What is the registry of digital product passports and what do I need to enter into it?
The register is the reference system, not the digital product passport itself
The register of digital product passports is a central system that the European Commission establishes and manages, in which unique identification codes and references to digital product passports are recorded. The register does not contain the content of a passport — that is, not the material composition, origin or recycling data of an aluminium profile — but it does contain the data with which a passport can be found and verified: a unique product identification, a unique identification of the market operator, and a link to the location where the passport actually stands (for example at a platform such as alupas.eu). In addition to this register, there will be a separate web portal with which customers and other interested parties can search and compare data from passports. The register is therefore primarily a reference system for supervision and control; the web portal is aimed at accessibility for a broader public.
Who this applies to, and who it does not
This obligation concerns the market operator that places a product with a digital product passport on the market — for aluminium semi-finished products this is usually the manufacturer or the importer, the same party that is also responsible for compiling the passport itself. The register does not apply to intermediaries or processors who resell a product with an already existing passport: they do not need to carry out a new registration, unless they themselves act as an importer or manufacturer. The register also only applies to product categories for which a digital product passport has been made mandatory via a delegated act; as long as such an act does not exist for a product category, there is no registration obligation for those products. For aluminium this is not the case at present.
When this comes into force is not yet fixed
There is no fixed date yet for the registration obligation for aluminium products to come into force. The registration obligation in Article 13 of the ESPR is linked to the moment when a delegated act for a specific product category enters into force that makes the digital product passport mandatory. For aluminium semi-finished products, that act has not yet been published; according to the European Commission's work plan for 2025–2030, such an act is expected by 2027. Once that act exists and contains an entry date, the obligation to have the associated identification data entered in the register applies from that moment on. Until then, the register exists as a system, but there is no obligation for aluminium to enter anything into it.
What this means in practice, step by step
Once the registration obligation for aluminium comes into force, the process runs broadly as follows. First, the digital product passport itself is compiled, with the data that the manufacturer or importer supplies about the origin, composition and processing of the aluminium product. After that, unique identification codes are created for that passport: one for the product, one for the market operator that places it on the market. Those identification codes, together with a link to the location where the passport stands — at a hosting party such as alupas.eu — are then submitted to the European register, before the product is placed on the market. From that moment on, customs and market surveillance authorities can consult the register to check whether a product has a valid passport, and customers can search for public data from the passport via the web portal and compare it with other products. For a market operator, this means primarily that compiling the passport and registering the identification codes are two linked but separate steps: the passport stands at the hosting party, its discoverability stands in the European register.
What this is based on
The obligation to establish a register of digital product passports and to include product identifications in it derives from Article 13 of the ESPR (Regulation (EU) 2024/1781). The obligation to additionally make available a web portal through which data from passports can be searched and compared derives from Article 14 of the same regulation. Both articles govern the infrastructure surrounding the digital product passport, separate from the substantive requirements for a passport itself, which are laid down per product group in separate delegated acts.
What to do with this information
For aluminium products, there is currently no registration obligation, so no action is required at the European register. What is useful, however: ensure in advance that the data that must go into a passport — origin, composition, processing steps — are in order and traceable, so that compiling the passport and subsequent registration can proceed smoothly once the delegated act for aluminium is published. This page will be updated as soon as that act and the associated entry into force date are known.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
- Regulation (EU) 2024/1781 (ESPR), Article 14 (web portal for data in the digital product passport)
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 European register of digital product passports is the central place where certain core data from each passport are stored, regardless of where the passport itself is hosted. Article 13 of the ESPR (Regulation (EU) 2024/1781) governs this register; Article 14 governs a web portal through which supervisory authorities and the public can access data from passports. For a company that manufactures or imports aluminium semi-finished products, this means that the passport does not stand alone: there must be a link between what appears on the product, what is hosted, and what is known in the register.
Ensuring that core data can be registered
The register works with a limited set of data per passport: identification of the product, reference to where the complete passport can be found, and similar basic information. For a company with 10 to 100 employees, this means that the administration surrounding a product must be in order before the passport is published: what exactly is the product, which identification code belongs to it, and under which name or code is it registered. This ties in with the question how do I give each product a unique identification code? — without a conclusive identification, registration in the register cannot be done properly.
Ensuring that the link to the passport works and continues to work
The register does not refer to the content of the passport itself, but to the place where the passport can be consulted. This means that the reference in the register must remain correct as long as the passport is required to be available. For a company, this means that changes to the hosting environment, a takeover, or changes in its own systems cannot simply happen without the registration being updated accordingly. This touches on the question how long must a product passport remain available? — the obligation to display something continues, and the reference in the register must continue to reflect that.
Ensuring that data remain current after changes
A product passport is not a snapshot; data can change, for example due to an amended composition, a new test report, or a changed importer. For a company, this means that there must be a procedure to determine when a change in the passport also entails a change in the register entry. This is connected with the question how do I update data in a product passport that is already published — the registration and the content of the passport must continue to match.
Taking accessibility via the web portal into account
Article 14 describes a web portal through which data from passports can be accessed. For a company, this means that the data supplied must be understandable without additional explanation to someone viewing the passport via that portal, not only via the company's own QR code on the product. This is a different reading environment from the company's own website or system, and it can have implications for how data are recorded and provided.
Where things go wrong in practice
A first situation: a company publishes the passport on its own page, but the registration in the European register is not updated until weeks later, or is done manually by someone who is on holiday. A gap then arises between publication and registration.
A second situation: the passport is hosted via a third party (such as alupas.eu), but during internal reorganisation the product assortment or the naming of articles changes, without anyone checking whether the register entry still corresponds to the new situation.
A third situation: a company thinks that one registration is sufficient for a product that is supplied in multiple compositions or sizes, whereas in reality each variant may require its own passport and registration. This is particularly relevant to the question do I register aluminium per batch or per item? — the way a company divides its own inventory does not automatically correspond to the way the register distinguishes between products.
A fourth situation: in the event of a merger, acquisition or closure of a business, the register entry remains unchanged while there is no longer anyone to maintain the link. This directly raises the question what happens to the product passport if my business stops? — the register does not account for business closure, so that transfer must be arranged in advance.
A fifth situation: a business assumes that its own ERP system automatically links to the register, while that link does not actually exist in reality or is incomplete. See on this subject can I link the product passport to my ERP or inventory system? — a technical link between systems is something different from a registration at the European register.
What you can document now
- An overview of which products (or product groups) have their own passport and registration, linked to the unique identification code per product.
- A fixed procedure for who within the business is responsible for keeping the register entry up to date following changes to the passport.
- An agreement on the point in time at which a change in data (composition, test results, importer) leads to an update of both the passport and the register entry.
- An overview of where and how the passport is hosted, so that when changing hosting provider or system the link in the register is included in the transfer.
- Documentation on how multiple variants of a product are handled, especially when multiple passports for a product may apply.
- A plan for what happens to the registration upon business closure, acquisition or cessation of a product line.
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.