First under ESPR — and a construction product under CPR

Steel and iron are the first product group for which the EU is adopting a delegated act under ESPR — ahead of textiles and furniture. The sector is among the most carbon-intensive in industry, and traceability of composition, origin and carbon footprint is becoming the basis both for market access and for low-carbon public procurement. On top of this, structural and reinforcing steel are a construction product under CPR (EU) 2024/3110 — so GWP declarations and a DoPC already apply to them, phased in with the revised harmonised standards. In practice, steel lives under two regimes — ESPR and CPR — and WIARA covers them with a single set of data.
Regulatory framework and requirements
Product creation at the mill
Right at production, data is entered on the melting process (BOF/EAF), chemical composition, steel grade and the origin of raw materials.
Generating the digital product passport
For each batch or item — rebar, pipes, sheet, sections — a unique DPP is created with a QR code or link carrying the technical characteristics and sustainability indicators.
Integration into the supply chain
Mills, warehouses and distributors add data on transport, traceability and certificates such as CE and EN 10204.
Access for traders and construction firms
Traders get technical characteristics and standards conformity, while designers and construction firms check compatibility and requirements.
Access for end clients and investors
By scanning a QR code, investors see the carbon footprint, recycled-content share and the environmental assessment of the material.
Tracking after use
On dismantling or scrapping, the passport reflects the reuse and recycling of the steel, closing the circular loop.

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DPP for steel and iron

Iron and steel products — structural steel, rebar, beams, sheet, wire, pipes and castings — manufactured or imported into the EU, including in Bulgaria.
Chemical composition and steel grade, mechanical properties, carbon footprint, recycled-content share, origin, applicable standards and certificates.
The definitive CBAM regime for steel imports starts on 1 January 2026, but the purchase and surrender of CBAM certificates begins in 2027 (first surrender by 30 September 2027); there is also a de minimis threshold of 50 tonnes. The carbon footprint data in the DPP overlaps with this reporting, making things easier for importers in Bulgaria.
Yes. Structural and reinforcing steel are at once an ESPR product and a construction product under CPR (EU) 2024/3110. As a construction product, steel is subject to a DoPC and a GWP declaration under the CPR (per EN 15804), phased in with the revised harmonised standards (from 8 January 2026). Under Article 12, where the two overlap the CPR takes precedence, and a single platform covers both obligations with no data duplication.
The threshold comes from the proposed Industrial Accelerator Act (COM(2026) 100, March 2026) — draft legislation, not from ESPR. Under it, from 1 January 2029 at least 25% of the steel in public buildings, infrastructure and vehicles must be low-carbon (with no requirement as to the steel's origin). The definition of "low-carbon" itself will be set out in a delegated act under ESPR/CPR.
Start collecting data on composition, production process and carbon footprint, and plan integration with their systems — a key step for Bulgarian steel manufacturers and exporters.
The DoPC (Declaration of Performance and Conformity) is the CPR document that merges the DoP and the CE declaration and adds environmental indicators (GWP per EN 15804). For structural steel it takes effect in phases with the revised harmonised standards (from 8 January 2026) and forms the data foundation for the future construction DPP.
Built to last

DPP for Construction Products
DPP ensures transparency for the composition and sustainability of construction materials, facilitating proof of origin and compliance with standards.

DPP for Manufacturers
Manufacturers create and maintain DPP, prove compliance and sustainability, earn trust and improve their processes.

DPP for Importers
Importers ensure a valid DPP for every product and provide EU market access without risk of sanctions and delays.

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Schedule a meetingDPP for Textiles
DPP for Steel and Iron
DPP for Batteries
DPP for Construction Materials
DPP for Furniture
DPP for Manufacturers
ESPR - Core Framework
DPP - Digital Product Passport
Work Plan 2025-2030
DPP - First Affected Industries
Partner Program
Technical standards
FAQ
Deadlines
CPR - Construction Products
Regulations
Battery Regulation & battery passport
PPWR – Packaging Regulation
CRMA – Critical Raw Materials Act
CBAM – carbon border adjustment
Toy Safety Regulation (EU) 2025/2509
Detergents Regulation (EU) 2026/405
Right to Repair – Directive 2024/1799
Green claims & greenwashing – ECD 2024/825
Textile EPR – Waste Framework Directive
CEA – Circular Economy Act
EPA – European Product Act
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