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Digital Product Passport vs CE Marking: What Steel Manufacturers Need to Know
By Technical Editorial Team
5 Min Read
18 Aug 2026
Table Of Contents
Key Takeaways
DPP connects product data across the value chain
CE Marking confirms applicable EU requirements
DPP and CE Marking serve different purposes
Steel manufacturers should prepare product data early
The Digital Product Passport (DPP) is a digital document containing product data throughout the value chain. According to the European Ecodesign for Sustainable Products Regulation (ESPR), the Digital Product Passports (DPP) are expected to increase product transparency, traceability, and information access.
In the case of iron and steel, the European Commission regards the industry as a priority product group. The information expected to be contained in the DPP for this product group includes product identification, technical and material data, recycled content, sustainability information, and compliance information.
The CE Marking means that the product is in compliance with the relevant EU legislation. The manufacturers are responsible for determining the relevant legislation and harmonised standards, conducting the necessary conformity assessment procedure, preparing technical documentation and affixing the CE marking when required.
In case of structural steel and aluminum construction products, EN 1090 may be especially important for the conformity assessment procedure according to the Construction Products Regulation. The EN 1090 certification provided by First Welding Certification Pvt Ltd (PRVÁ ZVÁRAČSKÁ, a.s.) includes Factory Production Control, welding, materials traceability and conformity assessment procedures.
| Comparison | Digital Product Passport | CE Marking |
|---|---|---|
| Main purpose | Product information and transparency | Demonstrates applicable EU conformity |
| Focus | Product data, traceability and sustainability | Safety, performance and legal conformity |
| Format | Digital information linked to a product | Physical CE mark supported by documentation |
| Main framework | ESPR | Applicable EU legislation |
| Steel relevance | Product-specific DPP requirements are being developed | Applies where relevant EU legislation requires CE marking |
| Typical information | Material, circularity, sustainability and compliance data | Declaration/documentation and conformity information |
| Does it replace the other? | No | No |
In the EU system, the DPPs can also have compliance information like declarations of conformity, technical documentation, and conformity certificates where necessary. This demonstrates that the DPP and CE Marking can be related but perform different roles.
DPP will most probably make the importance of structured product data and traceability very important for steel producers and exporters.
For steel producers manufacturing welded products, it is important to ensure that the welding process adheres to specific requirements, among others. The EN ISO 3834 Certification covers quality requirements for fusion welding of metallic materials and can be considered alongside other pertinent product and conformity requirements.
Steel-specific future requirements will most probably cover topics like:
• Product Identification
• Composition of Materials
• Technical Features
• Recycled Content
• Sustainability Information
• Circular Economy Information
• Compliance Documentation
• Product Traceability
Currently, the European Commission claims that the requirements for iron and steel will be set by a product-specific delegated act. The indicative timeline provided by the European Commission points towards Q4 2026.
No.
A Digital Product Passport is not a replacement for CE Marking. CE Marking addresses applicable EU conformity requirements, while the DPP is designed to make relevant product information accessible throughout the product lifecycle.
For manufacturers, this means that Digital Product Passport vs CE Marking should not be treated as an either-or decision. Depending on the product and applicable legislation, a manufacturer may need to meet CE conformity requirements while also preparing the product information required for a DPP.
Steel manufacturers exporting to Europe can begin by improving the quality and traceability of their existing product information.
A practical preparation checklist includes:
| Area | What to prepare |
|---|---|
| Product identity | Product and manufacturer identification |
| Material data | Steel grade, composition and technical characteristics — see EN 10025-1 Certification |
| Traceability | Link materials and products to production and inspection records, including EN 10204 Type 3.2 certification where applicable |
| Quality records | Inspection and testing documentation |
| Sustainability | Relevant recycled-content and environmental data |
| Compliance | Applicable declarations and certificates |
| Digital records | Structured information that can be accessed electronically |
- How Indian Steel Manufacturers Can Export to Europe: Complete EU Compliance Guide (2026)
- CE Marking vs EN 1090: Key Differences Every Manufacturer and Exporter Should Know (2026 Guide)
- EN 10025-1: Technical Delivery Conditions for Hot Rolled Structural Steel Products – Complete Guide
- EN 10204 Type 3.2 Inspection Certificate: Complete Guide for Manufacturers and Buyers
This comparison between the Digital Product Passport and CE Marking is relevant since both of these instruments apply to different sides of the EU market regulations. While the former relates to product conformity, the latter is supposed to promote the transparency and traceability of digital products. In order to prepare for the new regulation, manufacturers of steel products have to be ready with reliable information about their materials, products, quality and sustainability.
How does Digital Product Passport differ from CE Marking?
Digital Product Passport offers structured digital product information, whereas CE Marking denotes conformity with relevant EU legislation. They are intended to serve different purposes, and one cannot be considered an automatic replacement for another.
Is Digital Product Passport meant to replace CE Marking?
No. The DPP does not replace CE Marking. Where CE Marking is required according to the relevant law, manufacturers should still follow the relevant conformity assessment procedures.
Do I have to put a DPP on my steel products?
As steel is one of the product groups prioritized in the ESPR, specific requirements to DPP for such products will be elaborated. At the moment, according to the European Commission, the relevant delegate act concerning iron and steel products is expected in Q4 2026.
Which data may be included into the steel DPP?
Depending on the specifics of the final requirement, the data may include product identification, technical and material characteristics, recycled material share, sustainability information and circularity data.
Should steel manufacturers prepare for DPPs?
Yes. Before the steel-specific requirements to DPPs are finalized, you can already improve your product data and materials traceability, product data management and quality documentation.