My product needs multiple digital product passports — how does that work together?

Each product receives its own passport, which is linked to others

When a product consists of components that individually fall under the digital product passport obligation, no single overarching passport is created for the entire assembly. Instead, each component subject to the passport requirement — for example an aluminium profile, a battery, or the end product into which both are incorporated — receives its own passport. These passports are not separate from each other: they are linked to one another via the unique identification code prescribed by Article 12 of the ESPR (Regulation (EU) 2024/1781). In this way, someone who scans the end product can be directed via that code to the passports of the components from which it is made, without all information needing to be contained in a single file.

For material, for component, and for end product — not for every transaction

This issue arises especially with products that are further processed as raw material or semi-finished product: an aluminium profile that goes into a window frame, or aluminium sheet that becomes part of a battery housing. For the aluminium semi-finished product itself, a passport requirement may apply once the delegated act for aluminium is in place; for the end product (the frame, the battery) a separate, distinct passport requirement may apply under a different delegated act or regulation. These are then two different passports for two different products within the meaning of the ESPR — not one passport that "grows along". This does not concern the question of whether a manufacturer that merely supplies raw material (without a passport requirement yet applying to that raw material) must do anything themselves; nor does it concern the interaction with entirely different legislation such as CE marking or construction products rules — these are separate regimes not covered here.

No fixed date yet, but a timeline for aluminium

There is not yet a published delegated act that specifies when and how this will work exactly for aluminium semi-finished products. According to the ESPR work programme 2025-2030, that act is expected by 2027; the actual obligation would then, as expected, come into force around 2029. As long as the act has not been published, it is not determined what information will be included in the aluminium passport, and therefore also not exactly how the linking with passports of end products will work in practice. What is certain, however, is the principle from the basic regulation: passports are linked via a unique identification code, not merged into one passport per end product.

How this is being taken forward in practice

For those supplying aluminium semi-finished products that end up further down the chain in another product subject to the passport requirement, the first question is which passport belongs to which product: the passport of the aluminium product describes the aluminium product, not the end product into which it is processed. The second question is what data the purchaser needs in order to compile their passport — think of origin, composition or recycled content of the aluminium — and whether that data is already fixed in their own passport or must be provided separately. The third step is to ensure that the unique identification code of your own product is findable and transferable, so that a purchaser can use that code to refer to the aluminium passport from their own passport. Only when the delegated act for aluminium is published will it become clear which fields are mandatory and how that linking must be technically implemented; until then it is mainly a matter of knowing what information is available and where it comes from, so that it does not need to be looked up again later.

The basis: Article 9 and Article 12 ESPR

That a product receives its own passport instead of being included in the passport of another product follows from Article 9 of the ESPR (Regulation (EU) 2024/1781): the digital product passport is linked to a specific product via a data connection and a physical data carrier on or with that product. That a passport of one product can refer to the passport of another product — without the data needing to be merged — follows from Article 12: this article governs the unique identification code by which a product, and the data linked to it, can be uniquely traced. Together, these two articles form the basis that a chain of products can have a chain of linked passports, instead of one passport that encompasses everything.

If you now supply aluminium semi-finished products that end up in other products subject to passport requirements, it is best to already map out what data on origin and composition are available and where they come from — that inventory will be useful once the delegated act for aluminium provides clarity on the precise content of the passport. For the current status and the published text of the delegated act, the official EUR-Lex page of the ESPR is the appropriate source.

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

An aluminium semi-finished product rarely comes alone. An extruded profile may become part of a window frame, a casting may disappear into an engine component, packaging aluminium may end up as a component in a larger composite product. Each of those products may fall under its own delegated act, with its own digital product passport. The question that then arises: how do those passports relate to each other, and who is responsible for what?

The passport follows the product, not the supply chain

Article 9 of the ESPR (Regulation (EU) 2024/1781) links the product passport to the product as it is placed on the market. For the aluminium semi-finished product itself — the profile, the casting, the roll of packaging — the information applies that is relevant at that level: composition, origin, processing instructions. Once that semi-finished product is incorporated into another product, a new passport is created at that level, with its own responsible party: the manufacturer of the composite product. For a company with 10 to 100 employees, this means in practice that their own responsibility ends with the passport of their own product. No passport is compiled for what a customer does with it later.

Distinguish between material data and end-of-life data

What is often asked for, however, is that data from the passport of the semi-finished product flows into the passport of the end product — think of the share of recycled material or a chemical composition that remains relevant for the recycler at the end of the product's life. This is not an automatic consequence of Article 9 itself, but a practical arrangement between suppliers in a supply chain. For a mid-sized company, this is often the point where confusion arises: who supplies which data to whom, and in what format.

Each layer receives its own unique identification code

Article 12 of the ESPR regulates the unique identification code with which a product and its corresponding passport remain linked to each other. With multiple passports in a supply chain, this means that each level — the semi-finished product, the composite component, the end product — receives its own code. There is no shared or overarching code that identifies the entire supply chain all at once. For the question of how that code is precisely assigned and processed, the explanation about how do I give each product a unique identification code? is relevant, even when the product disappears as a supplying component in a larger assembly.

Know which passport applies to what

For companies that both supply semi-finished products and themselves process them into a further product, the question sometimes arises whether one passport could suffice for two levels of use. That is not the approach of Article 9: the passport belongs to the product as it is placed on the market as a unit. If the profile is sold separately and is also itself processed into a door or window construction, then in practice this concerns two products, each with its own passport, even if the underlying material data overlap.

Where things go wrong in practice

One passport for the entire batch, while the customer splits the product. A foundry supplies a batch of castings under one passport, but the recipient processes individual pieces in different end products. At that point, the question arises whether the passport was intended per piece or per batch — a question closely related to the choice described in do I register aluminium per batch or per item?.

Data filled in twice or contradictory. When both the supplier of the semi-finished product and the manufacturer of the end product each separately enter a chemical composition, small discrepancies can arise between the two passports. This is not immediately a violation, but it does raise questions at a check or with a customer about which source is correct.

Unclear about who applies the QR code. With a composite product, it is not always clear in advance whether the QR code of the semi-finished product must remain visible alongside that of the end product, or whether it is replaced. This touches on the practical aspect that is addressed at how does the QR code for the product passport get onto my aluminium? — a question that becomes more complex with multiple passports in the chain than with a single product.

Integration with internal systems that are not set up for multiple levels. A company that links the passport of its own semi-finished product to the ERP system sometimes discovers afterwards that this link was not designed for the moment when a customer requests data to be supplied for a passport at a higher product level. This is precisely where the setup described at can I link the product passport to my ERP or inventory system? makes a difference in advance.

No agreement on changes that have downstream effects. When a supplier adjusts a piece of data in the passport of the semi-finished product after publication, it is not automatically arranged whether and how that is communicated to the party that has incorporated it in its own passport. That affects the procedure described at how do I update data in a product passport that is already published.

What you can document now

An overview of which products in its own assortment count as loose semi-finished products and which are (also) supplied as part of a composite product.
An agreement with customers about which data from its own passport may be adopted in the passport of the next product level, and in what format that data is supplied.
A documented procedure for the unique identification code per product level, so that during an inspection it is clear which code belongs to which passport and which product.
An internal instruction on who is responsible for maintaining the passport of the semi-finished product, regardless of what a customer does with the product.
A procedure for communicating changes to customers who have adopted data in their own passport.
A template for the transfer of material data in the chain, so that not every customer imposes its own format.

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.