Does it matter whether my aluminium is primary or secondary?

What you must concretely do

What is expected of you

The ESPR does not make a distinction between primary and secondary aluminium in itself: the regulation describes in articles 5 to 7 that there will be ecodesign requirements and information requirements, and these can relate to matters such as recycled content, recyclability and environmental impact. Whether and how the origin of the aluminium — primary from ore or secondary from recycling — is taken into account exactly, depends on the delegated act that will be drawn up for aluminium. As long as that does not exist, there is no established calculation method or threshold value to work towards. What will or will not be included substantively, you can read as soon as that becomes known on the page about what is a delegated act and why does it determine what I must do.

Recording the origin of the material

For a company with 10 to 100 employees, this means in practice that it is useful to already know now which part of the incoming aluminium stream is primary and which part is secondary, per batch or per supplier. Not because a percentage is already mandatory, but because this information will probably be one of the data that end up in the passport. Those who keep track of this now will not have to retroactively reconstruct documentation later. Which data this will be exactly is described on the page about which data will be included in the aluminium product passport.

Substantiating with a recognised method

Article 39 of the ESPR concerns the test, measurement and calculation methods used to assess compliance with the requirements. That article makes clear that once the delegated act enters into force, a company's own calculation method cannot simply be used: there will be a prescribed method, and that will then apply to everyone in the sector. In practice, this means that an own assessment of the proportion of secondary aluminium — however carefully made — must at some point be replaced by a method that aligns with what is laid down in the act. Companies that already apply a calculation method for, for example, sustainability reports, would be well advised to document that separately, so that later it is clear what the basis was.

Origin as part of a larger whole

Primary versus secondary is one characteristic within a passport that will probably be broader, with data on composition, origin and processing. For profile manufacturers and extruders who work with varying alloys and origins, this is slightly different than for foundries that often work with scrap and secondary material. What this specifically means for the profiles sector is on the page about the product passport for aluminium profiles, and more generally on which products in the sector fall under the ESPR on the page about which products from the aluminium sector fall under the ESPR.

Where things go wrong in practice

A few situations come up repeatedly with companies that are preparing for this.

Mixing without registration. Companies that mix primary and secondary aluminium in the melt or during processing often do not keep track of the ratio in which this happens. Once origin becomes a reporting obligation, that ratio can no longer be reconstructed retroactively.

Assumption that 'recycled' is the same as 'secondary'. In practice this is used interchangeably, but it is not automatically the same definition that will be applied in future legislation. For now, a company's own definition does not present a problem, but it is something to keep in mind when the delegated act appears.

Suppliers who do not provide origin information. Anyone who purchases aluminium as a raw material or semi-finished product is dependent on the supplier or importer for this data. If that party does not record whether it is primary or secondary material, there is nothing to report for the company's own business either. This is particularly an issue with imports from outside the EU.

Unclear about who provides the data for semi-finished products. A company that purchases aluminium, processes it further and resells it, does not always know whether the origin data from the original manufacturer are passed on or whether these must be supplemented by itself. More on this is on the page about whether a product passport is already required if the aluminium is still a semi-finished product.

Packaging aluminium treated separately from the rest of the assortment. Companies that produce both profiles and packaging aluminium sometimes assume that the rules for both will be the same. This has not yet been established; what is specifically relevant for packaging aluminium can be found on that page: the product passport also applies to packaging aluminium.

What you can document now

• Per purchase batch: whether the aluminium is primary, secondary or a mixed form, with source reference from the supplier.
• The ratio of primary/secondary when mixing material in own production processes, including date and batch number.
• Correspondence with suppliers and importers about the origin of the supplied material — especially when importing from outside the EU.
• The calculation method that may be used internally to determine the share of secondary material, with a brief description of the assumptions.
• An overview of which product lines work with which type of aluminium, so that when the delegated act is published it is quickly clear which lines are affected first.
• Any existing sustainability certificates or declarations about recycled content, even if these are now drawn up for a different purpose than the product passport.

Anyone who already has doubts about whether this will be relevant for their own product will find a first outline on the page about whether the digital product passport applies to their aluminium.