How often must I update the data in the product passport?

What you must concretely do

The ESPR stipulates that the digital product passport remains linked to the product for which it was created, but the regulation does not work with a fixed calendar on which data must be reviewed. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes that the passport contains the information that follows from the delegated act for the product group, and article 10 of the ESPR (Regulation (EU) 2024/1781) describes the technical requirements that the passport and the data carrier must meet. For aluminium semi-finished products, that product-specific act does not yet exist, so a concrete deadline for updating — every year, with every change, with every batch — is not fixed at this time. What does follow from the design of the regulation, however, is that a passport is not a snapshot that you create once and forget: it must remain consistent with the product that is on the market, as long as the passport is active.

What is expected of you

The passport must match the product as it is on the market

A product passport describes a specific product or a specific product group, with characteristics that are inherent to that product. For a profile manufacturer or foundry, this practically means that changes in composition, alloy or the origin of the material are reflected in the passport of the relevant batch or article. A company of 10 to 100 employees often works with a limited number of alloys and a varying scrap mix; as soon as that mix changes, the share of recycled material and possibly the CO2 value in the passport usually changes as well. How you substantiate that share is described on the page on how you demonstrate the share of recycled aluminium.

The data carrier (QR code) must continue to point to valid information

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes requirements for the carrier that provides access to the passport. Practically, this means that a QR code on a profile or casting must not point to a dead link or an outdated dataset at the moment someone scans it. For a company that has the passport hosted, this is mainly a matter of submitting amended data to the hosting party, so that the underlying data remain current without the carrier itself having to change.

Revised information must be traceable to the correct product or the correct batch

A passport that is overwritten without it being clear which version belonged to which delivery makes it impossible for a customer to see what value applied at the time of purchase. For companies that produce to order with small variations per batch, this is a real point of attention: the link between the passport and the physical product must match, even retroactively.

Changes in legislation and regulations may require adjustment of the content

Once the delegated act for aluminium is published, it will presumably specify which data are mandatory and possibly also how often they must be reviewed. Until that time, the safest assumption is that the content of the passport moves with what is actually in the product, not with a fixed annual cycle.

Where things go wrong in practice

A foundry adjusts the scrap mix to meet a specific alloy requirement, but forgets that the CO2 value assigned to that alloy changes due to the adjusted share of recycled material. The passport continues to show the old value while the actual emissions have decreased — or increased.

A profile manufacturer changes the surface treatment (for example from anodising to powder coating) for part of the production, but the passport of the new batch still refers to the old treatment. See also the explanation on when the surface treatment must be reported.

An importer of aluminium semi-finished products takes data from a foreign supplier, but does not check whether that data is still correct after a change of supplier. The passport then remains linked to a source that no longer represents the actual origin of the material.

During an internal reorganisation, the person responsible for compiling the passport changes, without a fixed process for who communicates changes to the hosting party. Updates are thereby delayed, not from lack of willingness but because nobody sees it as their responsibility anymore.

A company assumes that the passport, like the technical file, only needs to be updated in the event of significant product modification, and thereby misses the fact that the passport serves a different purpose. The difference between those two documents is described on the page about the difference between the technical file and the digital product passport.

What you can document now

• An overview of which data in the passport are subject to change due to modifications in production (scrap mix, alloy, surface treatment), so that it is clear which internal signals call for an update.
• A fixed point of contact or process for communicating changes to the party hosting the passport, including a short checklist per delivery or batch.
• A link between production batch numbers and passport versions, so that a customer can retroactively see which data applied at the time of delivery.
• Justification of the method by which values such as CO2 emissions or recycled content are determined, so that an update of those values can be traced back to a fixed calculation method. See for this the explanation about the method for measuring the values in the passport.
• A log of changes to the passport, including date and reason, so that during an inspection it is clear that the passport was actively maintained and not filled in once only.
• Agreements with suppliers on the timely communication of changes in origin or composition of purchased aluminium, so that the own passport data can be adjusted accordingly.