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 linked to a product using a data carrier, such as a QR code or another approved identifier.It helps make important product information available throughout the product’s journey in the supply chain.For iron and steel products, the European Commission recommends that the DPP include details like product identification, technical and material data, information on circularity, sustainability features, and proof of compliance.These details will be decided in the final rules.The European DPP regulation is included in Regulation (EU) 2024/1781, which is part of the Ecodesign for Sustainable Products Regulation.
Although the final decision will set the required fields, manufacturers can already begin gathering the types of information that are probably going to be needed.
| 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 aim is to make sure that the real steel product is correctly linked to its digital data.This is especially important when steel goes through several steps in making, from creating the raw materials, to processing and building it, all the way up to when it’s finally used in a project.
No matter what, the Digital Product Passport works well only if the data it uses is accurate.
For example, if a steel plate has a specific heat number, the manufacturer needs to be able to link that number to the records of production and testing.
This shows how important it is to have proper material documentation.EN 10204 inspection certificates help by providing clear information about the metal product and the testing that was done.If you need an independent check, EN 10204 Type 3.2 certificates show that both the manufacturer and an independent body have verified the product.
To learn more about how heat numbers, inspection certificates, and material identification connect to being ready for the Digital Product Passport, read our article “Steel Traceability for EU Exports: EN 10204, Heat Numbers & Digital Product Passport.”
The DPP preparation process follows this workflow:
Steel Production → Product Identification → Testing & Inspection → Documentation → Digital Data Record → Data Carrier → EU Supply Chain
It’s important to note that the digital record should not be made separately from the manufacturing records.
Instead, it should be connected to the original source information.
For makers of structural steel products, they need to consider technical requirements, delivery documents, and the EN 10025-1 standard.
This standard covers the general technical delivery conditions for hot-rolled structural steel products.
1.Find out which steel products are meant for the EU market and check what EU rules and specific product requirements apply.
2.Check what product data is already available in ERP, production, lab, quality, and inspection records.
3.Make sure that heat numbers, batch numbers, product IDs, and other identifiers are correctly linked to production records.
4.Organize all technical documents like material certificates, inspection reports, test results, and other proof of conformity.
5.Find out what information is missing by comparing current records with the data needed for the final version of the DPP.
6.Prepare to connect product identifiers with digital information through the DPP system as required.
The DPP Registry was launched by the European Commission in July 2026 and is the first step in setting up the full DPP system.
No.The Digital Product Passport cannot take the place of the required product standards, inspection reports, and conformity assessment processes.However, the DPP is meant to make product information available in a digital format.As a result, technical documents and compliance records could be part of the information within the larger product data system.
This means that preparing the DPP should be done along with the relevant technical standards and conformity assessment requirements, not as a separate certification process.
Additionally, if some steel products are covered by EN 10025-1 certification, manufacturers should review the requirements related to this certification.
Digital Product Passports are becoming a major concern for Indian steel companies that want to sell their products in Europe.Even though exact rules for the iron and steel sector haven’t been set yet, manufacturers can start preparing now.They can do this by improving how they identify products, track their history, keep records of quality, and make data digital.
Information like heat numbers, inspection reports, test results, and necessary certifications can form a solid foundation for accurate product data.
It’s also important to think about existing standards and certification needs along with the DPP requirements.
Indian steel exporters should get ready early.
This way, they’ll find it easier to follow new EU rules about DPPs for steel products later on.
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.
Indian steel makers who want to sell their products in the EU market should start by identifying their products, tracking the materials used, and organizing technical documents.First Welding Certification Pvt Ltd (PRVÁ ZVÁRAČSKÁ, a.s.) offers certifications based on European standards, such as EN 10204 3.2 for checking metallic products and EN 10025-1 for hot-rolled structural steel.
If you want to understand how the Digital Product Passport compares to other EU requirements, you can read our article titled “Digital Product Passport vs CE Marking: What Steel Manufacturers Need to Know”.
Also, if you’re getting ready for the EU Digital Product Passport, you might find our article “How Indian Steel Manufacturers Can Prepare for the EU Digital Product Passport in 2026” helpful.
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