According to which method must I measure the values for the passport?
Measurement method follows from the product-specific decision, not from the ESPR itself
The ESPR (Regulation (EU) 2024/1781) establishes in Article 39 that a specific test, measurement or calculation method will be adopted for each product group, but the regulation itself does not contain that method. For aluminium semi-finished products — profiles, castings, packaging material — that method is yet to be established in a delegated act that is specific to aluminium. Until that act is in place, there is no prescribed way to measure, for example, the recycled content, the CO2 footprint or the recyclability of an aluminium product for the purposes of the passport. The regulation does describe the framework within which that future method must fit: reliable, accurate and reproducible, and based as far as possible on harmonised standards.
Who this applies to, and who it does not (yet) apply to
Article 39 applies to any product group for which the Commission establishes ecodesign requirements in accordance with Articles 5 to 7 of the ESPR — including aluminium, once that product group is reached. The article concerns the way in which a manufacturer or importer must demonstrate that a value is correct, not which specific values must be reported: the latter follows from the information requirements in the product-specific decision itself. It is also important to note what does not fall within its scope: existing measurement methods that are already common in the aluminium sector (for example for mechanical properties or alloy composition) do not automatically become the method for the product passport. The passport requires a method that the Commission specifically designates for this purpose, and that method may differ from what a foundry or profile manufacturer currently uses internally for quality control.
No established date yet, and therefore no mandatory method
No delegated act for aluminium has yet been published, and therefore no measurement method is established. According to the Commission's work plan for ecodesign for the period 2025-2030, that act is expected in 2027; when aluminium actually receives a mandatory product passport will depend on when that act becomes final and on any transitional periods within it. Until then, there is no legal measurement obligation for aluminium under the ESPR. Once the act is in place, this page will be updated with the exact method and the date on which it applies.
What to do while the method is not yet established
Anyone considering the product passport now would be well advised to start by making an overview of the data that will almost certainly be requested: the origin of the aluminium (primary or recycled), alloy composition, and data on processing and origin in the supply chain. This is useful work, regardless of which exact measurement method is prescribed later, because the underlying data will need to be collected anyway. There is no point in already investing in a specific test facility or certification in anticipation of the delegated act, because the method the Commission designates may differ from what sector stakeholders currently regard as standard — and an investment that does not align with the final requirement is wasted effort. Those affiliated through a trade association or standards institute can follow the development of the delegated act, because when drawing it up the Commission often engages the European standardisation organisations to develop standards that can serve as a measurement method. Alupas.eu follows this development and will integrate the method into the platform as soon as it is established, so that a manufacturer or importer does not need to submit data twice according to two different systems.
Where this is based: Article 39 and Articles 5 to 7 of the ESPR
The obligation to establish a test, measurement and calculation method per product group is laid down in Article 39 of the ESPR (Regulation (EU) 2024/1781). That Article specifies that these methods must be accurate, reliable and reproducible and should preferably align with harmonised European standards; if such standards are lacking, the method may be incorporated directly in the product-specific delegated act. The link to the ecodesign requirements themselves — that is, which properties of an aluminium product must then be measured — follows from Articles 5 to 7 of the same Regulation, which form the general framework for performance and information requirements per product group. For aluminium, both the requirements and the measurement method for them have not yet been worked out on a product-specific basis.
What to do now
Anyone placing aluminium products on the market now would be well advised to put their own supply chain data in order (origin, alloy, recycling percentage, processing steps) without waiting for or getting ahead of a specific test method that does not yet exist. Alupas.eu monitors the publication of the delegated act for aluminium and will update this page as soon as the method and entry into force date are established.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (ecodesign requirements, performance and information requirements)
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
Measurement according to the method applicable to the product group
Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that values for the product passport are not freely chosen, but are established according to a defined test, measurement or calculation method. This method is developed per product group in the delegated act that also sets out the other requirements for that group — for aluminium semi-fabricated products, this is the act that is still to be published. For a company with 10 to 100 employees, this means above all: the way in which measurement or calculation is already carried out (for example for internal quality control or for customer specifications) is not automatically the method that will apply to the passport in future. It is a separate step to verify this as soon as the act is available.
Traceability of the method used
Articles 5 to 7 of the ESPR link the performance and information requirements to each other: a value that appears in the passport must be consistent with what has been established about eco-design. This means that a company must not only record an outcome (for example a CO2 figure or a recycling percentage), but must also be able to demonstrate how that outcome was calculated. For a medium-sized company, this comes down to keeping track of which standard, which formula or which measurement setup belongs to which figure — not as additional red tape, but as part of the figure itself.
Consistency between different values in the same passport
A passport for aluminium contains several types of values side by side: composition, CO2 emissions, recycled material content, possibly data on surface treatment. Each of these values may have its own measurement method. The obligation that follows from Article 39 is that for each value the associated method is traceable — not that one method applies to the entire passport. For the way in which the recycled material content is demonstrated, for example, different considerations apply than for how CO2 emissions per tonne of aluminium are demonstrated; both must exist side by side in the same passport without overlapping.
Recording who carried out the measurement
In a shared chain — manufacturer, importer, platform that compiles the passport — it is important that it is clear who has supplied which value and on the basis of which measurement or calculation. This touches on the question of how a company's technical file relates to the digital product passport: the difference between the technical file and the digital product passport lies partly precisely here — the file typically contains the underlying measurements and calculations, the passport the outcome that follows from it.
Where things go wrong in practice
A foundry has used a specific calculation method for internal reporting for years to determine the recycled aluminium content, based on mass balance over a year. Without verification of whether this is also the method that the delegated act will prescribe, this value is provisionally entered into a draft passport — with the risk that the method does not match.
A profile manufacturer supplies CO2 figures from a supplier without establishing which calculation method that supplier used to arrive at that figure. When asked about it, there is no underlying document to refer to.
A packaging producer switches halfway through a financial year to a new, more accurate measurement method for a particular value, but older passports in circulation still refer to the old method — without it being recorded anywhere when the switch took place and why.
An importer takes over values from the foreign manufacturer without asking which measurement method was used, and only discovers when asked by a customer that the method differs from what is customary in the EU for the same value.
A company combines in one passport values that have been measured according to different editions of the same standard — for example an older and a more recent version of a test method — without this difference being stated anywhere.
What you can document now
- Per value in the passport: which test, measurement or calculation method has been used, including standard or method version.
- Date and circumstances of the measurement or calculation, so that a value does not become disconnected from the moment it was established.
- Name of the party that performed the measurement or calculation (own laboratory, external party, supplier).
- Underlying documents (test reports, calculation sheets) that align with what in the technical file is already being kept, so that passport and file do not contradict each other.
- An internal overview of which method applies to which value, to be consulted once the delegated act for aluminium semi-finished products has been published and the methods are finally established.
- Agreements with suppliers or importers on which method they use for values they supply, so that this does not only become apparent upon a later inquiry — relevant for, among others, the share of recycled aluminium and the CO2 emissions per tonne.
- A note on changes of method over time, so that older and newer passports can exist in an explainable manner alongside each other.
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.