Steel and aluminium are first in line for the DPP, not fashion

Ask a room of manufacturers who the digital product passport (DPP) is aimed at and most will say fashion. The coverage has been about textiles, the sustainability conversation has been about clothing, and the metal industry has largely assumed it has years.

The EU working plan says the opposite. Iron and steel are scheduled ahead of textiles.

What the working plan actually schedules

The ESPR Working Plan 2025-2030, adopted on 16 April 2025 as COM(2025) 187, sets out the order in which product groups get their delegated acts. Iron and steel come first, with a delegated act indicatively in Q4 2026 and compliance following roughly two years later. Textiles and apparel, tyres and aluminium are indicatively scheduled for Q3 to Q4 2027, with compliance around 2029.

Those dates are indicative, not legal deadlines. A delegated act adoption date is not a compliance date: each act carries a transitional period of 18 to 36 months before the obligation binds. That is why the honest planning phrase for any category without an adopted act is "in phases from 2027", and why our regulation timeline marks fixed and indicative dates differently.

But the ordering matters even when the dates move. Being first in the queue means your category gets its rules while everyone else is still reading about someone else's.

Why metal moved to the front

The reasoning is not mysterious. Iron, steel and aluminium are high-volume, high-emission, highly recycled materials with an existing traceability culture: mill certificates, heat numbers, material test reports. Much of what a passport needs already exists as paper in these industries. The regulation is formalising a practice rather than inventing one, which makes the category an easier first candidate than a fashion supply chain with four tiers and no shared data standard.

That is good news and bad news. Good, because the raw information often exists. Bad, because existing does not mean structured, and a heat number in a PDF attached to an email is not a passport field.

Who this reaches, and it is wider than steelmakers

This is the part most companies miss. A delegated act for iron and steel does not stop at the mill. It reaches everyone who places a covered product on the EU market, and once your customers are inside the scope, your data becomes their problem and therefore yours.

If you fabricate structural components, make fasteners, cast parts, extrude aluminium profiles, or supply metal parts into automotive, construction or machinery, the passport requirements arrive through your customers' contracts before any regulator knocks on your door. Procurement moves faster than enforcement, every time.

What to do while the act is still indicative

None of the following requires knowing the final field list.

Find out which of your products fall in the category. Not approximately. Product line by product line, with volumes, so you know how much of your revenue is exposed and when.

Ask your material suppliers what they can evidence today. Origin, recycled content, substances of concern. Not what they claim, what they can document. A supplier who has never been asked will not answer quickly, and some cannot answer at all, which is a sourcing decision that takes months to act on.

Name the person accountable. The passport crosses sustainability, supply chain, quality and sales. Without one owner it stays everyone's job and therefore nobody's, which is the failure mode described in who owns the DPP inside your company.

The metal industry's advantage is that its data mostly exists. Its risk is assuming that means the work is small.

Sources

• ESPR Working Plan 2025-2030, COM(2025) 187 final, adopted 16 April 2025.
• Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation).