Does the product passport apply to aluminium profiles?

What you must concretely do

What is expected of you

For aluminium profiles, no delegated act has yet been published. Without that act, there is no concrete obligation in place: no established date, no established data set, no established form of the QR data carrier. The ESVPR (Regulation (EU) 2024/1781) itself is a framework regulation: Article 1 describes the subject matter and scope, but the specification for each product group is carried out per product group via a separate decision. What exactly that is and how that process works is set out on the page about what a delegated act is and why it determines what you must doHowever, for a profile manufacturing company, it is not advisable to wait with all preparations until that act is in place. A few things can already be foreseen now.

Check whether profiles are in scope as a product category

Article 1 of the ESPR empowers the Commission to designate product groups via work plans that receive a delegated act first. Aluminium is mentioned in that context as a sector, but this is not a statement about profiles specifically. For a company with 10 to 100 employees, this means above all: monitor which product group within aluminium is first in line, and do not assume that profiles automatically receive the same date as, for example, packaging aluminium or castings. A broader overview of which product groups from the sector are mentioned in the ESPR is available on the page about which products from the aluminium sector fall under the ESPR.

Distinguishing between semi-finished product and end product

A profile that leaves the factory is usually not yet a final product — it is further processed, assembled or integrated by the next party in the chain. Article 2 of the ESPR works with definitions that determine at which level a product passport is linked: to the product as placed on the market. For an extrusion company this is a real point of attention, because the question of who compiles the passport and at what point in the chain this happens depends on where the "product" in the sense of the regulation originates. This question is discussed in more detail on the page about whether a product passport must already exist when aluminium is still a semi-finished product.

Demonstrate the origin of the material

Regardless of the precise content of a future delegated act, the ESPR establishes that a product passport contains data on the origin, composition and processing of the material. For profiles, the distinction between primary and secondary aluminium plays a role here, because this distinction is often already determined in their own procurement and melting administration. Companies that already have visibility into this data will be better positioned than companies that have to reconstruct this data later. What this distinction concretely means is described on the page about whether it makes a difference whether aluminium is primary or secondary.

Where things go wrong in practice

A profile manufacturer assumes that the obligation only becomes relevant at the moment the delegated act for aluminium enters into force, and therefore does not start any preparation. Upon publication, it subsequently becomes apparent that data on alloy composition, the origin of the scrap or energy consumption per production step have not been systematically recorded — resulting in a catch-up effort that no longer fits within normal planning.

An extrusion company supplies profiles to a customer who further processes them into a window frame or structural component. Uncertainty arises about who is responsible for compiling the product passport: the extruder, the processor, or both for part of the data. This is particularly relevant for companies that have not considered at what level in the supply chain their product is regarded as "placed on the market" in the sense of the regulation.

A company assumes that as a small enterprise it will remain out of scope, and therefore does not pay attention to the subject. The question of whether company size matters for the obligation is addressed on the page on whether the product passport also applies to small companies — the outcome of this is reason not to take this for granted.

A company confuses the general ESPR obligation with a product passport that is already specifically filled in, and thinks it is sufficient to arrange "something with a QR code" without the underlying dataset being established. As long as the delegated act is not in place, there is no established set of data to supply — what a product passport should substantively contain is explained on the page about what a digital product passport for aluminium is.

A company assumes that spare parts or further processed profiles fall outside the scope because it is not a "new" product. This is an assumption that can play out differently depending on the situation and is explained in more detail on the page about loose spare parts and the product passport.

What you can document now

• An overview per alloy and per batch of origin of the aluminium (primary, secondary, mix), including supplier data.
• A process description of the extrusion line with energy consumption and any coating or anodising steps, as a basis for future environmental data.
• An internal note on the point in the chain at which the profile is considered a "product" — upon delivery ex works, or only after further processing by the customer.
• Contractual agreements with customers about which party supplies which data, in case the product passport is compiled in the chain by a party further down.
• A file with technical datasheets and certificates that are already being prepared per project or order, so that these can later be traced per delivered batch.
• A subscription to notifications about the publication of the delegated act, so that the actual mandatory date is not missed — see the page about when the product passport becomes mandatory for aluminium for the current status.