ESPR and Iron & Steel: Why This Is the Next Delegated Act to Watch

When the European Commission adopted the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 in April 2025, it named five priority product groups for the first wave of ESPR delegated acts: textiles, furniture, tyres, iron & steel, and aluminium. Most of the compliance attention so far has gone to textiles and furniture - categories with obvious consumer visibility and existing DPP pilot work. Iron and steel have had a quieter profile. That's a mistake, because iron and steel carry the earliest indicative delegated-act date of the group: 2026, ahead of aluminium (2027), furniture (2028), and mattresses (2029).

If you sit anywhere in a steel-intensive value chain - primary producers, service centres, converters, or buyers specifying steel-containing products - the regulatory clock on this category is already running faster than the public conversation suggests.

Why iron and steel made the priority list

ESPR's Working Plan doesn't prioritise product groups arbitrarily. The categories selected combine high material and environmental footprint with significant EU market volume and, critically, enough existing standardisation and data infrastructure to make a delegated act technically feasible within the plan's timeline. Steel checks all three boxes: it's one of the most carbon-intensive material flows in the EU industrial base, it moves through well-defined supply chains with established grading and certification systems, and - unlike a category such as chemicals - the sector already has meaningful groundwork in carbon accounting through instruments like the EU Emissions Trading System and the Carbon Border Adjustment Mechanism (CBAM).

That last point matters more than it might first appear. CBAM already requires embedded-emissions reporting for imported steel. An ESPR delegated act layering ecodesign and DPP requirements on top of that isn't starting from zero - it's extending a carbon-accounting discipline the sector has already had to build for a different regulation.

What the requirements are likely to cover

The delegated act itself hasn't been published, and specifics will only become firm once the Commission's preparatory study and stakeholder consultation process concludes. But ESPR's framework and the pattern from other priority categories point to a predictable shape:

Recycled content. Steel is one of the most circular industrial materials by nature - scrap-based electric arc furnace production is already mainstream - which makes recycled-content thresholds a natural first lever, in the same way ESPR's broader recycled content mechanism works: the regulation sets the mechanism, delegated acts set the numbers.

Product carbon footprint (PCF) disclosure. Given the CBAM overlap, expect PCF methodology requirements aligned as closely as possible with existing embedded-emissions calculation rules, feeding into the Digital Product Passport's carbon footprint data field.

Durability and traceability data. For structural and industrial steel applications, expect DPP fields covering grade, origin, and processing history - data that construction, automotive, and machinery buyers already request informally through mill certificates, but which ESPR would formalise and make machine-readable.

Digital Product Passport implementation. As with every priority category, the delegated act will specify when DPP obligations attach to steel products placed on the EU market, governed by the same data carrier and Registry infrastructure now in place under Implementing Decision (EU) 2026/1736.

What "indicative 2026" actually means for planning

An indicative delegated-act date is not a hard legal deadline - it's the Commission's working estimate for when the act will be adopted, based on the preparatory study timeline. Adoption dates in EU rulemaking slip more often than they hold. But two things distinguish steel's position from other categories on the list:

First, it's first in the queue among the metals categories, meaning any Commission bandwidth constraints or consultation delays will show up here before they show up in aluminium's 2027 track. Second, because steel already has CBAM-driven carbon data infrastructure, the technical barriers to finalising a delegated act are genuinely lower than for a category starting from scratch - which cuts against the usual assumption that "indicative" means "distant."

What to prepare now

1. Inventory your PCF data readiness. If your CBAM reporting is solid, you're closer to ESPR-ready than most teams in other sectors - map what data already exists before building anything new.
2. Map recycled-content data by product line. Scrap ratio data often exists at the plant or mill level but isn't yet structured per SKU or per shipment - start building that granularity now.
3. Talk to your trade association about the preparatory study. Priority-category preparatory studies include stakeholder consultation windows. Steel producers and downstream converters who engage early have more influence over threshold-setting than those who wait for the draft act.
4. Don't wait for the delegated act to start DPP infrastructure work. The data carrier, Registry, and passport data model requirements are horizontal - the same infrastructure covered under ESPR's conformity assessment framework applies regardless of which category's delegated act triggers your obligation.

Steel's ecodesign requirements will land with less fanfare than textiles or furniture, but on the current Working Plan timeline, they may well land first.