DPP for Intermediate & B2B Products: Metals, CBAM and EN 10204
Most Digital Product Passport talk assumes a finished consumer good with a barcode. But the biggest data problem sits upstream — in the coils of steel, aluminium slabs, copper wire rod and resin batches that never reach a shelf. These intermediate products can carry passports too, referenced by the manufacturers who consume them, and they solve real problems: CBAM reporting, mill certificates and confidential alloy chemistry.
Why an intermediate product needs a passport
A car battery, a wind turbine or a building frame is only as traceable as the materials it's made from. When the ESPR framework reaches those finished products, the manufacturer has to answer questions about embedded carbon, recycled content and hazardous substances — data that originates with the metal or chemical supplier, not with them.
An intermediate-product passport lets an upstream supplier publish that data once and hand a downstream manufacturer a reference to it, instead of re-typing a mill certificate into every customer's system. The finished-product DPP then links to the supplier's passport, and the chain of custody becomes machine-readable end to end.
Identifiers: there is no GTIN here
A steel mill doesn't sell "a product with a barcode" — it ships a heat, a cast, a coil. So the identifier is the one already stamped on the material, not a GTIN. This is exactly the identifier-agnostic principle we cover in Beyond GS1: which identifiers work for a DPP:
| Identifier | Used for |
|---|---|
| Heat / cast / melt number | A batch of metal from a single furnace pour — the anchor for steel and aluminium |
| Coil / slab / bundle number | A physical unit within a heat |
| Batch / lot number | Chemicals, resins, coatings, wire rod |
Each of these keys a passport that a customer's ERP can dereference — the same role a GTIN plays for retail, but native to the industry.
HS codes and CBAM
The EU Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on imports of carbon-intensive goods — iron, steel, aluminium, cement, fertilisers, hydrogen and electricity. From the end of the transitional period, importers must report and eventually surrender certificates for the embedded emissions of what they bring in.
That reporting hangs on two data points the intermediate passport is perfectly placed to carry:
- The HS / CN commodity code that classifies the goods for CBAM scope
- The embedded emissions (direct and indirect) per tonne, attributable to a specific heat or batch
When a supplier records the HS code and verified emissions in the passport, the importer downstream isn't guessing from default values — they pull the actual figure for the material they received.
One heat, the whole picture
A passport keyed on heat number H-2026-4471 can carry the alloy grade, the HS code for CBAM, the embedded CO₂ per tonne, the mill test certificate and the chain back to the scrap and ore inputs — all in one machine-readable record.
EN 10204 mill test certificates
Metals trade on their certificates. EN 10204 defines the types of inspection document a supplier issues, and the type matters legally:
| Type | What it certifies |
|---|---|
| 2.1 | Declaration of compliance with the order — no test results |
| 2.2 | Test report with results from non-specific inspection |
| 3.1 | Certificate with specific test results, validated by the manufacturer's own authorised inspection representative |
| 3.2 | Certificate validated by both the manufacturer and an independent/customer inspector |
The passport attaches the certificate as a typed document — so a customer scanning the coil sees whether it came with a 3.1 or a 3.2, and can open the PDF directly rather than chasing it by email. This is the same document-linking mechanism that turns an EU Declaration of Conformity into a shareable artefact for packaging.
Confidential alloy chemistry — authority-gated
Chemical composition is commercially sensitive. A precise alloy recipe is a competitive asset, so it can't sit in the public consumer view. The passport handles this with role-gated access: the public view shows the grade and the properties that matter to a buyer, while the full elemental breakdown is released only to an authenticated recycler or market-surveillance authority.
This is the four-stakeholder model applied to B2B — the same access split we describe in who sees what in a Digital Product Passport. Consumers and public scanners get the grade; authorities and recyclers, authenticated by token, get the confidential chemistry they legitimately need for compliance and end-of-life processing.
Product lineage: parent → child
The real power of intermediate passports is composition. A finished product is a transformation of its inputs, and the passport can record that graph:
ore + scrap → heat H-2026-4471 (slab)
→ hot-rolled coil C-88213
→ stamped chassis part CH-5501
→ finished vehicle DPP
Each step is a parent-to-child link: the child passport references the parent it was made from. A downstream manufacturer inherits the upstream carbon and chemistry data by reference instead of re-declaring it, and an auditor can walk the chain from the finished good all the way back to the furnace.
Issue a B2B passport for your material
Non-GTIN identifiers, EN 10204 certificates, CBAM HS codes and authority-gated chemistry — referenced by your customers downstream.
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