Does the product passport also apply to small businesses?

What you must concretely do

What is expected of you

Article 22 of the ESPR (Regulation (EU) 2024/1781) gives separate attention to small and medium-sized enterprises. The substance: the obligations arising from the ESPR apply to everyone falling within its scope, small or large, but the legislator recognises that a product passport is a substantial task for a company without its own compliance department. Therefore, the regulation provides for supporting measures for SMEs. This does not mean that small companies are exempted — it means that, alongside the obligation, there is also a form of support. For a company with 10 to 100 employees that extrudes aluminium profiles, manufactures castings or produces packaging aluminium, this translates in practice to a few recognisable points.

The obligation itself remains applicable.

Whether the product passport becomes mandatory for a specific type of aluminium product depends on the delegated act that the European Commission draws up per product group. Company size is not an exclusion criterion. A profile factory with fifteen employees is addressed in the same way as a large industrial producer, once the product group to which its aluminium relates falls under a delegated act. What this concretely means for a specific type of semifinished product is described on the page on which products from the aluminium sector fall under the ESPR.

Support may be available.

Article 22 mentions measures to help SMEs: these can include financial support, technical assistance or practical tools, depending on what is set up at European and national level. For a small foundry or extrusion company, this means it is worthwhile to monitor which support schemes become available as a product group moves closer to the obligation. Which support will be available exactly and via which channel is not fixed in the regulation itself — that will be determined later.

The content of the passport does not change due to company size.

A smaller company does not need to compile a different or lighter passport than a large producer. The data that become mandatory — composition, origin, recycling content, and the like — depend on the product group, not on the number of employees. Which data are concrete, is described on the page on which data will be included in the aluminium product passport. A small company must therefore collect the same source data, only with fewer people to do it.

The schedule is not fixed, not even for small companies.

Because the obligation is established per product group via a delegated act, small companies face the same uncertainty about the timing as large ones. No separate, later entry into force date for SMEs is mentioned in the text of the regulation. More on how this schedule is determined is on the page on when the product passport becomes mandatory for aluminium and on what a delegated act is and why it determines what must happen.

Where things go wrong in practice

"We are too small, this does not apply to us." This is the most common misconception. Article 22 speaks of support, not exemption. A small extrusion company that supplies profiles to a product group falling under a delegated act faces the same obligation as a large producer.

Making no time available because 'our large customers will handle this anyway'. Some small suppliers assume that a buyer with its own compliance department will compile the passport. But the source data on composition and origin must come from the manufacturer or importer itself — no one else can provide this.

Waiting for support schemes before anything is fixed. It is tempting to wait until it is clear what support will be available, but the data that will later be needed (composition, origin, process data) are being produced now or precisely not being recorded. Waiting will later cost time to reconstruct everything.

Making no distinction between semifinished product and end product. A small casting company that supplies semi-finished products to a third party that makes an end product from them sometimes thinks the obligation only applies to that third party. Whether and when a passport is already required for the semi-finished product varies by situation — see the explanation on semi-finished product versus end product.

Underestimating how much data collection itself requires, apart from the ESPR. A company with twenty employees often has no separate function for quality data or chain registration. Setting up a process to systematically record composition, origin and process parameters is a bigger step for a small company than for a producer with its own QA department — even though the obligation is the same in substance.

What you can document now

• An overview of which product groups from your own range (profiles, castings, packaging aluminium) may fall under a delegated act, with a reference to the page on what falls under the ESPR as a starting point.
• A basic record of origin and composition per product line, even if the passport is not yet mandatory — this avoids reconstruction work later.
• Contact details and agreements with suppliers about who supplies which source data, especially when aluminium is purchased from multiple smelters or recyclers.
• A note of the distinction between primary and secondary aluminium in your own production, because this information may become relevant for the passport — more on this on the page on primary or secondary aluminium..
• A file with any communication about support schemes for SMEs, as soon as these are published by the Commission or national authorities, so that a small company does not have to find out afterwards what was available.
• A template for internal responsibility: who within the company monitors developments around the delegated act for your own product group, and who collects the source data once it becomes concrete.