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a product passport must already be in place if my aluminium is still a semi-finished product

No, not automatically — it depends on which product category applies

A semi-finished product such as an aluminium profile, sheet or coil does not automatically fall under the digital product passport requirement, and the fact that it is not yet a finished product does not automatically rule out that requirement either. The ESPR makes no general distinction between semi-finished product and finished product; the regulation works with product categories that are designated through delegated acts. Whether aluminium in a particular form — extruded, rolled, cast — falls under such a product category ultimately determines whether a passport is required, not the question of whether it is already "finished".

For whom this matters and for whom it does not

This is particularly relevant for companies that supply aluminium that is further processed later in the chain: profile manufacturers that supply to window frame builders, foundries that supply components to a finished product manufacturer, rolling mills that supply coil to packaging producers. The question then is: does the passport requirement apply to me, or to the party that will eventually make a complete product from it? Article 2 of the ESPR (Regulation (EU) 2024/1781) defines what constitutes a "product" for the purposes of the regulation, and that definition is broad enough to potentially include semi-finished products — it is not about whether something is a finished consumer article, but whether it is placed on the market as such within a designated product category. For those wondering whether that is already concretely the case for aluminium, which products from the aluminium sector fall under the ESPR provides an overview of where the designations currently stand.

What does not fall under this: spare parts and replacement components have their own treatment, which is explained separately on the page on loose aluminium spare parts. And according to the definitions in Article 2, it makes in principle no difference whether the aluminium is primary or secondary — that distinction affects the content of the passport rather than the question of whether one is needed, as explained in more detail on the page on primary and secondary aluminium.

No fixed date yet, and the requirement only arises after the delegated act is published

There is no delegated act yet published that specifically designates aluminium products as a product category subject to the digital product passport requirement. Without that act, no concrete obligation arises for a product category — Article 1 of the ESPR sets the framework, but the actual requirements per product category, including a semi-finished product question such as this one, are set out through that separate act. Until that act is published, no digital product passport requirement applies to aluminium semi-finished products under the ESPR itself. How that process works exactly and why its date depends on other factors is set out in detail on the page on what a delegated act is. As soon as more is known about the expected date, that will be kept up to date on the page on when the digital product passport becomes mandatory.

How this is worked out in practice

Those who want to know their position now should start by asking whether their own product corresponds to a product category that has already been designated or is in preparation — that overview is on the page that describes what falls under the ESPR. Next, it is important to consider your role in the supply chain: Article 38 of the ESPR addresses the requirements for actors in the supply chain, and that article is relevant to the question of who must provide which information when a semi-finished product ends up in a finished product further down the chain. A manufacturer of a semi-finished product may be required to pass on data to the party assembling the finished product, even if the passport is ultimately only created when that finished product is completed.

After that, the question of whether your own company, given its size, falls under any exemptions is relevant — that is covered on the page on small enterprises. And for those who want to know what will concretely have to be in such a passport, should their own product category be designated, the page on what data goes into the digital product passport gives an overview of the structure, including the unique identification code which according to Article 12 of the ESPR is part of every passport.

Where this is derived from: Article 1, Article 2 and Article 38 of the ESPR

The core lies in the combination of three provisions. Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the subject matter and scope of the regulation in general terms, without itself designating product groups. Article 2 provides the definitions that determine what qualifies as a "product" for the purposes of the rules, and that definition is not limited to end products. Article 38 regulates the obligations of actors in the supply chain, which becomes relevant once a semi-finished product is further processed into a passport-obligated end product. And Article 12 describes the unique identifier that belongs to a passport, which indicates how specifically a passport is linked to a product or batch. None of these articles specifically designates aluminium semi-finished products at this time; that occurs only via the delegated act.

Anyone wishing to monitor whether and when this will apply to their own aluminium semi-finished product should best keep track of the designation of product groups via the page on what falls under the ESPR for the aluminium sector, and in the meantime review which data is already being collected within their own company, so that it is ready when the obligation becomes concrete.

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

The question of whether a semi-finished product already falls under the product passport hinges on one thing: is there a delegated act that specifically mandates this product group? The ESPR itself (Regulation (EU) 2024/1781) is a framework regulation. Article 1 sets out the scope, but the regulation does not itself specify by product group when the passport becomes mandatory — that occurs by product group in a delegated act. For aluminium semi-finished products, that act does not yet exist. What can already be said is contained in the definitions and in the obligations that will apply once the act is in place.

What counts as a "product" under the ESPR

Article 2 of the ESPR provides the definitions that determine what is regarded as a product and what as a component of a product. An aluminium profile, sheet or coil that is further processed or worked into an end product may, depending on the definition in the later delegated act, be treated either as a standalone product or as a component. For a company with 10 to 100 employees that supplies semi-finished products to processing companies, this means that the company's own position in the chain — supplier of raw material versus manufacturer of a finished product — also determines which obligation applies at what time. More on this demarcation can be found in which products from the aluminium sector fall under the ESPR.

What the delegated act regulates per product group

Because the ESPR is a framework, the delegated act determines the actual content per product group: which data, which thresholds, and from which date. For aluminium, that act has not yet been published. This means that there is currently no fixed obligation for semi-finished products, but also that there is no guarantee that semi-finished products will be excluded when the act does appear. How this process works and why the content of the obligation is only fixed then is explained in what a delegated act is and why it determines what you must do.

Obligations for actors in the supply chain

Article 38 of the ESPR describes requirements for actors in the supply chain: everyone who moves a product or component further along the chain will have a role in transmitting information once that is mandatory. For a manufacturing company, this practically means that its own position — raw material supplier, processor, or end manufacturer — determines which data will have to be supplied and to whom. A company that supplies semi-finished products to a profile builder or foundry will in practice often have to provide data to the party that ultimately compiles the passport, even if the passport itself only becomes mandatory at the level of the end product.

The unique identifier as a future point of reference

Article 12 regulates the unique identification code that is assigned to a product once the digital product passport becomes mandatory. This code is the key used to link data throughout the supply chain — from raw material to end product. For a semi-finished product, this means that when the obligation ever takes effect, the question arises whether the semi-finished product itself receives its own code, or whether the code only comes into being in the end product into which the semi-finished product is incorporated. That switch has not yet been converted into a concrete rule for aluminium at this time.

Where things go wrong in practice

An aluminium profile supplier assumes that the digital product passport is only the responsibility of the party that places the end product on the market, and therefore does not pay attention to recording origin and composition data. If the delegated act then requires that data to come from the semi-finished product stage, the foundation to comply quickly will be lacking.

A foundry assumes that "semi-finished product" automatically falls outside the obligation, without checking how the final definition in the delegated act will be worded. The ESPR definitions in Article 2 actually allow room for interpretation that will be filled in per product group.

A packaging producer confuses the status of semi-finished product with that of end product, and thinks that because its own material is still processed by a third party, no obligation can arise. Article 38 shows that actors who do not sell the end product can also be given a role in passing on information.

A company asks the question "does this apply to me" too late, namely only when the delegated act has already been published, and then no longer has time to reconstruct data on origin and composition retroactively.

An importer of aluminium coils relies on what competitors do, instead of on the text of the regulation and the ESPR work programme, and thereby falls behind the actual schedule instead of anticipating it in time.

What you can document now

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.