What does the product passport mean if I import aluminium from outside the EU?

Import from outside the EU does not change the digital product passport requirement

Aluminium imported from outside the EU and placed on the EU market is subject to the same digital product passport requirement as aluminium produced in the EU itself. A company importing such a product acts as an importer within the meaning of the ESPR (Regulation (EU) 2024/1781) and thus assumes its own role and responsibilities in addition to those of the manufacturer outside the EU. The digital product passport itself does not change: it contains the same data on origin, composition and recycling options, regardless of where the product comes from. What does change is who is held accountable if something is missing: in the case of import, this is initially the importer, and customs checks this upon entry into the EU.

Who this applies to, and what falls outside the import obligation

This section covers companies that import aluminium semi-finished products — profiles, castings, packaging aluminium — from a country outside the EU and place them on the EU market for the first time. For these companies, the importer obligation under Article 29 of the ESPR applies, even if they did not produce the aluminium themselves. This does not apply to companies that trade aluminium only within the EU without having imported it themselves from outside the EU; they are a distributor or buyer, not an importer, and have different obligations. Nor does it apply to goods that merely transit through the EU without being placed on the market (transit), and it applies only to aluminium products that actually fall under a delegated act for aluminium — which does not yet exist at this time.

When this will come into effect

There is no fixed date yet. The ESPR itself is the framework; the concrete obligation for aluminium will only arise with a delegated act that is specifically established for aluminium products. According to the European Commission's work plan for 2025–2030, the delegated act for aluminium is expected around 2027, with the obligation entering into force thereafter — presumably around 2029. This date is not fixed and may shift. Until the delegated act is published, there is no digital product passport requirement for aluminium upon import, and the existing customs and import rules that currently apply will continue to apply. Once the act is published, this page will be updated with the definitive date.

What this means for the importer, step by step

For those looking ahead now, the sequence is clear. First, it is important to follow whether and when the imported type of aluminium product will fall under the delegated act — not every aluminium semi-finished product will need to comply at the same time. Next, it is practical to make arrangements with the manufacturer or supplier outside the EU regarding who will supply the underlying data for the digital product passport: composition, origin, recycling information. This data must be in place before the product crosses the EU border, as customs can check upon entry whether the required digital product passport is present and accessible. Following this comes the importer's own responsibility: adding their name and contact details, checking whether the manufacturer's information appears complete, and keeping documentation so that it can be shown to supervisory authorities upon request. Finally, it is important that storage and transport of the aluminium after import do nothing that jeopardises the accuracy of the digital product passport data — a digital product passport that was correct upon import must also be correct when the product reaches the next link in the chain.

Based on: Articles 15 and 29 ESPR

This allocation of responsibilities follows directly from the ESPR. Article 29 describes the obligations of importers: they are considered a separate link with their own duties, alongside and not instead of the manufacturer outside the EU. Article 15 regulates customs controls with regard to the digital product passport: it gives customs the authority to check upon import whether the required passport is present and accessible, as part of the control on placing products on the EU market. Together, these two articles ensure that a product coming from outside the EU cannot escape the passport obligation simply by being produced outside the EU: the obligation shifts to whoever brings the product into the EU.

If you are already importing aluminium from outside the EU, it is best to check which product category your goods will fall under and engage in timely discussion with the manufacturer or supplier about which data are available. For the current status of the delegated act for aluminium, the official ESPR text and the work plan of the European Commission are the first place to consult; as soon as more is known here, it will be processed on this page.

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

When importing aluminium from outside the EU, an importer is not a pass-through party under the ESPR but the party bringing the product onto the European market. This entails a separate set of obligations, regardless of what the manufacturer outside the EU has or has not arranged.

Verify that the product passport is present before the product is released

Article 29 of the ESPR (Regulation (EU) 2024/1781) places on the importer the task of checking that the product is accompanied by the required digital product passport before the product is placed on the market in the EU. For a company with 10 to 100 employees, this means in practice that someone within the procurement or logistics process must be responsible for that check, with every shipment and not only the first. Without a passport, no import that complies with the rules — that is a different position from that of a European producer who compiles the passport itself.

Assess whether the data in the passport are correct

The importer is not expected to blindly trust what the manufacturer outside the EU supplies. Article 29 asks to verify that the manufacturer has taken the necessary steps and that the technical documentation and the passport correspond with what is actually being supplied. In practical terms, this means: not only checking whether there is a QR code on the roll or the bundle of aluminium, but also whether its content matches the alloy, the origin and the batch actually received. How such verification can look is described on the page on how you verify a supplier's data for accuracy.

State own name and contact details

An importer bringing a product into the market must be identifiable on the product itself (or in the accompanying documentation) with name and contact details. For medium-sized companies, this is mainly a matter of administrative organization: the correct company details must be consistently linked to the shipment and to the passport, even when dealing with varying agents or freight forwarders.

Keep documentation

Article 29 expects an importer to be able to produce documentation: about the manufacturer, about the conformity of the product and about the passport itself. For a company without its own legal department, this comes down to a file per supplier and, where relevant, per batch: correspondence, certificates, and the passport data as received. Which data are needed for this depends on the question what data are requested from an aluminium supplier — for an importer outside the EU, the same basic principle applies, except that the responsibility to request and retain that data is greater, because there is no European supervisory authority that can address the manufacturer directly.

Cooperation with customs controls

Article 15 of the ESPR links the digital product passport to customs procedures on import. Customs authorities may consult the passport as part of the inspection of products entering the EU. For an importing company, this means that the passport is not only a sales argument or an obligation towards the end customer, but also a document that plays a role at the border. A shipment without an accessible or correct passport can therefore get held up at a point where that was not an issue before.

Where things go wrong in practice

A number of situations recur regularly in import practice.

The manufacturer outside the EU supplies a passport, but the QR code points to a page that is not available in an EU language or does not match the alloy actually supplied. The importer discovers this only when customs or their own customer raises questions about it.

An importer assumes that the manufacturer "will handle the passport" because that is mentioned in the contract with a supplier outside the EU, without ever actually verifying that the passport is present and correct for a specific shipment. This relates to what is recorded when the supply of passport data in a purchase contract is agreed upon: a paper agreement is not the same as working delivery per consignment.

For batches composed of mixed scrap or from multiple sources outside the EU, there is a lack of conclusive origin documentation. The importer then does not clearly know which data should be included in the passport, a matter that is discussed more extensively under the determination of data when aluminium comes from mixed scrap.

A fourth situation: the importer further processes the aluminium after import (for example by rolling, cutting or alloying with other batches) and assumes that the original passport from the manufacturer outside the EU remains fully valid without checking what exactly happens to the passport during that processing. This raises the question what happens to the passport upon further processing.

Finally: when importing via an intermediary or trader outside the EU, it is not always clear who should actually be designated as the manufacturer in the passport, causing the importer to request documentation from the wrong link in the chain or to be unable to trace where the aluminium originally came from — see also what to do when the origin of the aluminium cannot be traced.

What you can document now

A fixed inspection step in the purchasing or logistics process in which for each consignment it is checked whether the digital product passport is present, accessible and substantively correct, before the consignment is booked as "released for the EU market".
A file per manufacturer outside the EU with the data needed to demonstrate conformity and origin, including the date and the batch to which the data relate.
Written agreements with the manufacturer or exporter on the supply of passport data per consignment, included in the purchase contract or delivery terms.
A fixed procedure for storing the company's own business data as stated on the product or accompanying documentation, so that this is consistent with every import.
An overview of which batches come from mixed or multiple sources, so that if there is doubt about the origin, it is clear which steps have already been taken to clarify this.
Notes on how customs questions or inspections regarding the passport were handled, so that with the next consignment, one does not start from scratch again.

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.