ESPR 2024/1781 · iron, steel and aluminium named as intermediate products in the ESPR working plan · CBAM definitive regime live since 1 Jan 2026.
The ESPR working plan names iron, steel and aluminium as priority intermediate products — and the same mills and exporters already face CBAM, the EU's carbon border adjustment, in its definitive regime since January 2026. Both ask the same underlying question: can this material prove where it came from and what it embodies?
The working plan extends the DPP beyond consumer goods to iron, steel and aluminium — data on origin, composition and embodied characteristics travelling with the material downstream.
EU importers of steel and aluminium surrender CBAM certificates against embedded emissions under the definitive regime. Verifiable production data is the difference between measured and default — usually punitive — values.
Coils, billets and extrusions face heat, abrasion and transformation. Carrier selection for metals is an engineering problem, not a labeling decision.
A carmaker's DPP inherits the steel's data. Mills that can hand customers verifiable material passports become preferred suppliers in every regulated chain.
CBAM's definitive regime is already live; the ESPR delegated acts for intermediate products set DPP fields and dates. Exporters to the EU feel CBAM first and the DPP second — the data spine is shared.
Heat numbers, cast records, energy inputs: structure the data CBAM importers already ask for — the DPP will draw from the same well.
On-metal tagging and batch-level identity need testing against real mill conditions. Aeroz runs carrier trials as part of the audit.
Pick one EU customer and hand them verifiable material passports for one product. Preferred-supplier status is won one proof at a time.
Aeroz binds batch and unit identity to metals with industrial-grade carriers, writing production and custody events to an append-only EPCIS 2.0 log. The same record that satisfies a DPP delegated act gives CBAM importers the verifiable production data that beats default values — and gives UAE and GCC exporters a compliance story the EU border understands.
Yes — the Commission's ESPR working plan names iron, steel and aluminium as priority intermediate products, so passport requirements reach them through delegated acts, feeding data downstream into finished-goods passports.
CBAM prices embedded carbon at the border under the definitive regime live since 1 January 2026; the DPP structures product data for the market. They share a data spine: verifiable production records tied to identifiable material.
Specialized on-metal and harsh-environment inlays, batch-level tagging, or carrier-at-packaging with cryptographic linkage — chosen per product form. This is an engineering selection Aeroz makes during the audit, with read-rate evidence.
Because its EU customers must surrender CBAM certificates and will inherit DPP obligations. Mills that ship verifiable data with their material make their customers' compliance cheaper — and win the order.
A fixed-fee Aeroz audit maps your products against dpp for steel & aluminium requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.