how do I explain to my colleagues what changes with the product passport

It is not about IT, it is about who supplies what

The digital product passport primarily changes who within the company is responsible for data that may not have been structured anywhere until now: alloy composition, material origin, recycling percentage, processing instructions. For most teams, this is therefore not an ICT project but an organizational matter: who supplies that data, who checks it, and who is the point of contact if a customer or supervisory authority asks about it. Explaining it to colleagues works best if you do not frame it as "a new law" but as "a new data stream that is attached to the existing production process".

For the commercial, technical and logistics side — not for management alone

This topic affects more than one department. The technical department or quality department usually knows best which material data are already fixed and which are still missing. Sales and customer service receive the question first from a customer who wants to know something about the passport. Logistics and packaging come into play once a physical QR data carrier needs to be placed on a roll, bundle or pallet. What this topic is not: a replacement for existing quality certificates or environmental declarations. The passport collects and unlocks data; it does not prescribe which technical requirements the aluminium itself must meet — that remains separately regulated. It is also not a task that necessarily belongs to one person; Article 38 of the ESPR (Regulation (EU) 2024/1781) describes precisely that different actors in the supply chain — manufacturer, importer, distributor — each have their own role in supplying and passing on information.

The obligation comes product group by product group; a date for aluminium is not yet set

There is no fixed date yet for when the digital product passport for aluminium semi-finished products becomes mandatory. The ESPR works with a work plan in which the European Commission determines per product group when the delegated act with the precise requirements comes; Article 18 of the ESPR describes that prioritization and planning. For aluminium, that act has not yet been published. Once that happens, the mandatory date is set and will be mentioned here. Until then, there is no legal obligation, but there is a clear direction: the requirements for the passport itself — which data it must contain, how it must be accessible via a data carrier such as a QR code — are already set out in Article 9 and Article 10 of the ESPR. That is precisely why preparing now makes sense, even without a hard deadline. What a team can do with this concretely is described on the page about what you can already do while the rules are not yet final.

This is how you explain it step by step to colleagues

Start with the why, not the what. Explain that a customer will soon scan a QR code and see data about the product — alloy, origin, recycling content, processing advice — instead of having to ask for it by email. This makes it concrete and recognizable, even for colleagues without a regulatory background.

Then go through the data that already exist. Ask the technical department which information is already in certificates, test reports or internal systems, and which data are still missing or scattered across different files. This is also immediately the first step of the approach described on the page how you tackle the product passport for aluminium step by step.

Then discuss who becomes the point of contact towards customers and towards a possible supervisory authority. This does not have to be the same person: sales can receive the question, quality can provide the answer. What a supervisory authority could concretely ask during an inspection is described on the page about what a supervisory authority asks during an inspection of aluminium — that is useful material to go through in a team meeting, so that no one is caught off guard by a question to which the answer is already at hand.

Finally, make a practical arrangement about inventory and outstanding orders: is it about new production lines, or also about material already on the shelf. That distinction is just as relevant for a team as it is for management, and is explained on the page about what you do with aluminium inventory already in place when the rules come into effect.

A good first team session need not contain more than: what is the passport, what data do we already have, who is the point of contact, and when will we revisit this. The rest will follow once more becomes clear.

The legal basis: articles 9, 10, 18 and 38 of the ESPR

What the passport must contain and how it must be accessible is set out in article 9 and article 10 of the ESPR (Regulation (EU) 2024/1781). When that obligation applies to a specific product group is determined via the prioritisation in article 18. And which party in the chain — manufacturer, importer, distributor — must provide or pass on which information follows from article 38. Together, those four articles form the framework within which a team can determine its role, even while the delegated act for aluminium has not yet been published.

A practical next step is to start a data inventory within the team and record who takes on which role once more clarity emerges — this takes little time now, and saves effort once the date is confirmed.

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

The digital product passport concerns not only the department responsible for compliance. Procurement must ask different questions of suppliers, production must start keeping data that may not currently exist anywhere, and sales will face questions from customers who themselves must also be able to present a passport. Anyone who starts to explain this only once the obligation comes into force will be playing catch-up. Anyone who makes it a topic for discussion now gives the team time to adapt to a different way of working.

What is expected of you

Gathering and maintaining data

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a data set attached to a product and retrievable via a data carrier, such as a QR code. For a company of 10 to 100 employees, this means in practice that someone — often a combination of quality, procurement and production — must know what data about an aluminium semi-fabricate already exists, what is missing and who supplies it. This is not a one-off exercise: the data must be accurate as long as the product is on the market.

Knowing which requirements apply per product group

Article 10 of the ESPR determines that the precise content of the passport is laid down per product group. For the team, this means that the question "what must be in it?" cannot be answered with a general answer. Someone within the company must keep track of which product group is applicable and what is specifically established for it — this is different work from filling in a fixed form.

Tracking which product group is next in line

Article 18 of the ESPR describes that the Commission draws up work programmes and priorities for which product groups fall under the rules when. For a company, this means that the question "when must we be ready for this" is answered at product group level, not all at once for the entire sector. Anyone who does not keep track of this will be caught off guard by a deadline that has actually been known for some time. A team prepared on this subject knows where the answer is When does the product passport become mandatory for aluminium? to be found and can check that page regularly.

Passing data on to the next link

Article 38 of the ESPR concerns the obligations of actors in the supply chain: anyone passing on a product must ensure that the data associated with the passport is also passed on. For a company supplying aluminium semi-fabricates to a processor, this means that sales and logistics must know that a delivery is incomplete without the accompanying passport data — this is something different from a delivery note or invoice.

Where things go wrong in practice

A few situations come up repeatedly among companies preparing for this:

Compliance knows about it, the shop floor doesn't. One person has read the regulation, but production and procurement only hear about it when the first customer asks for a passport. By that time, there is no time left to collect data calmly.

No one knows where the source data should come from. Alloy composition, origin, recycling percentage — those data often exist, but are scattered across certificates, supplier declarations and internal test reports. Without someone bringing that together, the passport does not emerge automatically from existing systems.

Responsibility is not assigned. It sounds like a task for "someone from quality or sustainability", but without a name and time on the agenda, it remains a matter of good intentions.

Sales promises things that are not yet settled. An account manager tells a customer that the passport will be there "next year", while the date for that product group has not yet been determined. That sets expectations that the company cannot meet.

People wait until everything is certain. Because the delegated act for a product group has not yet been published, no one does anything — while collecting data and testing a working method can already begin. Anyone who wants to see what is already possible in this will find starting points on the page about What can I already do while the rules are not yet final?

What you can document now

A number of agreements and documents help to move the subject from "something in the law" to "something the team understands":

An overview of who supplies which data. Per aluminium product: who supplies the alloy data, who the origin, who the test report. This overview is the basis for everything that follows.
One person responsible per product group, with a clear task: follow when the rules for that group become concrete and inform the rest of the team.
An internal explanation in plain language about what a product passport is and is not, to be used in a team meeting. The page What is a digital product passport for aluminium? is a good starting point for sharing or using as a basis.
A list of products for which the question "does this apply to us" still needs to be answered. Not every aluminium product automatically falls under the same rules; those who check this per product line via Does the digital product passport apply to my aluminium? prevents the team from doing half work.
A test case. Before the obligation takes effect, a team can already experience how filling in and submitting data works in practice. Anyone who wants to know what this looks like should read more on the page about can I test a product passport now before it becomes mandatory.
A brief note on the role of procurement and sales in the chain, based on article 38: who supplies to whom, and which data will in future go standard with a delivery.

Together, these documents do not form a compliance file, but a working basis: something with which the team can have the conversation without everyone having to read the regulation themselves.

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 2026-09-05. Is something incorrect? Let us know — corrections are prioritised.