What happens to the passport if I process aluminium further?

Further processing may require a new passport

The digital product passport that accompanies the aluminium semi-finished product is created for that product as it leaves the manufacturer or importer. If the aluminium is subsequently further processed into another product — a profile that becomes a window frame, a casting that becomes part of a machine, packaging aluminium that becomes a can — then the question changes in character: is this still the same product with the same passport, or does a new product emerge for which its own passport is required? That answer is not fixed in the ESPR itself, but is determined per product category in a delegated act. Such a delegated act is expected for aluminium semi-finished products; for the end products into which further-processed aluminium ends up, different trajectories apply, with their own timeline. What the ESPR does establish: actors in the supply chain have obligations to pass on passport information and keep it accessible (Article 38), and each product or batch receives a unique identification code that links the passport to that specific product (Article 12). These two elements together determine in practice what happens to the data when the material changes form.

For the semi-finished product, not automatically for the end product

The passport that is compiled via alupas.eu belongs to the aluminium semi-finished product: the profile, the casting, the coil or sheet as it leaves the manufacturer or importer. That passport contains the data that is known at that time — origin, composition, recycling content, and what is otherwise established in the delegated act for aluminium. As soon as the material is sawn, cast, extruded into a new profile, anodised, or combined with other materials into an end product, a new product is in fact created. Whether that new product also falls under the ESPR passport obligation depends on the product category in which it ends up — windows, packaging, machine components — and on the question of whether a delegated act has already been established for that category. That is a different trajectory from that of the aluminium semi-finished product itself, with its own timeline that cannot be derived from the sources here. What therefore does not apply: the passport of the semi-finished product does not automatically 'move with' it as a ready-made passport of the end product. It is rather a building block: the data in it may be relevant for a passport of the end product, but that is a separate exercise.

No fixed date yet for further-processed end products

For the aluminium semi-finished product itself, the passport obligation is expected around 2029, with a delegated act anticipated for 2027; that date is not yet fixed and will be updated here as soon as the act is published. For end products made from further-processed aluminium, a separate track applies within the ESPR work plan, with its own — possibly later or earlier — planning per product group. As long as no delegated act has been established for such an end product category, no passport obligation yet applies to that end product, regardless of whether the aluminium semi-finished product used is itself already under the obligation. Until then, what Article 38 and Article 12 regulate in general terms remains in place: obligations to pass information on through the supply chain and to make products uniquely identifiable, as soon as and insofar as a product category falls under the ESPR rules.

What this means for those who further process aluminium

When you purchase and process aluminium semi-finished products, you can first of all keep the digital product passport of that semi-finished product and take the data in it — origin, composition, recycling content — as basic information for your own process. This data may be needed once your end product becomes subject to its own passport obligation, and it is more practical to have it on hand than to reconstruct it afterwards. Secondly, it is useful to monitor which product category your end product is intended for, and to check whether a delegated act is already in preparation for it within the ESPR work plan — that determines whether and when a passport obligation arises there. Thirdly: as long as your own end product does not fall under an established delegated act, there is no legal obligation to draw up a passport yourself, even though the aluminium you are working with is itself passport-certified. And fourthly, if the processed product is resold to the next party in the chain, the thinking behind Article 38 remains relevant: information that is needed to meet obligations further down the chain must remain available, even though the precise form of it is not yet defined for every product category.

The basis: Article 38 and Article 12 of the ESPR

The fact that passport information must be able to flow through the chain follows from Article 38 of Regulation (EU) 2024/1781 (ESPR), which imposes obligations on actors in the supply chain with regard to making available and passing on product information. The fact that each product or batch is linked to a specific passport via a unique identification code follows from Article 12 of the same regulation. Together, these provisions explain why a passport is in principle attached to a concrete product, and why processing into a new product raises the question of whether a new passport is needed — a question that is answered per product category in the delegated act that applies to it, and not in the ESPR itself.

Anyone currently processing aluminium semi-finished products is well advised to keep the passport and underlying data of the purchased semi-finished product, monitor whether there is any movement in the ESPR work plan for their own product category, and in case of doubt about a concrete situation, consult the official texts or the work plan of the European Commission — this page will be updated as soon as the delegated act for aluminium has been published.