Do I register aluminium per batch or per unit?

What you must concretely do

What is expected of you

The ESPR does not rigidly fix the level at which a product passport is granted to "per unit" or "per batch". Article 11 of the ESPR (Regulation (EU) 2024/1781) stipulates that the product passport is available at the level specified in the applicable delegated act for the product group — this may be per product model, per batch or per individual product. For aluminium semi-finished products, that delegated act does not yet exist, so for profiles, castings or packaging aluminium it is not yet determined at which level the passport must be assigned. What can be derived from the regulation in the meantime is the logic underlying that choice: a unique identification code per carrier of the passport, and a link between that code and the data behind it.

Each data carrier receives a unique identification code

Article 12 of the ESPR requires a unique identification code by means of which the product — or the batch, depending on the chosen level — can be traced back to the corresponding passport. For a company with 10 to 100 employees, this in practice represents a choice that goes beyond compliance: it determines the administration for the years to come. With registration per batch, one casting charge or one coil batch receives one code and one passport, with data that apply to the entire batch (composition, scrap origin, process certificates). With registration per unit, each profile, each pallet or each casting receives its own code, which is more granular but also requires more registration work and more coding capacity on the production line. How that code is precisely structured and assigned depends on the way you give each product a unique identification code .

The passport must align with how the product is actually traded

Article 11 requires that the product passport truthfully represents the product's characteristics. For aluminium that is produced as coil, billet or casting in batches but is sold per unit or per pallet, there is a tension between the production level and the trading level. A company that extrudes aluminium profiles from one casting batch and subsequently saws those into thousands of lengths must make a choice about whether the chemical composition (which applies per batch) and the physical dimensions (which differ per unit) come together in one passport, or whether a separate passport is created for each sold unit that refers back to the batch data.

The data carrier must be physically affixable to the product

Whatever is chosen — per batch or per unit — the QR code or other data carrier must land somewhere on the physical product or packaging. With batch registration, it is logical to place that code on the packaging unit, the bundle or the pallet, not on each individual profile. With registration per unit, each item must be marked separately, which on aluminium comes with its own challenges (heat, surface treatment, corrosion). How that is technically solved depends on how the QR code on the product is applied and which material and method are suitable for it.

Where things go wrong in practice

A foundry registers per casting batch, but the sales administration works per order line and per customer shipment. The result is that the batch code from production is not automatically traceable in the ERP system, and when a customer asks for the passport, it must be manually determined which batch belonged to which delivery.

At a profiles company, one casting batch is cut up and processed into hundreds of different end products with varying lengths and surface treatments. A choice is made for one passport per batch, but the surface treatment differs per sub-lot within that batch — resulting in a passport that no longer applies to part of the batch.

A packaging aluminium producer codes per roll, but the roll is cut into smaller units at the customer's site and sold separately. The original QR code disappears with the roll, and the smaller units have no data carrier of their own — traceability stops at the first processing step after purchase.

A company registers per piece, but subsequently adjusts the batch composition once a new alloy analysis arrives. Because each piece has its own passport, that modification must be made in hundreds of individual passports instead of in one batch record — a question that touches on how you modify data in a passport that has already been published.

Two companies in the chain — a foundry and an extruder — register independently of each other, the foundry per batch and the extruder per piece, without the identification codes of the foundry being recognisable in the passport of the extruder. The result is a break in traceability between raw material and end product.

What you can document now

• An internal decision on the registration level (batch, piece, or a combination) per product line, with the reason why that level was chosen.
• An overview of how the internal batch or order numbers from production and sales relate to the unique identification code of the passport.
• A description of the moment in the process at which the identification code is assigned (at casting, at sawing, at packaging, at shipment).
• Agreements with suppliers and customers in the chain on the level at which they register their own passports, so that identification codes align — relevant once a product requires multiple product passports that must align with each other.
• A technical specification of the data carrier per registration level: which code goes on the pallet, which on the individual piece, and how the two relate to each other.
• A procedure for the situation in which a batch is split or merged after the first registration, including who updates the data in the system.
• Documentation of the link between the registration level and your own ERP or inventory system, especially when batch and piece level exist side by side — a question that is directly linked to how you link the passport to your own ERP or inventory system.