My manufacturer is outside the EU — who arranges the digital product passport then?

The importer or the authorised representative arranges the passport

If the manufacturer is established outside the EU, responsibility for the digital product passport in practice lies with the party that places the product on the EU market: the importer. If the manufacturer outside the EU has appointed an authorised representative within the EU for this task, that representative can fulfil the passport obligations on behalf of the manufacturer. Without such an authorised representative, that role reverts to the importer. For aluminium semi-finished products — profiles, castings, packaging material — imported from outside the EU, this means there is always an EU party that can be held accountable for the existence and accuracy of the passport, even if the manufacturer itself has never had an office in the EU.

Who this applies to, and who it does not

This topic applies to products imported from a country outside the EU by an importer who subsequently places them on the EU market, and which fall under the ESPR requirements for product passports once those requirements become mandatory for the relevant aluminium product group. It does not apply to manufacturers established in the EU themselves — they are directly responsible and do not need an importer or authorised representative between themselves and the market. It likewise does not apply to a party that only resells the product within the EU without having placed it on the EU market first; that link is treated differently in the regulation than the importer conducting the initial import. And this concerns specifically the allocation of roles regarding the passport, not other import obligations such as customs formalities, which are governed separately.

From when this applies

There is no fixed date yet. The ESPR itself, with the general obligations for importers and authorised representatives, has already been adopted as a framework, but when a product passport becomes mandatory for a specific aluminium product group depends on a delegated act that still needs to be established for each product group. According to the European Commission's work plan for 2025-2030, such a delegated act for the first product groups is expected around 2027, after which there is usually still a transition period before the obligation actually takes effect. Once that act is published for aluminium, the date will be indicated here. Until then, it is already established who will be responsible — the allocation of roles between manufacturer, authorised representative and importer is already fixed in the ESPR, only the moment when that allocation becomes concrete for aluminium is not yet determined.

What this means for the importer or authorised representative

The first step is to check whether the manufacturer outside the EU has already appointed an authorised representative for tasks relating to the product passport. If that is the case, the initiative for providing data and having the passport compiled lies with that representative, and it is mainly for the importer to be able to demonstrate that this representation exists and what the mandate entails. If there is no authorised representative, the importer itself must act: it checks whether the manufacturer has provided the required technical information, whether the passport is present and accessible via the QR data carrier before the product is placed on the EU market, and retains the data needed to demonstrate this. In practice, this amounts to: first mapping out the relationship with the manufacturer (is there an authorised representative, or not), then gathering the data needed for the passport — material composition, origin, recycled content and the like — and subsequently having that processed into a passport that meets the requirements. A platform such as alupas.eu can in that third step compile the passport from the provided data and arrange the QR data carrier, but the data itself must come from the manufacturer or, if represented, from the representative.

The legal basis: Articles 28 and 29 ESPR

This role distribution is laid down in Regulation (EU) 2024/1781 (ESPR). Article 28 describes the figure of the authorised representative: a manufacturer established outside the EU may appoint a representative established within the EU in writing and delegate specific tasks to that representative, including tasks related to the product passport. Article 29 regulates the obligations of importers, and determines inter alia that an importer places a product on the market only after having verified that the manufacturer has met the applicable requirements — with explicit attention to the situation in which no authorised representative has been appointed. Together, these two articles ensure that, regardless of where the manufacturer is established, there is always an accountable party within the EU for the product passport: the authorised representative if one has been appointed, otherwise the importer.

What to do now

Anyone importing aluminium from a manufacturer established outside the EU is well advised to already start identifying whether an authorised representative has been appointed and, if not, which data will subsequently need to be requested from the manufacturer in order to compile a passport. For the exact wording of the obligations, the official ESPR text is the source; for the practical processing of the data into a passport and the associated QR data carrier, alupas.eu can be engaged as soon as the data are available.

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

Aluminium semi-finished products entering the European market from outside the EU are not excluded from the digital product passport. The obligation then shifts to another party within the EU. Who exactly that is depends on the arrangement: there is always an importer, and there may also be an authorised representative appointed by the manufacturer outside the EU. Both roles are defined in the ESPR (Regulation (EU) 2024/1781), and both entail their own obligations.

The importer ensures that the passport is in place before the product enters the market

A company that places aluminium profiles, castings or packaging material from a manufacturer outside the EU on the European market is, according to Article 29 of the ESPR, the party that must verify whether a digital product passport exists before the product is marketed in the EU. For a company with 10 to 100 employees, this means in practice: when establishing or adapting a purchasing relationship with a manufacturer outside the EU, you should enquire about the source of the passport data. Not afterwards, when the container has already arrived, but at the purchasing decision itself. The importer does not verify the accuracy of each piece of data, but does verify that the passport is present, current and accessible via the QR data carrier.

The authorised representative may act on behalf of the manufacturer

Article 28 of the ESPR makes it possible for a manufacturer outside the EU to appoint an authorised representative within the EU, who carries out specific tasks on behalf of the manufacturer. This is a separate role alongside the importer — a manufacturer outside the EU can thus have appointed an authorised representative as well as supply to an importer, and these two roles can be with different parties or sometimes overlap. For a purchaser of aluminium, it is practically relevant to know which of the two actually supplies and manages the data, because that is the party with whom corrections or supplements are discussed.

Determining who fulfils which role in the chain

Before anything can be documented, it must be clear who plays which role in one's own chain. A company that purchases aluminium from a party outside the EU is not automatically "the importer" within the meaning of the ESPR if there is an intermediary that actually places the product on the market. Conversely, a company that appears at first glance only to resell can indeed bear the importer obligations. This delimitation is precisely what Am I an importer or manufacturer according to the ESPR? addresses, and is the first step before a company can set up its own file.

Where things go wrong in practice

The manufacturer outside the EU supplies only a material certificate, not passport data. That certificate (for example on alloy or mechanical properties) is valuable but is not a product passport. The importer who forwards this certificate and thinks the matter is settled is missing the link with the QR data carrier and the other mandatory data.

No one within the EU knows whether an authorised representative has been appointed. When purchasing via an intermediary or agent outside the EU, this information sometimes gets lost in transit. The consequence: when a customer asks the importer about the origin of passport data, there is no point of contact to be found, and the importer discovers that the obligation has remained with them.

The importer role is attributed to the wrong party within a group. In companies with a purchasing office and a sales establishment in the EU, it is sometimes assumed that the sales establishment is automatically the importer, whereas in fact the purchasing office is the first to place the product on the EU market. This confusion is stronger as a company operates or trades in multiple EU countries.

The passport is only arranged after the aluminium has already been resold to a processor. An importer who views the passport as something that "will come in due course" runs the risk that the product will already have been processed in a customer's production process before the data is complete. What is actually happening in that situation if the passport is missing is described under what happens if you do nothing.

It is assumed that the manufacturer outside the EU remains responsible for the accuracy of the data. A manufacturer outside the EU is not subject to EU supervision in the same way as a manufacturer within the EU. Who in practice is the point of contact if data proves to be incorrect is therefore a question that does not automatically remain with the foreign manufacturer — see who is liable if there is incorrect data in the product passport.

What you can document now

An overview of the chain per product line: who is the manufacturer outside the EU, has an authorized representative been appointed, and which party within the EU actually places the product on the market. This overview must remain up to date with any change of supplier or intermediary.
Contact details and mandate of the authorized representative, including written confirmation from the manufacturer that this representative acts on its behalf for the product passport.
A fixed arrangement with the manufacturer outside the EU regarding supply of passport data, with a moment before shipment at which it is checked whether the passport is complete and can be linked to the QR data carrier.
An internal control point upon receipt of the goods, in which it is recorded that the passport has been checked before the product is resold or processed.
A procedure for changing manufacturer or intermediary, so that with a new supplier outside the EU it is immediately established who fulfills the importer role and who, if applicable, fulfills the role of authorized representative — comparable to the points of attention that apply when changing supplier.
A file for each authorized representative or importer with whom cooperation takes place, containing the agreements on who supplies, maintains and corrects which data.

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.