what do I do if I cannot trace the origin of my aluminium
Missing origin data is not a dead end
If the origin of aluminium cannot be traced, that does not automatically mean that no product passport can be issued. The ESPR (Regulation (EU) 2024/1781) places the obligation to provide data on the actors in the supply chain: the manufacturer, the importer and the parties that follow in the chain, each for the part of the information they hold. Those further along in the chain — for example a processor of aluminium semi-finished products — depend on what a supplier can and is willing to share regarding origin data. If that data is missing, the first step is to find out exactly why: does the supplier not know it themselves, does the supplier not want to share it, or is the origin in the case of mixed or recycled material simply not traceable back to a single source.
For those facing this issue, and for those who are not
This question particularly affects companies that purchase aluminium from a supplier that is themselves far removed from the original production, or material that has been melted from scrap or mixed batches. Those who are themselves the manufacturer or importer of the aluminium have in most cases visibility of the origin, because that data is already part of their own production or import. The problem is more pronounced for intermediaries: a profile manufacturer or foundry that purchases from a trader, who in turn purchases from a smelter, which processes a mix of primary and secondary aluminium. For data originating from mixed scrap determining an exact origin is by definition more difficult than with a single, traceable source — this is a different issue than a supplier simply not providing data, and it is important not to confuse these two situations. This page addresses the first: not having access to data that in principle exists, but is not being shared or has not been passed on.
The rules already apply, the reporting obligation via the product passport does not yet
The obligations under the ESPR to pass on data within the supply chain apply from the moment the regulation comes into force, but the delegated act that specifically sets out which data must be mandatory in the product passport for aluminium has not yet been published. In the European Commission's work programme for 2025-2030, a delegated act for aluminium is expected in 2027. When the product passport for aluminium semi-finished products actually becomes mandatory is therefore not yet fixed — the exact date on which the product passport becomes mandatory will follow on this page once that act is available. Until then, there is no legal obligation to already show a complete product passport with origin data, but the practice of recording and requesting origin is something that can already be built up now, precisely because missing data often cannot be restored overnight.
What to do if origin data is missing
The first step is to establish which data exactly is being requested and why it is not available — an overview of which data must be requested from a supplier helps to make the conversation concrete, rather than asking about "origin" in general terms. Often it turns out that a supplier does have the data but does not routinely send it, and in that case a targeted request is often sufficient. If the origin remains unclear even after enquiry, the second step is to examine whether this is due to the way the material is composed: when aluminium from multiple suppliers comes in for the same alloy, a different issue is at play than with a single source, and the approach for combining data from multiple suppliers in a single product passport is then more relevant than insisting on an origin that can no longer be traced. If a supplier refuses to share data as a matter of principle, that is a different scenario from data that simply does not exist — the approach for that is described on the page about what to do if a supplier does not provide the data. For the longer term, it is advisable not to leave the provision of this data to a supplier's memory or goodwill, but to record it in the purchasing terms, so that the next order does not start with the same uncertainty.
Where this is based on: Article 27 and Article 38 ESPR
Article 27 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of manufacturers, including making available the information necessary for the product passport. Article 38 of the same regulation addresses other actors in the supply chain and establishes that they, for the part of the information they possess, must provide data to the party compiling the passport. Neither article determines what happens when that information is actually unavailable because the origin can no longer be traced — the text governs the obligation to share what exists, not how to act when there is a gap in the chain. Once the delegated act for aluminium is published, it will probably clarify how such gaps in the chain are handled in practice; until then, the safest course is to discuss this with the supplier and to get your own purchasing agreements in order.
Anyone currently encountering missing origin data should best start by inquiring with the supplier about the specific data that are missing, and at the same time establish in your own procurement process which information must be sent automatically with the next delivery.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), Article 27 (obligations of manufacturers)
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
Providing information you already have yourself
The ESPR places responsibility for the content of the product passport primarily with the manufacturer, as follows from Article 27 of the ESPR (Regulation (EU) 2024/1781). This means that a company that processes or places aluminium semi-finished products on the market is expected to pass on the data it possesses regarding origin and composition. For a company of 10 to 100 employees, this means in practice that procurement, quality assurance and the person compiling the passport must be aligned on which documentation arrives with each delivery. If that documentation is not there, the problem this page addresses arises.
Cooperating as a link in the chain
Article 38 of the ESPR (Regulation (EU) 2024/1781) describes what is expected of actors in the supply chain: they pass on the information necessary for the passport to the next party in the chain. A company that purchases, processes and resells aluminium is therefore both a recipient and a provider of this information. In practical terms, this means that the role of "link" is not voluntary: what does not come in cannot go out. This directly touches on the question what you may expect from a supplier of aluminium in terms of data, because without a clear picture of what is needed, it is difficult to determine what is missing.
Recording what is and is not known
One aspect that is often underestimated in practice is documenting your own efforts. Not because that literally appears in the text, but because a company that cannot trace data is expected to be able to demonstrate what it has done to obtain them. For a medium-sized company, this means that a fixed procedure is needed: who asks for what, from whom, and what happens if an answer is missing or incomplete.
Where things go wrong in practice
The supplier no longer exists or does not respond. With aluminium that has been purchased through multiple intermediaries, the original producer is sometimes impossible to trace. This is particularly pronounced with aluminium that is composed of mixed scrap, where origin by definition is fragmented.
The supplier refuses to share data. Some suppliers regard origin information as commercially sensitive and withhold it. There is then a difference between "the data does not exist" and "the data is not shared" — that distinction is relevant to how a company handles this, and is further elaborated on the page about what to do if a supplier does not provide the data.
Import from outside the EU without underlying file. When aluminium is imported from outside the EU, the chain is often longer and less transparent. What an importer must precisely be able to demonstrate depends on the questions at issue in import of aluminium from outside the European Union.
Subcontractors who do not supply data. A company has part of the processing carried out by a third party, which in turn does not record data on origin or process. That gap then remains unnoticed until the moment the product passport is compiled — see also the question of whether a subcontractor processing aluminium must themselves supply data.
Multiple suppliers for the same alloy, with varying completeness. When the same alloy comes from multiple sources and one supplies origin data while the other does not, a product passport results with an uneven level of detail. That touches on the question of how data from multiple suppliers for the same alloy come together in one product passport.
What you can document now
- Correspondence with the supplier in which origin data has been requested: date, question asked, answer received (or its absence).
- Purchase contracts or order confirmations in which it is specified what data a supplier provides upon delivery — how to arrange this is described under agreements on product passport data in the purchase contract.
- Internal notes on the reason why certain data are missing: unknown origin in scrap, no response from supplier, supplier bankrupt or no longer traceable.
- Received certificates, melting tickets or analysis reports, even if incomplete — incomplete documentation is still documentation.
- An overview of the inspection steps that have been taken to assess the received data, following the approach described under checking a supplier's data for accuracy.
For companies dealing with this kind of missing links, maintaining a fixed, repeatable file is often more valuable than pursuing one perfect answer. Alupas.eu provides templates for this that align with the data that ends up in the final product passport, so that what is recorded also matches what is needed.
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 2026-09-05. Is something incorrect? Let us know — corrections are prioritised.