My supplier does not provide the data — what can I do?

What you must concretely do

What is expected of you

A product passport does not come out of nowhere. The data in it — alloy, origin, composition, recycling content — must come from somewhere, and in most cases it comes from the party that supplies or processes the aluminium. Article 38 of the ESPR (Regulation (EU) 2024/1781) sets requirements for actors in the supply chain, and article 27 describes the obligations of the manufacturer who must ultimately compile and bear the passport. Those in between — purchaser, processor, assembler — thus face two sides of the same obligation: requesting data from one party, passing data to another.

Requesting data from your supplier

A company that purchases aluminium semi-finished products typically does so from a handful of regular suppliers. For each of these relationships, the data needed for the passport is not automatically available — it must be requested, preferably before an order is placed and not only when the passport is already due. For a company with 10 to 100 employees, this usually means that one person (procurement, quality, or a combination) takes this on as a regular task, with a fixed list of what is requested. Which data exactly that is, is described on the page about data you request from your aluminium supplier.

Recording what is delivered

A verbal assurance that "the data will come along" is in practice not a basis to build on. What does work is to establish the delivery of passport data as part of the purchasing contract — including what is delivered, in what form, and when. How that concretely appears in a contract is set out on the page about agreements in your purchasing contract.

Passing on to the next party in the chain

Anyone who further processes or supplies aluminium often finds themselves on the other side as well: for their own customer, they are the party that must supply data. This makes the obligation feel double — a company is both requesting and supplying party, often in the same week. What happens to a passport once the material goes through a processing step is described on the page about the passport during further processing.

Where things go wrong in practice

The supplier does not respond. A request for data disappears into a mailbox, or is dismissed with "we'll sort that out later". Without a fixed agreement on delivery deadline, there is little basis to fall back on.

The supplier delivers, but too late. The order is already produced and shipped before the data arrives. The passport then comes about afterwards, which is awkward for your own company's planning if the passport must be present at delivery.

The supplier delivers incomplete data. A composition without a declaration of origin, or a recycling content without underlying calculation. This is often only discovered when compiling the passport itself, when it is too late to request additional information without delaying the delivery.

Multiple suppliers for the same alloy, with conflicting data. A company that sources from two smelters to ensure supply security finds that the stated composition does not match exactly. How this is handled within one passport is set out on the page about processing data from multiple suppliers for the same alloy.

The supplier is outside the EU and is not aware of the obligation. An importer who sources aluminium from outside the Union finds that the supplier does not recognize the request for passport data, because the ESPR is not a direct obligation for them. What this means for those who import is set out on the page about importation from outside the European Union.

What you can document now

If a supplier does not deliver, the first question is always: what exactly was agreed, and can it be found somewhere? A number of things help to be able to answer that question before the problem occurs:

• A data request in writing, with a description of which data precisely are required and for what purpose they are used. A fixed checklist prevents having to reinvent this for every order.
• A contractual provision on the supply of passport data, with a deadline by which the data must be received at the latest — for example linked to the delivery of the material itself, not to a separate moment afterwards.
• A receipt record, so that for every delivery it is documented which data were and which were not received. This is also the starting point for the verification that is part of checking whether the supplier's data are correct.
• A fixed procedure for what to do if data are not supplied: who follows up, after what period, and with what escalation. Even if no fixed legal sanction has been established, an internal procedure prevents a missing delivery from going unnoticed.
• A file per alloy or material stream, in which it is documented which supplier has supplied which data. This is especially relevant for material that does not come from a single, traceable source — see also the approach described on the page on data for mixed batches.
• A note on unknown origin. If a supplier cannot demonstrate the origin of the material itself, documenting that fact — who said it, when, and with what substantiation (or the lack thereof) — is already a step forward. What to do if origin cannot be traced is stated on the page on the absence of access to source data.

A template for a data request or a contractual provision saves time above all in repetition: the same question does not need to be formulated anew each time, and for a new supplier the standard for what is expected is immediately set. Anyone who at this moment is still checking whether the obligation applies to them can find a first entry point on the page on when the product passport applies to aluminium.