current indicative timeline identifies Q4 2026 for adoption of the ESPR delegated act establishing product-specific requirements for iron and steel.
The exact implementation dates and requirements can evolve as the legislative and technical process progresses.
Therefore, manufacturers should treat 2026 as a preparation year, not a year to wait for the final deadline.
What Information Could a Steel DPP Contain?
The final mandatory data fields for iron and steel will depend on the product-specific legislation.
However, the European Commission identifies several categories of information that may form part of the framework.
These include:
- Product identification
- Product classification
- Technical characteristics
- Material information
- Recycled content
- Sustainability-related information
- Circularity information
- Compliance documentation
- Traceability information
For a steel manufacturer, this means that existing quality and production records may become increasingly valuable as structured digital data.
The Connection Between DPP and Steel Traceability
One of the most important preparations for Indian steel manufacturers is to strengthen material traceability.
A manufacturer should be able to connect a finished product with its underlying material and production records.
For example:
Finished Product
↓
Product Identification
↓
Heat Number
↓
EN 10204 Material Certificate
↓
Chemical & Mechanical Test Results
↓
Production Records
↓
Inspection & NDT Records
↓
Sustainability / Environmental Data
This creates the foundation for reliable digital product information.
Without accurate traceability, creating a trustworthy DPP becomes significantly more difficult.
Step 1: Build a Strong Product Identification System
The first step is to ensure that every relevant product can be uniquely identified.
Manufacturers should establish consistent identifiers for:
- Product type
- Batch
- Heat
- Material grade
- Production order
- Component
- Finished product
Avoid using multiple unrelated identification systems across purchasing, production, quality control and dispatch.
The objective is to create one consistent product identity across the organisation.
Step 2: Strengthen Heat Number Traceability
Heat number traceability is particularly important for steel products.
A heat number can connect physical material to its production and testing records.
Manufacturers should ensure that:
- The heat number is recorded when material is received.
- The heat number is linked to the material certificate.
- Identification is maintained during storage.
- Heat identification is transferred after cutting.
- Fabricated components remain traceable to their source material.
- Final documentation retains the relevant material connection.
This creates a reliable foundation for future digital traceability.
Step 3: Digitise EN 10204 Certificates
Steel manufacturers commonly maintain material certificates such as EN 10204 Type 3.1 or 3.2 depending on the applicable requirements.
Instead of treating these certificates as isolated PDF documents, manufacturers should create structured records connecting:
Material → Heat Number → Certificate → Test Results → Product
This will make documentation retrieval faster and provide better data quality for future digital systems.
For companies already working with EN 10204 certification, this is one of the easiest areas to improve.
Step 4: Connect Production and Quality Records
A DPP-ready organisation should not have production information sitting in one system and quality information in another with no connection between them.
Where applicable, manufacturers should connect:
- Material certificates
- Heat numbers
- Purchase orders
- Production orders
- WPS
- WPQR
- Welder qualifications
- Welding records
- NDT reports
- Inspection reports
- Final inspection records
- Product identification
This creates a connected digital evidence chain.
Step 5: Start Collecting Sustainability Data
Digital Product Passports are closely connected with sustainability and circularity information.
For steel manufacturers, this means organisations should begin reviewing what environmental and material information they currently collect.
Potential data categories may include:
- Recycled content
- Material composition
- Production information
- Energy-related information
- Environmental performance data
- Carbon-related information
- Recycling and circularity information
The final mandatory data requirements will depend on the applicable EU legislation.
Manufacturers should therefore avoid assuming that every currently discussed data field is already legally mandatory.
Instead, they should build systems capable of collecting reliable data as requirements become clearer.
Step 6: Improve Data Quality
Digital compliance is only as reliable as the information behind it.
A manufacturer may have sophisticated software, but incorrect product data can still create compliance problems.
Common data-quality problems include:
- Incorrect heat numbers
- Duplicate product IDs
- Missing certificates
- Inconsistent product names
- Incorrect material grades
- Missing inspection records
- Different data formats between departments
- Manual spreadsheet errors
Manufacturers should establish validation procedures before data enters their digital product system.
Step 7: Prepare for QR Codes and Data Carriers
The European Commission indicates that DPP information for iron and steel is expected to be linked to products through a data carrier such as a QR code, subject to the final requirements.
This means manufacturers should consider how product identification will work physically.
For example:
Product → QR/Data Carrier → Unique Product Identifier → Digital Product Information
The data carrier should not be considered the DPP itself.
It is the mechanism that helps users or systems access the relevant digital product information.
Step 8: Prepare Your IT Infrastructure
Indian manufacturers do not necessarily need to build a completely new software platform immediately.
Instead, they should evaluate whether their existing systems can manage:
- Unique product identifiers
- Structured product data
- Document relationships
- API connectivity
- Access permissions
- Data updates
- Audit trails
- Digital certificates
- Product lifecycle information
The EU DPP architecture uses a decentralised approach, with product data remaining under the responsibility of relevant economic operators or their service providers, while the EU Registry provides a common indexing function.
This makes interoperability and data architecture important considerations.
Step 9: Review Your Existing EU Compliance Systems
DPP preparation should not happen separately from existing EU compliance work.
Indian steel manufacturers should review their existing systems for:
EN 1090
For structural steel manufacturers supplying the European market, EN 1090-related Factory Production Control and traceability processes can provide an important foundation.
EN 10204
Material inspection certificates should be accurately connected to the supplied material and product.
Welding Documentation
Where applicable, WPS, WPQR and welder qualification records should be linked to production records.
NDT
Relevant non-destructive testing reports should remain traceable to the inspected component.
EU CBAM
Carbon-related information should be managed separately but coherently with the broader sustainability and product-data strategy.
We already covers several of these EU compliance areas, including EN 1090, EN 10204 and EU CBAM.
A Practical DPP Readiness Roadmap for Indian Steel Manufacturers
Manufacturers can approach DPP preparation in four phases.
Phase 1: Audit Existing Data
Identify:
- What product data is already available?
- Where is it stored?
- Who owns the data?
- Which documents are still paper-based?
- Which records cannot currently be connected?
Phase 2: Standardise Traceability
Create consistent procedures for:
- Product identification
- Heat numbers
- Material certificates
- Production records
- Inspection records
- Document retention
Phase 3: Digitise and Integrate
Move toward structured digital records and connect relevant systems.
The goal is to create a relationship between:
Product + Material + Production + Inspection + Sustainability Data
Phase 4: Test DPP Readiness
Once the sector-specific requirements become clearer, compare your existing data model against the final EU requirements.
The EU has already made a DPP testing environment available alongside the Registry, giving economic operators an opportunity to understand the emerging system.
10-Point EU DPP Readiness Checklist
Indian steel manufacturers can use the following checklist:
- Identify products potentially affected by future EU DPP requirements.
- Establish unique product identification.
- Standardise heat number traceability.
- Digitise EN 10204 material certificates.
- Connect material certificates with production records.
- Link relevant inspection and NDT documentation.
- Review sustainability and environmental data collection.
- Establish data-quality controls.
- Evaluate QR/data-carrier and digital infrastructure.
- Monitor the final EU iron-and-steel delegated act.
What Indian Steel Manufacturers Should Do in 2026
The biggest mistake would be to wait until the final EU rules are published before starting preparation.
Manufacturers should begin with the information they already control.
A practical starting point is:
Material Traceability → Certificate Management → Product Identification → Production Records → Inspection Data → Sustainability Data → Digital Product Infrastructure
This approach also creates benefits beyond DPP compliance.
Better traceability can improve:
- Quality control
- Audit preparation
- Customer confidence
- Documentation retrieval
- Production visibility
- Export compliance
- Supply-chain transparency
Digital Product Passport vs Traditional Steel Documentation
| Traditional Documentation | DPP-Ready Approach |
|---|---|
| Separate PDF certificates | Connected digital product records |
| Manual document searches | Searchable product information |
| Paper-based traceability | Digital traceability |
| Heat number recorded separately | Heat number linked to product |
| Quality records stored separately | Connected quality records |
| Limited data accessibility | Controlled digital access |
| Reactive compliance preparation | Continuous compliance readiness |
The DPP does not necessarily eliminate existing certificates or technical documentation.
Instead, it represents a move toward more connected and accessible product information.
Final Takeaway
The EU Digital Product Passport is becoming an important consideration for Indian steel manufacturers targeting the European market.
The European Commission has already operationalised the DPP Registry, while iron and steel remain a priority product group under the ESPR framework. The current indicative timeline points to Q4 2026 for the sector-specific iron-and-steel delegated act.
The exact legal requirements will depend on the final EU rules. However, manufacturers do not need to wait before improving their systems.
The best preparation is to establish a strong foundation around:
Product Identification + Heat Number Traceability + EN 10204 Documentation + Quality Records + Sustainability Data + Digital Product Infrastructure
Indian steel manufacturers that start organising this information now will be better positioned to respond when the final DPP requirements are established.
We supports manufacturers with certification, inspection and compliance requirements for international markets, including European requirements for steel, welding and related industrial products.
Frequently Asked Questions
Is the Digital Product Passport mandatory for Indian steel manufacturers in 2026?
Not yet as a universal requirement for all steel products. The European Commission is developing product-specific DPP requirements for iron and steel, with the current indicative timeline pointing to Q4 2026 for adoption of the relevant delegated act.
Does the EU DPP apply to imported steel?
DPP obligations under applicable EU legislation can apply to economic operators placing covered products on the EU market, including imported products. The exact obligations for iron and steel will depend on the final sector-specific rules.
What should Indian steel manufacturers do before the final DPP rules?
Manufacturers should focus on product identification, material traceability, heat numbers, EN 10204 certificates, production records, inspection documentation and sustainability data.
Will a QR code be the Digital Product Passport?
No. A QR code or another data carrier can provide access to the relevant digital information, but it is not the complete DPP itself. The European Commission identifies data carriers as part of the DPP architecture for iron and steel.
Is EN 10204 being replaced by the Digital Product Passport?
No. DPP requirements and EN 10204 serve different purposes. EN 10204 concerns inspection documents for metallic products, while the DPP framework concerns broader digital product information and traceability.
When should Indian manufacturers start preparing?
Now. The DPP Registry is already operational, and the European Commission’s current indicative timeline places the iron-and-steel delegated act in Q4 2026. Early preparation allows manufacturers to identify data gaps and improve traceability before the final requirements take effect.