What obligations does a distributor or trader of aluminium have?
Distributors and traders check, they do not build the product passport
A distributor or trader of aluminium semi-finished products has, under the ESPR, primarily a checking role: to verify that a product has the required documentation and marking before it is offered for sale, not to compile that documentation. Where the manufacturer or importer is responsible for the content of the digital product passport and for affixing the QR data carrier, the parties that come later in the supply chain have the task of checking whether all of that is present and in order. Anyone in doubt as to whether a batch of aluminium profiles, castings or packaging material complies with the rules is expected to do something about it — selling on without more is then not automatically the right course of action.
Who this applies to, and who it does not
These obligations apply to parties that place aluminium products on the market without being a manufacturer or importer themselves: wholesalers, resellers, and other links between producer and end user. A company that itself imports aluminium from outside the EU falls under the rules for importers, not those for distributors — that is a different regime with different obligations. Also, a manufacturer who sells his own product through his own sales channel remains a manufacturer for the purposes of the ESPR. The role of distributor or trader only arises when a company offers a product from another company without itself adding anything to it or modifying it in a way that is relevant to compliance.
When this will come into effect
The obligations under Articles 30 and 31 of the ESPR have in general applied since the regulation came into force, but they only take on concrete form for aluminium once there is a delegated act that sets out exactly what is required for this product type — think of what must be in the product passport and what the QR carrier looks like. For aluminium, that delegated act is expected in the European Commission's work programme for 2025-2030, with 2027 as the expected time of publication. An obligation for distributors to specifically check the aluminium product passport will therefore only become concrete once that act is in place and the transition period thereafter has elapsed — presumably around 2029, although that date is not yet fixed. Until then, the general due diligence obligations under the ESPR do apply in principle, but the product-specific requirements for aluminium are still lacking.
What this means in practice, step by step
Once the obligation for aluminium comes into force, it is logical to check upon receipt of a batch whether a digital product passport and a QR data carrier are present, and whether that carrier is readable and intact. A next step is to verify that the data in the product passport matches what appears in the supplier's accompanying documents — a manufacturer or importer is responsible for that content, but an obvious discrepancy is something a trader does something about. If there is doubt about compliance, contacting the manufacturer or importer is a logical course of action before the product is sold on. During storage and transport, it is important that the QR carrier does not become damaged or illegible, because that blocks access to the product passport for the next link in the supply chain. Finally, it is customary that a supervisory authority asking for information also receives that information — that is part of the same obligations.
Where this follows from: Articles 30 and 31 ESPR
These obligations are set out in Articles 30 and 31 of Regulation (EU) 2024/1781 (ESPR), which specifically regulate the role of distributors and traders in the product chain. These articles form part of a broader system in which manufacturers, importers, distributors and traders each have their own share in compliance with ecodesign requirements — with each link in the chain having a different degree of responsibility, commensurate with the extent to which that link influences the product itself.
If you are already trading in aluminium, it is advisable to map out your own procurement and sales processes in advance: identify who the manufacturer or importer is per product line, and through which channel documentation normally arrives. Once the delegated act for aluminium has been published, the specific date and content will appear in this place — until then, nothing is specifically required for aluminium, but preparation is not a luxury.
What this is based on
The regulation itself is on EUR-Lex. We refer per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
A distributor or trader is the party that places aluminium products on the market or makes them available for sale, without being a manufacturer or importer. Think of a wholesale profile supplier, an intermediary that maintains inventory, or a company that resells aluminium products to processors. The ESPR (Regulation (EU) 2024/1781) places a number of obligations on these parties in Articles 30 and 31, which are separate from — but do align with — the obligations of the manufacturer.
Checking whether the product passport is present
Before a product is placed on the market, it should be verified that the digital product passport is present and that the QR data carrier is on the product or packaging. For a company with 10 to 100 employees, this means in practice: a fixed control point upon receipt of goods, where someone — often in procurement or quality assurance — verifies that the data carrier is present and readable. This is not a substantive assessment of the data itself, but a presence check.
Verifying that the accompanying information corresponds with what is required
It should be verified that the conformity information that accompanies the product is present — such as a declaration or statement that goes with the product passport. This is not a re-assessment of the technical content, but a check on completeness: is everything included that should be there. For companies that source aluminium from multiple manufacturers or importers, this means that this check can differ per supplier, depending on how that supplier has provided the passport.
Not placing on the market if it is known that the product does not comply
When a distributor or trader knows — or on the basis of the information available should know — that a product does not meet the requirements, the product should not be placed on the market until that is resolved. This directly relates to the question who is liable if there is incorrect data in the product passport: the trader is not the party that compiled the data, but is nevertheless called to account for what happens to a product once a defect becomes known.
Retention and transfer of information
A distributor or dealer maintains data on who the product was received from and to whom it was supplied. This is comparable traceability information as with manufacturers and importers, but focused on its own position in the supply chain. For a company with a number of fixed suppliers and customers, this is often already part of the existing ERP or inventory system; the main point is that this data can be retrieved during the retention period required by the regulations.
Cooperation in response to inquiries from a supervisory authority
At the request of a competent authority, the distributor or dealer is to cooperate in providing information and documentation that demonstrates the product complies. This is a reactive obligation: there is no active reporting, but when requested, the requested information must be available and supplied within the set deadline.
Where things go wrong in practice
A common situation is a distributor of aluminium profiles from different manufacturers combining and repackaging a single batch without it being clear which QR data carrier belongs to which part of the batch. If the link between product and passport then comes loose, it is no longer possible to determine which passport belongs to which piece of aluminium.
A second situation is the dealer who purchases aluminium products from a manufacturer outside the EU via an intermediary, assuming that the importer — which according to the question who is responsible for the product passport for aluminium has its own position — has already arranged the passport. If nobody has explicitly documented that, it can happen that nobody in the supply chain has actually checked whether the passport exists.
A third situation: a distributor receives a complaint about an aluminium product and assumes it is a matter between the customer and the manufacturer. Yet the obligation not to supply once it is known that a product does not comply also rests with the distributor itself from the moment that knowledge exists.
A fourth situation arises with businesses that resell aluminium products under their own article number or own packaging, without realizing that this can change their own role in the supply chain — a question that is addressed more extensively in selling under own brand.
A fifth, more administrative situation: when changing supplier, the new supplier is not asked about the status of the product passport, causing a trader to temporarily offer products without visibility into whether the data carrier and the associated information are complete — something closely related to the points of attention that apply when changing supplier.
What you can document now
- An internal inspection form at goods receipt, on which it is checked whether the QR data carrier is present and readable.
- An overview per supplier of who has drawn up the product passport, and what agreements have been made about it — useful when multiple establishments in the EU or multiple manufacturers are in the supply chain.
- A log of received and supplied batches, with reference to the associated passports, so that the origin and destination of a batch of aluminium remain traceable.
- A documented procedure for when a product defect becomes known: who decides to stop supply, and how that is documented.
- A template for contact with a supervisory authority, so that requested documentation can be provided quickly and completely.
- Agreements with suppliers about when the product passport is available, particularly relevant when selling via online marketplace and the origin of products is less clear-cut than with fixed suppliers.
This is not legal advice. This page provides general information on the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something not right? Let us know — corrections are prioritised.