CBAM and Digital Product Passport compliance for companies exporting to the EU.
The EU now asks not only what your product is, but where it comes from. CBAM and the Digital Product Passport require supply chain data you can prove. Provscope collects it from your suppliers, verifies it against evidence and publishes it to EU standards.
Hot-rolled steel coil
Example plant · CN 7208 · Batch L-2026-118
Illustration drawn with demo data; not real customer data.
The obligation is not in your product. It is in the part of your supply chain you cannot see.
The data the EU asks for does not end at your factory gate: who mined the ore, where the electricity came from, which plant produced the alloy. You are asked to declare it, but the data sits with your suppliers.
Market access
Once a passport becomes mandatory for a product group, products without one cannot be placed on the EU market. That is not a fine, it is lost sales.
The cost of default values
Under CBAM, goods without actual emissions data are assessed with default values. Default values price a clean producer like a carbon-intensive one.
Buyer screening
EU buyers need supplier data for their own reporting obligations. Suppliers who cannot provide it drop off the list before any legal deadline arrives.
Collecting data from suppliers takes months; it cannot start on the deadline. The battery passport date is already fixed: 18 February 2027. The CBAM definitive period is running now, so 2026 data is being created today.
We do not hand you a form. We collect the data.
Most tools open an empty form and wait for you to fill it in. We identify your suppliers, request the data from them, link it to evidence and publish the passport.
Data collection
We map your bill of materials and which supplier holds which data. Each supplier receives a single-purpose link. No account, no training.
a supplier list and the bill of materials. Follow-up and reminders are on us.
Verification
Every value is linked to its source: invoice, measurement report, plant declaration. Inconsistencies are flagged and gaps are closed. What remains is a chain of evidence, not a self-declaration.
each data field shown with its source and verification status.
Publishing and registry
The passport is published with a canonical GS1 Digital Link identifier, the QR code goes on the product, and the record is prepared for the EU DPP registry. Pages are rendered on the server, so search engines, customs and buyers all see the same content.
the identifier stays the same for the life of the product; the content is versioned.
What your supplier sees
No account, no password, no software to learn. The link a supplier receives opens only the fields requested from them. That low friction is what decides whether data collection succeeds.
Example Steel Co. is requesting 3 data points
Without this data, your product is reported with default values in your customer's EU declaration.
Illustration drawn with demo data; not real customer data.
Self-declaration is a tool. Evidence is a service.
The comparison below is at category level: it describes common approaches in the market, not any specific provider.
| Criterion | Self-declaration tools | Provscope |
|---|---|---|
| Where the data comes from | You fill in the form. Supplier data is your problem. | We collect it from suppliers and chase the forms. |
| Data quality | Self-declared. No verification chain. | Traceable to its source, linked to evidence. |
| Passport page | Client-side; crawlers see an empty shell, cannot be archived. | Server-side rendering. Full content in raw HTML, fully indexable. |
| Product identifier | Proprietary, non-standard identifier. | Canonical identifier following the GS1 Digital Link standard. |
| EU registry | No registration, or "on the roadmap". | Built-in submission flow for the central DPP registry. |
| Trade secrets | Single visibility level: public or closed. | Layered access: public, customs and market surveillance separately. |
| Scope | A single regulation. | DPP and CBAM from one database; CSRD/EUDR on the roadmap. |
Compliance without exposing your trade secrets.
A passport is not fully public. Who can see which data is split into the access layers defined by the regulation, so your recipe is never published.
Origin, material class, recycling information, care instructions.
Embedded emissions detail, supplier chain, verification records.
Declarations of conformity, test reports, chain of responsibility.
Recipe ratios, unit cost, supplier prices. Never exposed in any layer.
Data collected: last 6 months
Status by supplier
Billet supplier
Electricity supply contract
Ferroalloys (2 suppliers)
Scrap origin declaration
Illustration drawn with demo data; not real customer data.
See which data is waiting on whom.
Progress by supplier, missing fields, evidence status. We handle follow-up and reminders, and you can see where you stand at any time.
Obligations do not arrive for everyone on the same date.
The regulation and the date that apply to you depend on your product group.
Iron, steel and metals
One of the largest CBAM sectors by import volume. Covered by CBAM and a priority group in the first ESPR working plan.
CN 7208, 7214, 7326 Batteries Regulation · DPPBatteries and energy storage
The sector with the clearest passport date: 18 February 2027. The first real-world application of the DPP.
CN 8507 ESPR · DPP · CSRDTextiles and apparel
A priority group in the first ESPR working plan. Brand customers have started requesting data before the obligation date.
CN 6109, 6203, 6204 CBAM · ESPRAluminium and alloys
Covered by CBAM. Electricity-intensive production makes the gap between default and actual emissions large.
CN 7601, 7604, 7606 CBAMCement and clinker
Covered by CBAM. A high share of process emissions makes the default versus actual gap decisive.
CN 2523 CBAMFertilisers and nitrogen compounds
Covered by CBAM. The embedded emissions chain from feedstock (ammonia) is critical.
CN 3102, 3105Let the dates speak.
The dates below are taken from the regulatory texts. Dates that are not final are clearly marked as indicative.
CBAM transitional period began
Reporting obligation only, no financial obligation. Importers started submitting quarterly CBAM reports.
Batteries Regulation started to apply
The general provisions of the regulation entered into application. Some obligations, including the passport, phase in on their own timelines.
ESPR entered into force
The legal framework for the Digital Product Passport was established. Concrete product obligations follow through delegated acts.
First ESPR working plan published
Priority product groups were set: iron and steel, aluminium, textiles (apparel), furniture, tyres. Delegated act preparation started for these groups.
CBAM definitive period began
The transitional period ended. Embedded emissions now create a financial obligation; importers must surrender CBAM certificates.
CBAM certificate sales open
Purchasing certificates for the 2026 obligation opens on this date. The certificate price is indexed to the weekly EU ETS average.
Indicative Based on the timeline amended by the 2025 Omnibus I simplification package. To be confirmed as implementing acts are finalised.
Battery Passport becomes mandatory
LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries cannot be placed on the EU market without a passport.
First CBAM declaration deadline
The CBAM declaration for calendar year 2026 is due by this date. Without actual supplier data, default values apply, and default values are expensive.
Indicative The original 31 May 2027 date was moved to 30 September 2027 by the 2025 Omnibus I package. To be confirmed against the final implementing texts.
Textiles DPP delegated act
Product-specific requirements and the passport obligation for apparel and textiles will be set by a delegated act. The drafting process is ongoing.
Indicative The delegated act has not been adopted yet. The date is an expectation based on the working plan, not an obligation date.
Iron and steel DPP delegated act
Iron and steel, as an intermediate product, is a priority group in the first ESPR working plan. Passport scope and data fields will be set by a delegated act.
Indicative The delegated act has not been adopted yet. The CBAM obligation for steel, however, already applies; the two should not be confused.
Regulatory data last reviewed: 1 July 2026. Sources: EUR-Lex.
Find out in 30 minutes which obligations apply to you.
Tell us about your product groups and EU markets. We will map which dates apply and where the data has to come from.
- Obligations list for your product group
- Supplier data collection plan
- Default vs actual estimate for CBAM