Iron, steel, and aluminium are priority sectors in the ESPR Work Plan 2024–2027. Delegated acts are expected in 2027–2029. The DPP requirements for metals will align with CBAM carbon content declarations — manufacturers who build ESPR DPP systems will have the data infrastructure for both ESPR and CBAM compliance.
The ESPR metals delegated acts are expected to cover: structural steel (beams, plates, coils), stainless steel, aluminium sheets and extrusions, aluminium castings, and copper products. Mining outputs (ore, concentrate) are not in scope — ESPR applies to processed metal products placed on the EU market.
| Data Category | Expected Requirement | CBAM Alignment |
|---|---|---|
| Carbon footprint | GHG emissions per tonne of product (kgCO₂e/t), by lifecycle stage (A1–A3) | Direct CBAM input |
| Recycled content | Percentage of recycled steel/aluminium by weight, with scrap source verification | Indirect CBAM factor |
| Production route | Electric arc furnace (EAF) vs basic oxygen furnace (BOF) for steel; primary vs secondary aluminium | CBAM production route declaration |
| Energy source | Percentage of renewable energy in production, grid carbon intensity | CBAM embedded emissions factor |
| Country of origin | Country of manufacture (melt and pour for steel) | CBAM country of origin |
| Critical raw materials | Content of critical raw materials (cobalt, chromium, manganese, nickel) per tonne | — |
| Hazardous substances | Surface treatment chemicals, coating compositions, SVHC declarations | — |
The EU Carbon Border Adjustment Mechanism (CBAM — Regulation (EU) 2023/956) entered its transitional phase on 1 October 2023. From 2026, CBAM requires importers of iron, steel, aluminium, and other products to purchase CBAM certificates for the embedded carbon content of their imports.
The carbon footprint data required in the ESPR DPP for metals is the same data required for CBAM declarations. Manufacturers who build a robust ESPR DPP system — with verified carbon footprint data per tonne — will have the data infrastructure for CBAM compliance at no additional cost.
The metals and mining sector is not directly subject to ESPR ecodesign requirements — ESPR regulates finished products placed on the EU market, not raw materials. However, the metals and mining sector is deeply affected by ESPR through the supply chain due diligence requirements embedded in ESPR DPPs. Products containing critical raw materials (lithium, cobalt, nickel, rare earth elements, natural graphite, silicon metal, and others) must include supply chain data in their DPPs — and this supply chain data must ultimately come from the mines and processing facilities that produce the raw materials.
The EU Critical Raw Materials Act (Regulation (EU) 2024/1252) establishes strategic benchmarks for EU domestic production and processing of critical raw materials. It also requires supply chain due diligence for critical raw materials used in strategic technologies. The ESPR DPP supply chain data requirements and the Critical Raw Materials Act due diligence requirements are complementary — manufacturers who comply with one will have a foundation for complying with the other.
| Critical Raw Material | ESPR-Regulated Products | Due Diligence Standard |
|---|---|---|
| Lithium | EV batteries, consumer electronics | Responsible Lithium Initiative |
| Cobalt | EV batteries, consumer electronics | Responsible Cobalt Initiative (RCI) |
| Nickel | EV batteries, stainless steel | Responsible Nickel Initiative |
| Rare earth elements | Electric motors, wind turbines, electronics | OECD Due Diligence Guidance |
| Natural graphite | EV batteries | OECD Due Diligence Guidance |
| Silicon metal | Solar panels, electronics | OECD Due Diligence Guidance |
| Platinum group metals | Catalytic converters, fuel cells | OECD Due Diligence Guidance |
South Africa is the world's largest producer of platinum group metals (PGMs) — platinum, palladium, and rhodium — and a significant producer of manganese, chromium, and vanadium. These materials are critical raw materials under the EU Critical Raw Materials Act. South African mining companies who supply to EU manufacturers must be prepared to provide supply chain due diligence documentation that meets the requirements of the applicable ESPR delegated acts and the Critical Raw Materials Act.
The EU Critical Raw Materials Act (CRMA, EU 2024/1252) identifies 34 critical raw materials (CRMs) and 17 strategic raw materials (SRMs) that are essential for the EU's green and digital transitions. Many of these materials — lithium, cobalt, nickel, manganese, graphite, rare earth elements — are used in batteries, electric motors, wind turbines, and solar panels that are subject to ESPR requirements. The ESPR DPP for products containing CRMs must disclose the CRM content, the origin of the CRMs, and the recycled CRM content. This disclosure requirement serves multiple policy objectives: it enables market surveillance authorities to verify compliance with the CRMA's recycled content targets, it provides supply chain transparency for EU manufacturers seeking to source CRMs from responsible suppliers, and it enables end-of-life recyclers to identify and recover CRMs from products at end of life.
Mining companies are not directly subject to ESPR — the regulation applies to products placed on the EU market, not to raw material extraction. However, mining companies are indirectly affected by ESPR because their customers (battery manufacturers, electronics manufacturers, automotive OEMs) will require supply chain data to comply with ESPR DPP requirements. Mining companies that can provide verified data on the carbon footprint of their extraction operations, the environmental management systems in place at their mines, and the absence of substances of concern in their ore will be preferred suppliers for manufacturers seeking to comply with ESPR. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides a framework for mining companies to document their responsible sourcing practices.
For products containing steel, aluminium, or copper, the ESPR DPP must include the recycled content percentage for each metal, the carbon footprint per kg of metal (distinguishing between primary and secondary production), and the country of origin of the primary metal. This data must be verified by a third-party auditor using the methodology specified in the relevant delegated act. Metal producers that participate in industry certification schemes — such as the Aluminium Stewardship Initiative (ASI) for aluminium, the ResponsibleSteel standard for steel, and the Copper Mark for copper — will have a significant head start on ESPR DPP compliance, as these schemes already require the collection and verification of much of the data that will be required in the ESPR DPP.
The EU Critical Raw Materials Act (CRMA, EU 2024/1252) establishes strategic autonomy targets for critical raw materials — the EU aims to produce at least 10% of its annual consumption of critical raw materials domestically, process at least 40% domestically, and recycle at least 15% by 2030. The CRMA and ESPR are complementary instruments — ESPR's DPP requirements for products containing critical raw materials will generate the data needed to track the flow of critical raw materials through the economy and to identify opportunities for increasing domestic production and recycling. The CRMA also establishes a strategic projects framework that provides fast-track permitting for mining and processing projects that contribute to the EU's critical raw materials strategic autonomy targets. ESPR DPP data on recycled critical raw material content will be used to measure progress towards the CRMA's recycling targets.
The EU Conflict Minerals Regulation (EU 2017/821) requires EU importers of tin, tantalum, tungsten, and gold (3TG) to conduct supply chain due diligence to ensure that their imports do not finance armed groups in conflict-affected areas. The ESPR DPP for products containing 3TG minerals must include the supply chain due diligence data required by the Conflict Minerals Regulation — specifically, the smelter or refinery identification and the due diligence scheme used. Electronics manufacturers that are already complying with the Conflict Minerals Regulation (which applies to importers of 3TG minerals above threshold volumes) will have a foundation for the ESPR DPP supply chain transparency requirements. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides the framework for conflict minerals due diligence that is recognised under both the EU Conflict Minerals Regulation and the ESPR DPP requirements.
The ESPR iron and steel delegated act is expected to be published in 2027, with compliance requirements entering into force in 2028–2029. The Commission's preparatory study is currently underway, with a focus on recycled content, carbon footprint, and CBAM alignment.
The EU Carbon Border Adjustment Mechanism (CBAM — Regulation (EU) 2023/956) requires importers of iron, steel, aluminium, and other products to declare the embedded carbon content. ESPR DPP data — particularly carbon footprint per tonne — will be directly used for CBAM declarations. Manufacturers who build ESPR DPP systems will have the data infrastructure for CBAM compliance.
ESPR applies to products placed on the EU market. Scrap metal is generally classified as waste, not a product, and is not subject to ESPR. However, products manufactured from recycled metals (e.g., steel beams, aluminium sheets) are subject to ESPR when placed on the EU market.
The ESPR iron and steel delegated act is expected to require recycled content declarations as a percentage of total steel content by weight. The minimum recycled content thresholds will be set in the delegated act. The DPP must include the verification methodology and third-party certification.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →The EU Critical Raw Materials Act (CRMA, EU 2024/1252) establishes strategic autonomy targets for critical raw materials — materials that are essential for the EU's green and digital transitions but that are currently sourced predominantly from a small number of non-EU countries. The CRMA requires the EU to source at least 10% of its annual consumption of critical raw materials from domestic extraction, at least 40% from domestic processing, and at least 25% from recycling by 2030. ESPR's recycled content requirements for metals products directly support the CRMA recycling target — by requiring minimum recycled content in metal products, ESPR creates demand for recycled critical raw materials and incentivises investment in recycling infrastructure. Manufacturers of products containing critical raw materials (lithium, cobalt, nickel, manganese, graphite, rare earth elements) should monitor both ESPR and CRMA developments, as the two regulatory frameworks interact in complex ways that affect supply chain strategy and sourcing decisions.
Mining companies that supply raw materials to EU manufacturers should be aware that ESPR's supply chain transparency requirements will create demand for environmental data about raw materials. EU manufacturers will need to disclose the carbon footprint and recycled content of their products in their ESPR DPPs, and this data must be based on verified supply chain data. Mining companies that can provide verified environmental data about their raw materials — including carbon footprint per tonne of ore processed, water consumption, land use, and biodiversity impact — will be preferred suppliers for EU manufacturers seeking to comply with ESPR. Mining companies should begin developing their environmental data reporting capabilities now to position themselves as preferred suppliers in the ESPR-compliant supply chain.