Duisburg: Germany’s biggest steel hub has been keeping a close eye on Berlaymont since the spring, and for good reason. The Commission’s first Ecodesign for Sustainable Products Regulation delegated acts, the binding rules that translate the 2024 framework law into real obligations, are scheduled to land for iron and steel before the end of 2026, and the technical drafts circulating in expert groups now read very differently from the gentle principles tone that some producers had hoped for.
The choice of steel as the pilot category was not made for show. Iron and steel sits in the first ESPR working plan adopted last April alongside textiles, aluminium, tyres and a small number of intermediates, but it is steel that the Commission has signalled will go first. The reasoning is partly practical, most of the metric infrastructure for carbon intensity already exists in the Carbon Border Adjustment Mechanism, and partly political. A sector that produces over 130 million tonnes of crude steel a year inside the bloc cannot be left out of the climate-aligned product agenda much longer.
Concretely, the delegated act being prepared sets out three layers of requirement. The first is mandatory disclosure through a Digital Product Passport. By 19 July 2026, the EU’s central DPP Registry will go live, providing the back-end where every passport will be referenced. That date is fixed by Article 75 of ESPR itself and the Commission’s services are racing to deliver the technical specifications in time. The second layer is performance, with floors for recycled content, scrap share and embedded emissions per tonne. The third, and most contested, is information on durability, reparability and disassembly for steel products sold to construction and automotive integrators.
For Duisburg’s integrated mills and the network of mini-mills running through Brescia and Aviles, the timeline is the headline. The act adoption is one thing, but the law gives a minimum 18-month transition window, which pushes hard compliance to 2028 or 2029. Industry has read that as breathing room. Several stakeholder letters this month have argued the opposite, that delaying enforcement until late decade risks colliding head-on with revised CBAM default values and the free-allocation curve under the Innovation Fund, leaving installations exposed to two regulatory deadlines at once.
Civil-society watchers see another sharp edge. The Environmental Coalition on Standards has pushed for tighter caps on recycled-content thresholds, arguing the draft floors sit well below what European scrap supply can support. WWF and Eunomia have echoed those calls and warned the Commission against carving out exemptions for stainless or specialty grades, which they say would undercut the credibility of the entire working plan.
The political track sits in parallel. The Environment Council is expected to discuss the wider 2025 ESPR working plan review at its June and October meetings, and the European Parliament’s ENVI rapporteur has flagged that delegated acts will receive sustained scrutiny rather than the cursory non-objection pathway some had assumed. That matters because the Council can still send a delegated act back if a qualified majority objects within two months of publication, and a return for redrafting would shift the entire 2026 timetable.
Beyond steel, the dominoes wait. Textiles is widely expected to follow in 2027, with the textile DPP draft moving in parallel and the wider apparel destruction ban already due in July of the same year. Aluminium, ICT, and tyres sit on the working plan but are months behind. For now, the steel sheet is the live one, and Duisburg’s plant managers are already drafting compliance budgets that assume a 2026 act and a 2028 enforcement cut-off, the safest assumption given how often regulatory drafts have stuck closer to schedule than the industry has predicted.
