ESPR and CBAM as a dual data obligation
Steel and iron are prioritised intermediate products in the ESPR working plan 2025-2030; the Commission lists 2026 as the indicative adoption date for the delegated act. The final act will define which steel and iron products need a DPP, which data fields apply and when they become mandatory. In parallel, the Carbon Border Adjustment Mechanism (CBAM) has applied in its definitive regime since 1 January 2026: importers of steel and iron must prepare as authorised CBAM declarants, declare embedded emissions and purchase CBAM certificates for 2026 imports from February 2027.
For steel producers this means dual data preparation: CBAM reporting to national authorities on one hand, and expected product-accompanying DPP documentation under ESPR on the other. Product-level carbon accounting now builds the data foundation for CBAM and later ESPR product information. All deadlines at a glance →
Likely data categories
- Carbon footprint — Specific greenhouse gas emissions in t CO₂e/t steel — broken down by direct (Scope 1), indirect (Scope 2) and upstream (Scope 3) emissions.
- Scrap content — Share of secondary steel (scrap input) in percent — key sustainability indicator for the circular economy.
- Production route — Blast furnace/converter (BF-BOF) versus electric arc furnace (EAF) — direct impact on carbon intensity and scrap rate.
- Product specification — Steel grade, standard conformity (EN 10025, EN 10149 etc.), coating, dimensions, mechanical properties.
- Supply chain — Ore and scrap origin, processing sites, rolling mill and surface treatment data.
CBAM: reporting obligation from January 2026
From 1 January 2026, CBAM is in its definitive regime. EU importers or indirect customs representatives above the single 50-tonne threshold must apply for authorised CBAM declarant status, declare embedded emissions and surrender certificates each year. In 2026 the Commission publishes quarterly certificate prices; according to the Commission, certificate purchases for 2026 imports begin only from February 2027. The transition phase with reporting obligations but no certificate surrender ran from October 2023 to December 2025.
For steel manufacturers outside the EU, this means EU buyers are demanding precise emissions data at product level. These data points are not automatically identical to later ESPR DPP fields, but they are a strong basis for product carbon footprint, production route and supply-chain evidence.
Associations and standards
- EUROFER — European Steel Association — positioning on CBAM, ESPR and carbon footprint methodology
- European Commission CBAM — Primary source for the definitive CBAM regime from 1 January 2026
- European Commission CBAM price — Commission note on 2026 certificate prices and certificate purchases from February 2027
- European Commission ESPR working plan — Official prioritisation of steel and aluminium as ESPR intermediate products
- WV Stahl — German Steel Federation — guidance on CO₂ accounting for steel products
- ResponsibleSteel — International sustainability standard for the steel industry — possible source for supply-chain and sustainability evidence
- worldsteel — World Steel Association — CO₂ database standard for the global steel industry
German production hubs
Germany has several important steel, processing and research locations. For DPP and CBAM programmes, the important overlap is where emissions, production-route, scrap, quality and supply-chain data is created:
- Duisburg — Integrated steel production, blast-furnace/converter routes, rolling mills and industrial decarbonisation projects; relevant for emissions and production-route data
- Dortmund — Special steel, research and processing environment; relevant for material standards, quality data and carbon accounting
- Salzgitter — Steelmaking and decarbonisation programmes; relevant for scrap share, production route, electricity sourcing and product-carbon-footprint data
Frequently asked questions
- When does the DPP apply to steel products?
- Steel and iron are prioritised in the ESPR working plan 2025-2030. The concrete DPP application date arises only through the delegated act. What is already certain: CBAM has run in its definitive regime since 1 January 2026.
- What is the difference between CBAM and DPP for steel?
- CBAM is a border adjustment measure for imported goods: importers declare embedded emissions and surrender certificates. The later steel DPP will make product-accompanying information digitally accessible once the delegated act defines the fields. Both data worlds are likely to overlap around the core carbon dataset.
- How is the carbon footprint for steel calculated?
- In the CBAM context, the EU uses actual emissions data from production installations and, where allowed, default values. The methodology for a later steel DPP will be specified only by the ESPR delegated act; existing product-carbon-footprint or EPD data can be an important basis.
- Does CBAM also affect domestic steel producers?
- CBAM directly applies to imports from third countries. Within the EU, steel producers are subject to the EU Emissions Trading System (ETS). A later ESPR DPP would set product information duties for the steel and iron products covered by the delegated act.