The steel Digital Product Passport: what ESPR means for Turkish mills, and what is still open

Ahmed Furkan Gul · Ganrich Advisory · 2 November 2026 · 10 min

Turkish steel exporters have spent 2026 learning to supply embedded-emissions data to EU CBAM declarants. The next EU data requirement is already on the calendar. The European Commission's Digital Product Passport (DPP) timeline lists the ecodesign delegated act for iron and steel for adoption in Q4 2026, first in line among product groups under the Ecodesign for Sustainable Products Regulation (European Commission, DG GROW, accessed 2 Nov 2026).

This article separates what is decided from what is not, so a steel or metals export manager can plan 2027 without guessing.

What is decided today

• The legal basis. The DPP rests on the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR). Product-specific DPP requirements come either from ESPR delegated acts or from separate EU laws such as the Batteries Regulation and the Construction Products Regulation (European Commission, DG GROW, accessed 2 Nov 2026).
• The registry. Commission Implementing Regulation (EU) 2026/1778 on the DPP registry was published in the Official Journal on 17 July 2026 (T.C. Ticaret Bakanlığı, DPP page, accessed 2 Nov 2026). The Commission says the registry became operational on 20 July 2026 (European Commission, DG GROW).
• What the registry holds. It stores the unique identifier of each product with mandatory registration data. The full product information is kept by the economic operator or a DPP service provider. A data carrier such as a QR code links the product to its passport, and for imported products the registry's unique registration identifier can be checked at customs (European Commission, DG GROW).
• Standards. The first six DPP standards were published in the Official Journal by July 2026 (Ticaret Bakanlığı); the Commission expects an implementing decision on the remaining two in November 2026 (European Commission, DG GROW).

What ESPR itself already says about the passport

Even without a steel act, the framework regulation fixes the architecture. ESPR's recitals say (Regulation (EU) 2024/1781 of 13 June 2024, recitals):

• The passport should be linked to a unique product identifier and, where appropriate, to a unique operator identifier and a unique facility identifier, so that the actors and manufacturing facilities related to a product can be traced. These identifiers and the data carrier should follow internationally recognised standards.
• The passport should let economic operators, named as manufacturers, authorised representatives, importers, distributors, dealers and fulfilment service providers, access, introduce or update data, without endangering the protection of confidential business information.
• Data should be accurate, complete and up to date, and the passport can be complemented by non-digital information such as a label or product manual.

For a Turkish mill, the facility identifier is the notable point: it ties a product to the plant where it was made, much as CBAM ties emissions to an installation. Whether the steel act requires it is for the act to decide.

Steel is first in line for ESPR, and why it matters for Türkiye

The Commission's list of planned ESPR delegated acts puts iron and steel in 2026, ahead of textiles, tyres and aluminium (2027), furniture (2028), and mattresses and ICT products (2029) (European Commission, DG GROW, accessed 2 Nov 2026).

For Türkiye this is a direct exposure. Turkish mills that ship to the EU already deal with CBAM (our CBAM data readiness service). A steel passport would add a product-level information duty at the point of placing on the EU market.

The difference matters. Under CBAM the declaration duty sits with the EU importer, and the Turkish installation supplies emissions data. Under the DPP the information is tied to the product itself: the data carrier on the product or batch, the registry record and the identifier that customs can check are links in one chain (European Commission, DG GROW). Data readiness is therefore not only a job for the environment or sustainability team; it involves production planning, quality, shipping and IT. Which data sit with whom, how they are shared with the EU buyer and how commercially sensitive data are protected are questions to start discussing now.

Timeline: what comes when

The Commission publishes an indicative timeline, subject to change (European Commission, DG GROW, accessed 2 Nov 2026):

The key planning rule: after an ESPR delegated act is adopted, economic operators get a transition period of at least 18 months (European Commission, DG GROW). If the steel act is adopted in Q4 2026, obligations would not apply before mid-2028 at the earliest, and later if adoption slips (Ganrich calculation from the Commission's indicative dates; the actual date will be set in the act).

What a steel passport is likely to hold, and what is still open

The Commission says a DPP may, depending on the product group, include information on safety, origin, materials, repairability, environmental performance, reuse and recycling (European Commission, DG GROW). For steel specifically, the Commission's call for evidence (published 20 May 2026, Have Your Say initiative 17672) lists the policy options under assessment: information requirements on the carbon footprint of iron and steel products, on recycled content and on substances that make them harder to recycle; performance classes and minimum environmental performance thresholds, based for example on carbon footprint; and digital product passport requirements for all actors in the supply chain. The initiative will also define "low-carbon steel" for the Industrial Accelerator Act. As of 2 November 2026, no draft act had been published for feedback (Have Your Say initiative 17672; secondary: Publicea, 28 Oct 2026).

How DPP and CBAM data overlap

This section is Ganrich analysis, not a regulatory fact. CBAM already requires installation-level embedded emissions for steel. If the steel delegated act includes a carbon-footprint field, mills that already have verified CBAM monitoring will likely start ahead. The methods may differ (CBAM embedded emissions versus a product footprint method), so do not assume one number will serve both. Build one emissions data set that can be traced to source, and keep the method choices documented.

What the Turkish Ministry of Trade is telling exporters

The Ministry of Trade has a DPP information page on EU technical regulation alignment (accessed 2 Nov 2026) and published a DPP frequently-asked-questions document on 24 June 2026. On 15 October 2026 the Ministry of Trade opened a DPP question-collection survey (Ministry of Trade, announcement, 15 Oct 2026), which TOBB relayed to chambers on 20 October 2026. If you received it, it is worth answering: it is how Turkish industry's questions reach the authorities.

Five things to prepare in 2027

1. Product inventory: list EU-bound steel products by CN code, grade and mill, so scope can be checked the day the act is published.
2. Identifiers: decide how you will give each product or batch a unique identifier and data carrier (marking, labels, certificates).
3. Emissions data: keep CBAM monitoring running at verified quality; it is your best base for any carbon field.
4. Recycled content: document scrap inputs and their sources by heat or batch.
5. Service provider decision: decide whether you will host passport data yourself or use a DPP service provider; rules for providers are expected in 2027.

Our supplier sustainability data work and the textile product passport report show how this works in practice; for batteries see battery passport readiness. Track dates on the EU regulation calendar.

FAQ

Next step: take the CBAM readiness check, which covers the emissions data a steel passport is likely to build on.

Dates and sources last checked 2 November 2026. General information, not legal advice.

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