Must I report the surface treatment of aluminium?

What you must concretely do

What is expected of you

A surface treatment such as anodising, powder coating, chromating or passivation changes the properties of the aluminium product: the corrosion resistance, the recyclability, and sometimes also the chemical composition of the surface. At present, there is no product-specific delegated act under the ESPR for aluminium that precisely specifies which data on surface treatment must be included in the passport. What is certain, however, is the framework within which that choice will be made in future.

The delegated act determines which information is mandatory.

Article 7 of the ESPR (Regulation (EU) 2024/1781) provides that information requirements per product group are established via a delegated act. This means that the question of whether a surface treatment must be reported will be answered at the time the act for aluminium products is published — not before. For a company with an anodising or coating line, this means that the current period is primarily a period of taking inventory: which treatments are applied, on which production lines, and with which chemicals. This information will be needed in any case, regardless of what form the obligation takes.

A surface treatment may be relevant for the performance requirements.

Articles 5 to 7 of the ESPR distinguish between ecodesign, performance requirements and information requirements. In practice, a surface treatment often touches on all three: it can extend the service life (performance), it can affect recyclability because a coating is sometimes difficult to remove during melting, and it can say something about the production process (information). For a company of 10 to 100 employees that applies surface treatment to semi-finished products, the practical significance is that the treatment should not be seen as a standalone detail, but as part of the overall picture that the passport will have to provide. That overlaps with the question what data are included in the aluminium product passport?, where surface treatment is one of the possible categories alongside alloy and origin.

The digital passport must make the data accessible, not necessarily make everything public.

Article 10 of the ESPR describes the requirements for the digital product passport itself: how the data must be accessible, via which data carrier, and for whom. That article says nothing about the content per product group, but it does say something about the form. For surface treatment, that distinction is useful: even if a delegated act subsequently asks for information about the treatment to be displayed, it is not automatically the case that every detail is visible to everyone. Those wondering how this will work in future will find more about the different levels of access at who may view which data from the product passport?

Where things go wrong in practice

The coating supplier is not included in the dossier compilation. A company that has aluminium profiles powder coated by a third party sometimes assumes that the coating information is not part of its own passport dossier because the treatment "takes place elsewhere". Once surface treatment becomes part of the information requirements, that separation is no longer tenable: the data on the treatment belong to the end product, regardless of who carried out the processing.

The chemical composition of the coating is not recorded separately. Some companies record only the process ("anodised") but not which substances were used. If the delegated act asks for more detail, that information is then missing retroactively — and is often more difficult to reconstruct afterwards than to record beforehand.

Different production lines with different treatments are lumped together. A foundry or profiles company that uses multiple surface treatments side by side (for example, both anodising and wet painting) runs the risk that it is not clear in the records which batch received which treatment. This becomes problematic once the passport must be able to demonstrate per product variant exactly what has been applied.

The link with recyclability is not established. A coating or anodizing layer has implications for how the aluminium is processed at end of life. Companies that already demonstrate the share of recycled aluminium according to the approach at how do I demonstrate the proportion of recycled aluminium? sometimes forget that a surface treatment of their own product affects the recyclability of that product later in the chain — a fact that will need to be combined in the future.

Waiting until the delegated act is available before recording anything. This is understandable because the precise obligation is not yet settled, but it means that historical production data on surface treatment is missing at the moment when it is requested. Recording what is already happening is separate from the question of when it becomes mandatory.

What you can document now

• An overview per product line of which surface treatment is applied, including any variations per customer or order.
• The name and details of the party performing the surface treatment, if that is an external supplier, so that the traceability of that step is ensured.
• A record of the chemicals or process substances used in the treatment, even if this is not yet requested.
• Internal arrangements on which department is responsible for maintaining this data, comparable to the approach that also applies to maintaining other data as described at how often must I update the data in the product passport?
• A note for each product variant on the test method used to establish properties of the treated layer, in line with the subject according to which method should I measure the values for the passport?
• Documentation on how the surface treatment modifies the product compared to the bare alloy, so that the link with the EN-AW designation of the base material remains clear — see also how do I record the alloy and the EN-AW designation?

Once the delegated act for aluminium is published, this will be supplemented with which of these data actually need to be included in the passport and in what form.