As Matrec, we participated in the second stakeholder consultation for the ESPR preparatory study on iron and steel. It was an intensive technical meeting focused on a regulatory framework that closely affects many sectors.

The core of the work presented concerns five representative products:
– hot-rolled coil,
– wire rod,
– galvanized cold-rolled coil,
– electrical sheet,
– stainless steel,
for which the JRC proposes performance classes from A to E based on the cradle-to-gate carbon footprint.

The method distinguishes between the BF-BOF and EAF routes, and between EU-produced and imported steel. The figures provided are significant: for HRC produced in the EU via the BF-BOF route, emissions are estimated at approximately 1,813 kg CO₂eq/t; via EAF, it drops to 675 kg CO₂eq/t.

For 304 stainless steel, the gap between EU production (3,244 kg) and imported production (7,690 kg) is the most striking figure.

Regarding the Digital Product Passport (DPP), the JRC proposes the heat number as a mandatory identifier at the batch level. The real challenge is not technical: foundries and steel mills already issue Mill Test Certificates containing most of the required data. The issue lies in harmonizing ontologies, managing granularity, and integrating with existing reporting systems such as CBAM and the Construction Products Regulation.

Regarding recycled content, the proposal distinguishes between pre-consumer and post-consumer scrap with three chain-of-custody models:
– controlled blending,
– order-level mass balance,
– site-level mass balance.

Traceability at the source level—who produced the scrap, where, and under what conditions—remains technically unfeasible. The proposed system therefore operates on aggregated mass flows, not on material identity.

The most significant open issue for manufacturers of finished goods is the question of scope: the JRC has presented four scenarios, ranging from intermediate products only (Option A) to a reporting requirement for all steel-intensive end products (Option D).

At Matrec, we are monitoring the evolution of this scope for clients in the furniture, lighting, and manufacturing sectors who are downstream in the steel supply chain and are evaluating how to integrate information disclosure requirements into their product development processes.