Iron and Steel Delegated Act Tracker: ESPR Iron and Steel DPP Status
EXPECTED 2026-2027The iron and steel delegated act will establish Digital Product Passport requirements for iron and steel products placed on the EU market. This tracker covers the current status and what steel manufacturers need to prepare.
Current Status and Timeline
| Milestone | Expected Date | Status |
|---|---|---|
| ESPR Working Plan identifies Iron and steel as priority | 2022–2024 | Complete |
| Preparatory study published | 2024–2025 | In Progress |
| Stakeholder consultation | 2026-2027 | Expected |
| Delegated act adopted | 2026-2027 | Expected |
| Iron and steel DPP mandatory | 2028-2029 | Expected |
Key Facts for Iron and steel Manufacturers
Steel product DPPs are expected to contain: steel grade and composition, production route (blast furnace vs electric arc furnace), recycled scrap content, carbon footprint per tonne (Scope 1, 2, and 3), country of origin for raw materials, and end-of-life recyclability. The EU Carbon Border Adjustment Mechanism (CBAM) already requires carbon footprint disclosure for steel imports — the steel DPP will extend this requirement to all steel products, not just those subject to CBAM.
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Register Your Digital Product Passport →ESPR Iron and Steel Delegated Act: Current Status
Iron and steel are among the most carbon-intensive materials in the global economy, accounting for approximately 7–9% of global CO2 emissions. The EU steel industry is under significant pressure to decarbonise, driven by the EU's 2050 net-zero target, the Carbon Border Adjustment Mechanism (CBAM), and the ESPR delegated act for iron and steel products. The ESPR delegated act for iron and steel is expected to require manufacturers to calculate and disclose the carbon footprint of their products and to set minimum recycled content requirements.
The preparatory study for the ESPR delegated act on iron and steel was launched in 2023. The study is examining the environmental impact of iron and steel production across the full lifecycle, including the extraction of iron ore and coking coal, the steelmaking process (blast furnace/basic oxygen furnace vs. electric arc furnace), the rolling and finishing processes, and the end-of-life phase. The study is also examining the feasibility of different policy options, including carbon footprint disclosure requirements, minimum recycled content requirements, and restrictions on the use of hazardous substances in steel coatings and treatments.
Frequently Asked Questions
The ESPR delegated act for iron and steel is expected to be adopted in 2025–2028. The exact timeline will depend on the outcome of the preparatory study and the stakeholder consultation process. Steel manufacturers should plan for compliance by 2027–2030.
The Carbon Border Adjustment Mechanism (CBAM) requires importers of steel (and other carbon-intensive products) to pay a carbon price equivalent to the EU ETS price for the embedded carbon in the imported product. ESPR complements CBAM by requiring disclosure of the carbon footprint of steel products in the DPP. Together, CBAM and ESPR create a strong incentive for steel manufacturers to reduce their carbon footprint.
The ESPR delegated act for steel is expected to set minimum recycled content requirements for steel products. Electric arc furnace (EAF) steel, which is produced primarily from recycled scrap steel, typically has a recycled content of 70–100%. Blast furnace/basic oxygen furnace (BF/BOF) steel, which is produced primarily from iron ore, typically has a recycled content of 10–30%. The delegated act may set minimum recycled content requirements that incentivise the transition from BF/BOF to EAF production.
Steel coatings and surface treatments (such as galvanising, painting, and electroplating) may contain substances of concern (such as hexavalent chromium, which is restricted under REACH). The ESPR delegated act for steel is expected to require disclosure of coating and surface treatment information in the DPP and may restrict the use of substances of concern in coatings.
Yes. ESPR applies to all products placed on the EU market, regardless of where they are manufactured. Importers of steel products are responsible for ensuring that the products they import comply with ESPR requirements, including the DPP requirement. The CBAM and ESPR together create a comprehensive framework for ensuring that imported steel meets EU environmental standards.
Iron and Steel ESPR Delegated Act: Policy Context
The EU steel sector is one of the largest industrial emitters of CO₂ in Europe, accounting for approximately 4% of total EU greenhouse gas emissions. The EU Commission's Green Deal Industrial Plan and the Net-Zero Industry Act (NZIA) identify green steel — steel produced with near-zero carbon emissions using hydrogen-based direct reduction or electric arc furnace technology — as a strategic priority. The ESPR delegated act for iron and steel will set ecodesign requirements that incentivise the transition to green steel by requiring manufacturers to disclose the carbon footprint of their steel products and by introducing minimum recycled scrap content requirements. The delegated act is expected to be published in 2027–2028, with a compliance deadline of 2029–2030.
Steel Carbon Footprint Methodology
The carbon footprint of steel varies significantly depending on the production route. Blast furnace/basic oxygen furnace (BF/BOF) steel, produced from iron ore using coking coal, has a carbon footprint of approximately 1.8–2.2 tonnes of CO₂ per tonne of steel. Electric arc furnace (EAF) steel, produced from recycled scrap using electricity, has a carbon footprint of 0.4–0.8 tonnes of CO₂ per tonne of steel (depending on the carbon intensity of the electricity grid). Hydrogen-based direct reduction (H-DRI) steel, currently in demonstration phase, has a potential carbon footprint of near zero if green hydrogen is used. The ESPR steel DPP will require manufacturers to declare the carbon footprint per tonne of steel using the methodology specified in the World Steel Association's CO₂ data collection methodology or an equivalent methodology approved by the EU Commission.
Steel Recycled Content and the Circular Economy
Steel is one of the most recycled materials in the world — the global steel recycling rate is approximately 85%. EAF steel production uses 100% recycled scrap as its primary input. BF/BOF steel production uses approximately 25–30% recycled scrap. The ESPR delegated act for steel is expected to introduce minimum recycled scrap content requirements that incentivise the shift from BF/BOF to EAF production. The EU's Carbon Border Adjustment Mechanism (CBAM, EU 2023/956) already creates a financial incentive for steel importers to use lower-carbon production methods, as CBAM charges are based on the carbon intensity of the imported product. The ESPR steel DPP will provide the carbon footprint data that CBAM authorities need to calculate the correct CBAM charge for imported steel products.
Steel and ESPR: The Carbon Intensity Challenge
Steel production is one of the most carbon-intensive industrial processes — global steel production accounts for approximately 7–9% of global CO₂ emissions. The EU steel industry produces approximately 140 million tonnes of steel annually, with a carbon intensity of approximately 1.8 tonnes CO₂ per tonne of steel for blast furnace production and 0.4 tonnes CO₂ per tonne for electric arc furnace (EAF) production using recycled scrap. The EU Commission has identified steel as a priority material for ESPR because of its high carbon intensity and its widespread use in products covered by ESPR (construction, automotive, appliances, packaging). The ESPR iron and steel delegated act is expected to include requirements for carbon footprint per tonne of steel, recycled scrap content, and end-of-life recyclability for steel-containing products.
ResponsibleSteel Standard and ESPR Readiness
The ResponsibleSteel standard is a global multi-stakeholder certification standard for responsible steel production. ResponsibleSteel certification requires steel producers to meet performance standards covering greenhouse gas emissions, energy efficiency, water management, biodiversity, labour rights, and supply chain due diligence. ResponsibleSteel-certified steel producers collect and verify data on CO₂ emissions per tonne of steel, energy consumption, and recycled scrap content — data that overlaps significantly with the data required for ESPR DPP compliance. EU steel producers that are already ResponsibleSteel-certified will have a significant head start on ESPR DPP compliance. The ResponsibleSteel standard is working with the EU Commission to align its certification requirements with ESPR DPP data requirements.
CBAM and ESPR: Complementary Carbon Instruments
The Carbon Border Adjustment Mechanism (CBAM, EU 2023/956) requires importers of steel, aluminium, cement, fertilisers, electricity, and hydrogen to pay a carbon price equivalent to the EU ETS price for the embedded carbon in their imports. CBAM and ESPR are complementary instruments — CBAM addresses the carbon price differential between EU and non-EU production, while ESPR addresses the product design and lifecycle data requirements. Steel importers that are already complying with CBAM (by collecting and verifying embedded carbon data for their steel imports) will have a significant head start on ESPR DPP carbon footprint disclosure requirements, as the CBAM embedded carbon data is the same data that will be required in the ESPR steel DPP.
EU ETS and ESPR Steel: Carbon Price and Carbon Footprint Disclosure
EU steel producers are subject to the EU Emissions Trading System (EU ETS), which requires them to surrender EU Allowances (EUAs) for their CO₂ emissions above the free allocation threshold. The EU ETS carbon price provides a financial incentive for EU steel producers to reduce their carbon intensity — producers that reduce their emissions below the free allocation threshold can sell their surplus EUAs. The ESPR iron and steel delegated act is expected to require carbon footprint disclosure in the steel DPP, using the same carbon accounting methodology as the EU ETS. This alignment between the EU ETS and the ESPR DPP carbon footprint disclosure will make it easier for steel producers to report their carbon footprint in the DPP — they can use their EU ETS emissions data as the basis for the DPP carbon footprint calculation.
Green Steel and ESPR: The Market Opportunity
Green steel — steel produced using hydrogen-based direct reduction (H-DRI) or electric arc furnace (EAF) processes powered by renewable energy — has a carbon footprint of approximately 0.5–1.0 kg CO₂e per kg of steel, compared to 1.8–2.5 kg CO₂e per kg for conventional blast furnace steel. The ESPR iron and steel DPP's carbon footprint disclosure requirement will make the carbon footprint of steel products transparent to buyers, creating a market premium for green steel. Steel manufacturers that invest in green steel production now will be able to command a price premium for their products once the ESPR DPP carbon footprint disclosure requirement comes into force. The EU Commission's Green Deal Industrial Plan includes funding for green steel production through the Innovation Fund and the Just Transition Fund — steel manufacturers should explore these funding opportunities as part of their decarbonisation strategy.